No Extensions Will Be Granted
On May 30, 2025, the Centers for Medicare & Medicaid Services (CMS) released an official HPMS memo titled “Deadlines for the Submission of Risk Adjustment Data for Risk Adjustment Data Validation Sampling.” The memo outlines a critical compliance deadline for all Medicare Advantage Organizations (MAOs):
All closed period deletes for Payment Year (PY) 2020 must be submitted no later than June 16, 2025.
No extensions will be granted.
This is a firm, non-negotiable deadline. MAOs must ensure timely review and submission to maintain compliance and minimize RADV-related financial risk.
What Are Closed Period Deletes?
Closed period deletes refer to the removal of diagnosis codes submitted for payment in prior years that are no longer eligible for standard correction. These deletes are allowed specifically to prepare for Risk Adjustment Data Validation (RADV) audits, which assess the accuracy of risk-adjusted payments.
CMS permits these deletions prior to the RADV audit sample selection, offering health plans a final opportunity to align submitted data with the supporting clinical documentation.
Key Takeaways from the Memo
Deadline: All deletes for PY2020 must be submitted by June 16, 2025.
Applies to: Submissions via both RAPS and EDPS.
No exceptions or extensions will be provided after the deadline.
Deletions submitted after this date will not be excluded from RADV sample consideration.
Implications for MA Plans
This deadline is especially significant in light of CMS’s broader initiative to accelerate the RADV audit timeline. CMS has announced its intention to complete all remaining RADV audits for PY2018 through PY2024 by early 2026 — compressing seven years of audit activity into a short timeframe.
MAOs should take the following immediate steps:
Conduct a thorough internal review of all PY2020 diagnosis submissions.
Identify and submit unsupported or invalid diagnoses for deletion.
Ensure that retained codes are fully supported by appropriate medical record documentation.
Confirm that deletes are submitted through the appropriate RAPS or EDPS pathways by the deadline.
Compliance Risk and Financial Impact
Failure to remove unsupported diagnoses before sampling could significantly increase audit exposure and result in repayment obligations. Given the lack of extensions, plans that miss this window may have no recourse to mitigate findings for PY2020 RADV.
Conclusion
The June 16, 2025 deadline represents a critical milestone in CMS’s evolving approach to RADV enforcement. Health plans should act with urgency to complete their data reviews and deletions.
Proactive data validation today is the key to audit readiness tomorrow.
For support with closed period deletes, RADV audit preparation, or risk adjustment data integrity, contact the team at Health Data Max. Our experts assist MAOs in achieving full compliance and minimizing risk exposure.