May 30, 2025 — Baltimore, MD
The Centers for Medicare & Medicaid Services (CMS) has issued a notice to all Medicare Advantage (MA) organizations regarding upcoming Risk Adjustment Data Validation (RADV) audits. CMS is now accelerating audit activities for Payment Years (PYs) 2018 through 2024, and MA plans must act quickly to meet the deadlines for submitting risk adjustment data corrections (closed period deletes).
What’s Happening?
CMS is initiating RADV sampling for PYs 2020 through 2024 starting June 2025.
MA plans must submit any known data deletes in RAPS and/or EDPS before the specified deadlines.
Once a deadline passes, CMS instructs plans to pause all data corrections and overpayment reports for that PY until further notice.
Submission Deadlines (Point by Point)
For PY 2020:
System: RAPS and EDPS
Dates of Service: January 1, 2019 – December 31, 2019
Deadline: June 16, 2025
For PY 2021:
System: RAPS and EDPS
Dates of Service: January 1, 2020 – December 31, 2020
Deadline: June 23, 2025
For PY 2022:
System: EDPS only
Dates of Service: January 1, 2021 – December 31, 2021
Deadline: June 30, 2025
For PY 2023:
System: EDPS only
Dates of Service: January 1, 2022 – December 31, 2022
Deadline: July 8, 2025
For PY 2024:
System: EDPS only
Dates of Service: January 1, 2023 – December 31, 2023
Deadline: July 15, 2025
What MA Plans Need to Know
Do not submit overpayment reports or auditable estimates to the RAOR module for PYs 2020–2024 after the deadlines listed above.
Do continue to comply with Section 1128J(d) of the Social Security Act and 42 CFR 422.326, even while submissions are paused.
CMS will notify MA organizations via HPMS when it’s time to resume submissions and reporting.
Once that notice is given, plans must report and return overpayments for members not included in the RADV sample for the given PY.
Additional Guidance
MA organizations should review the following HPMS memos for details about handling encounter data deletes:
March 15, 2024 – Support for Use of Encounter Data in Overpayment Reruns
May 21, 2024 – Follow-Up to May 1, 2024 “Use of Encounter Data” User Group
Note: CMS will not make payment adjustments at this time based solely on the closed period deletes. Future HPMS memos will provide updates on overpayment reruns for these years.
Questions?
For RADV audit questions: 📩 RADV@cms.hhs.gov
For RA data submissions and overpayment questions: 📩 RiskAdjustmentPolicy@cms.hhs.gov
Official CMS RADV page: cms.gov/radv
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