CMS Releases HPMS Memo on Risk Adjustment Data Submission Deadlines for PY 2025–2027

CMS has issued an HPMS memo titled: “Deadlines for Submitting Risk Adjustment Data for Use in Risk Score Calculation Runs for Payment Years 2025, 2026, and 2027.”

This memo serves as official notice to:

• Medicare Advantage Organizations

• PACE Organizations

• Medicare-Medicaid Plans

• Cost Contractors

• Demonstration Plans

Organizations must adhere to strict deadlines for submitting Risk Adjustment Processing System (RAPS) and Encounter Data System (EDS) data. All submissions must be received by 8:00 PM ET on the designated deadline date to be included in the relevant model run. Late submissions will not be reflected in CMS’s risk score calculations.

Key Submission Details:

• Initial Deadline: Data included in the initial model run

• Mid-Year Deadline: Data submitted after the initial but before mid-year deadline will be included in the mid-year run

• Final Deadline: Data submitted after the mid-year but before the final deadline will be included in final reconciliation

• Post-Final Deadline: Data submitted after the final deadline will not be used in any payment calculation for that year (per 42 CFR § 422.310(g)). Only deletes may be processed after this point.

  
  

  Read the full memo here.

  
  

  

  
  

  Need help navigating risk adjustment submission timelines? Rebellis Group can help you design an end-to-end submission strategy that ensures compliance, meets CMS deadlines, and supports operational efficiency.

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