PY2020 MA RADV Audit Notices Are Here — And This Is the Largest Cohort Yet

CMS released the PY2020 Medicare Advantage RADV audit notices on Friday—and this round is significant. A total of 471 Medicare Advantage contracts are now under review, making it the largest audit cohort to date.

With timelines already in motion, plans should be preparing now. Key dates to keep on your radar:

April 3, 2026	Enrollee Data List (EDL) available
April 13, 2026	Medical record submission opens
August 28, 2026	Submission deadline
September 11, 2026	Hardship deadline

What’s Different This Year?

This cycle introduces several notable shifts that will directly impact audit strategy and execution:

• Larger, stratified sample sizes

  CMS is expanding its sampling methodology, increasing both volume and complexity.

• Expanded audit population

  The scope has moved from the top decile to the top quartile, pulling in a broader set of contracts than ever before.

• Stricter HCC validation standards

  CMS is taking a more rigid stance: if a diagnosis was not submitted correctly—or does not align within the same HCC hierarchy—it will not be counted.

• Ongoing uncertainty around extrapolation

  Questions remain following Humana Inc. v. Becerra, leaving plans navigating an unclear financial risk landscape.

Where Plans Often Struggle

One of the most common pitfalls is approaching RADV like a traditional coding exercise.

It’s not.

RADV is an audit-level validation process. That means:

• Every diagnosis must be supported

• Every date of service must be verified

• Every record must withstand scrutiny against what was submitted

At the same time, plans must identify unsupported diagnoses and missed conditions—a balance that standard production coding workflows aren’t built to manage.

How Rebellis Helps Plans Navigate RADV

RADV success requires a purpose-built audit approach—and that’s where Rebellis comes in.

Rather than forcing audit work through production coding teams, Rebellis partners with plans to stand up a dedicated audit function that aligns with CMS expectations. Our support includes:

• Chart validation

  Comprehensive review of every record tied to sampled members, ensuring each diagnosis is fully supported and defensible.

• Independent quality assurance (QA)

  A second layer of review to catch discrepancies, reduce error rates, and strengthen audit confidence.

• Targeted risk-based reviews

  Focused analysis on high-impact areas, including unsupported HCCs and potential gaps, helping plans prioritize where it matters most.

• Audit readiness and workflow design

  Guidance on structuring internal processes so teams can handle RADV efficiently—without disrupting ongoing operations.

• Scalable audit support

  The ability to ramp up quickly as submission deadlines approach, without overburdening internal staff.

The Bottom Line

If your contract is included in this year’s cohort, the time to act is now. Early organization, the right workflows, and a clear audit strategy will make all the difference as deadlines approach.

RADV isn’t just about getting charts out the door—it’s about making sure every submission can stand up to scrutiny. With the stakes higher than ever, having the right audit partner in place can be a critical advantage.

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