Health Affairs November 17, 2025
Introduced with bipartisan sponsorship in March of 2025, the No Unreasonable Payments, Coding, or Diagnoses for the Elderly (No UPCODE) Act intends to address a major problem in Medicare payment policy—the ability of insurers in the Medicare Advantage (MA) program to extract additional payments by exploiting the program’s risk adjustment system. The bill—just a few pages of brief text—includes three provisions to limit payments to MA plans for increasing risk scores by coding diagnoses more intensively.
First, the bill instructs the Centers for Medicare and Medicaid Services (CMS) to use two years of data (instead of one) to determine beneficiaries’ diagnoses, thereby limiting rewards for documenting the continued presence of a condition—a practice encouraged by plans to boost risk scores....
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