CMS Announces Accelerated RADV Delete Deadlines: Is Your Organization Prepared?

The Centers for Medicare & Medicaid Services (CMS) has issued formal deadlines for the submission of closed period deletes to the Risk Adjustment Processing System (RAPS) and Encounter Data Processing System (EDPS) in preparation for Risk Adjustment Data Validation (RADV) audit sampling for Payment Years (PYs) 2020 through 2024. Sampling is scheduled to begin in June 2025, leaving a narrow window for Medicare Advantage Organizations (MAOs) to reconcile unsupported diagnoses before beneficiaries are selected for audit.

To ensure data integrity ahead of audit sampling, CMS has set the following deadlines for closed period deletes:

These deadlines represent the final opportunity to remove unsupported diagnosis codes before RADV sampling begins. Late submissions will not be accepted. 

Operational Implications

Effective immediately:

• RAOR reporting for PYs 2020–2024 should be suspended as of these deadlines until CMS provides further instruction.

• No additional deletes will be processed via RAPS or EDPS beyond the posted deadlines.

• Compliance with SSA §1128J(d) and 42 CFR 422.310 remains mandatory. MAOs are still responsible for identifying and correcting inaccurate submissions based on their best knowledge, information, and belief.

Recommended Actions for MAOs

To minimize audit exposure and maintain compliance, MAOs should:

• Review MAO-004 reports and ensure diagnosis codes are fully supported by medical record documentation

• Identify and remove non-persistent or unsupported HCCs prior to the applicable deadline

• Coordinate internal audit and coding review resources to ensure timely validation

• Monitor CMS communications for updates on when data correction and overpayment reporting can resume

Rebellis Can Help

The upcoming RADV audits represent one of the most comprehensive oversight efforts CMS has undertaken to date. The RADV delete submission deadlines are quickly approaching, and the potential financial impact of extrapolated recoveries make proactive action essential. 

Our team of expert consultants is equipped to guide organizations through every phase of this accelerated timeline.

We provide:

• Comprehensive RADV readiness assessments

• Retrospective data validation and closed period delete support

• Targeted chart audits and clinical documentation reviews

• Compliance guidance that is aligned with CMS regulatory requirements

• Operational and coding strategies to reduce audit exposure

Our experienced consultants will work collaboratively with your compliance, coding, and risk adjustment teams to ensure audit readiness and long-term program integrity.

If your organization has not yet initiated a review of previously submitted data, the time to act is now.  Contact us at partners@rebellisgroup for help.

We’re here to help you prepare, respond, and mitigate risk.