ACA Supplemental Claims Are Reshaping Risk Adjustment Strategy

Supplemental claims have become a critical driver of ACA risk adjustment accuracy, financial performance, and RADV preparedness for health plans. According to Wakely’s 2025 ACA Supplemental Claims Impact white paper, supplemental claims increased average Plan Liability Risk Scores (PLRS) by 7.3% in the individual market and 3.3% in the small group market, with results varying considerably across issuers and states.

For healthcare executives, actuarial leaders, and risk adjustment teams, the findings underscore the need for a strategic approach to supplemental claims. Successful programs focus on targeted chart reviews, accurate documentation, coding integrity, and operational efficiency to maximize risk score accuracy while mitigating compliance and RADV audit risk.

Key Takeaways

  • Supplemental claims continue to have a growing impact on ACA risk adjustment performance.
  • Risk score accuracy depends on more than coding. It requires coordinated clinical, operational, and data strategies.
  • Targeted supplemental claims programs can improve financial outcomes while supporting compliance and documentation quality.
  • Organizations should evaluate supplemental claims alongside HCC recapture rates, coding accuracy, risk score trends, and audit performance.
  • Healthcare organizations that invest in a comprehensive ACA risk adjustment strategy are better positioned to improve reimbursement accuracy, reduce audit exposure, and strengthen long-term financial performance.
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