CMS Sheds Light on its Timeline for Expedited RADV Audits

Shortly following its announcement of sweeping changes to RADV audits, CMS shared industry guidance last week regarding upcoming deadlines for the submission of risk adjustment data corrections in advance of RADV sampling. While this type of notice is routine in advance of RADV audit sampling, it is unique as it covers five plan years (2020 through 2024).  CMS instructs Medicare Advantage organizations (MAOs) to submit data corrections for PY 2020 through PY 2024 with deadlines ranging from June 16, 2025, through July 15, 2025.  Based on these dates and CMS’s target of completing these audits by early 2026, we believe that MAOs can expect to receive audit notices on a rolling basis beginning in the mid to late summer. 

CMS’s decision to alter the long-standing audit time frame results in MAOs having a far shorter time to correct data than they have in the past with significant variation across the plan years that are addressed in the notice.  For example, for PY 2020, an MAO has until June 16, 2025, to submit data corrections – this amounts to approximately 4 years 6 months from the close of the plan year.  During that time MAOs have identified a variety of errors and submitted them for corrections.  Compare this to PY 2024 audits for which MAOs must submit data corrections by July 15, 2025 – this only allows the MAOs 6 1/2 months from the close of the plan year.  While many MAOs will likely have identified some errors during the plan year, they are losing a significant amount of time that is often used to address any identified errors. 

In the memorandum, CMS also announced that it has finished the PY 2019 audit sampling and that the MAOs that have been selected would receive their notices soon.  

Another notable point is that CMS does not plan to make payment adjustments at this time for any closed period deletes submitted for PY 2020 through PY 2024. Instead, it will announce the rerun of these PYs and their related overpayment data submission deadlines in future industry guidance (HPMS memos).

We will continue to monitor CMS communications for information regarding the volume of contracts that will be audited, the process updates, and the speed with which the audits will be completed.

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