CMS Releases Updated Risk Adjustment Data Validation (RADV) Questions & Answers and Audit Timeline

CMS recently released an updated Risk Adjustment Data Validation (RADV) Questions & Answers document along with a schedule outlining when upcoming Medicare Advantage RADV audits are expected to begin by payment year. While the release does not introduce major policy changes, it does provide something many organizations have been looking for, which is greater transparency into how CMS intends to sequence future RADV audits.

For those working in Medicare Advantage risk adjustment, this type of visibility is helpful. Understanding the anticipated audit cadence allows plans and operational teams to begin planning ahead and evaluating whether their internal processes and resources are positioned to support upcoming audits.

Based on the information CMS released, RADV audits are expected to be initiated according to the following timeline:

Payment Year	Expected Audit Initiation
2020	March 2026
2021	May 2026
2024	August 2026
2023	November 2026
2022	January 2027
2025	April 2027

One aspect of the schedule that stands out is the audit years are not listed in chronological order. CMS notes in the updated Q&A that the sequencing of audits may vary depending on factors such as data readiness, sampling methodology, and operational capacity. While this may initially seem unusual, it reflects the logistical realities of administering large-scale national audit programs.

The timing is particularly noteworthy because many organizations are still navigating ACA RADV activities. As a result, risk adjustment, compliance, and coding teams may find themselves supporting more than one RADV program at the same time.

When multiple audit programs occur within overlapping timeframes, the operational implications become significant.

Organizations may need to carefully evaluate areas such as:

• Resource allocation

• Chart retrieval capacity

• Coding validation workflows

• Internal audit and compliance review processes

Each of these functions can become strained when several audit activities are occurring simultaneously. Beyond the regulatory discussion, the real challenge for many plans will be operational execution. RADV audits require coordination across multiple teams, including analytics, chart retrieval, coding, compliance, and finance, and the timelines can move quickly once audit notices are issued.

The most important takeaway from this update may simply be that the timeline is now visible. With audits beginning soon and additional years already scheduled behind them, organizations have an opportunity to revisit their RADV readiness. This may include reviewing internal workflows, confirming chart retrieval strategies, validating coding review processes, and ensuring the right resources are in place to support the work ahead.

Organizations do not have to navigate this process alone. Preparing for RADV requires a combination of strong analytics, efficient chart retrieval strategies, experienced coding review, and clear operational workflows. Whether a plan needs assistance evaluating readiness, validating coding and documentation, or helping manage the audit response process, having the right expertise in place can make a significant difference.

In addition, many organizations find that coding capacity becomes a constraint during RADV audits, especially when internal coding teams are already supporting retrospective programs, overreads, or other risk adjustment initiatives. Access to experienced coding resources can help ensure charts are reviewed quickly and accurately, while maintaining alignment with CMS risk adjustment guidelines.

As audit notices begin to arrive, now is the time to evaluate your organization’s preparedness. If your team is looking for additional support, or simply wants to discuss strategies for approaching upcoming RADV activity, we are always happy to connect and help organizations think through the operational, coding, and compliance considerations ahead.

How Rebellis Can Help

As audit notices begin to arrive, now is the time to evaluate your organization’s preparedness. If your team is looking for additional support, or simply wants to discuss strategies for approaching upcoming RADV activity, we are here to support.

Contact us