CMS Pauses New RAOR Reports: What Medicare Advantage Organizations Need to Know
CMS HPMS Update | October 16, 2026
The Centers for Medicare & Medicaid Services (CMS) has announced a temporary pause on new submissions to the Risk Adjustment Overpayment Reporting (RAOR) module, effective October 19, 2026.
Starting October 19, 2026, Medicare Advantage (MA) organizations and other entities that submit risk adjustment data can no longer submit new plan-identified overpayment reports through the module until CMS announces that the updated module is available.
Why Is CMS Pausing RAOR Submissions?
CMS is updating the RAOR module to streamline the user experience and improve the reporting process. During this transition, organizations cannot submit new plan-identified overpayment reports through the module until CMS announces its reopening.
The key distinction: A pause in RAOR reporting does not mean a pause in risk adjustment corrections or applicable compliance responsibilities.
What Is Changing?
The October 16 memorandum outlines three key changes:
New RAOR submissions: The module will not accept new plan-identified overpayment reports beginning October 19, 2026.
Existing RAOR reports: Organizations can continue editing previously submitted overpayment reports as necessary.
Module reopening date: CMS will issue another HPMS notification before the new RAOR module is deployed, with details about the updates and the date when organizations may resume reporting new plan-identified overpayments.
Critical Risk Adjustment Correction Deadlines
The temporary RAOR closure does not remove the obligation to submit required risk adjustment data corrections through the appropriate CMS systems. CMS reminds organizations to continue submitting applicable corrections through the Risk Adjustment Processing System (RAPS) and/or the Encounter Data System (EDS).
Payment Year (PY) 2021: October 30, 2026
Payment Year (PY) 2020: November 30, 2026
These deadlines relate to the respective overpayment reruns identified in the memorandum. The required corrections must be submitted through RAPS and/or EDS by the applicable deadlines.
What this means for operations teams: Do not wait for the RAOR module to reopen before continuing required corrections through RAPS and/or EDS. Review outstanding work, confirm responsibilities, and track progress against both deadlines.
RAOR Is Not a Replacement for Risk Adjustment Corrections
The RAOR module should be used to report and return plan-identified risk adjustment overpayments in the limited circumstances described by CMS. It is distinct from the systems used to submit and correct risk adjustment data. For guidance on when RAOR should be used, CMS points to its May 21, 2024, HPMS memorandum, Follow Up to May 1, 2024 “Use of Encounter Data in Overpayment Reruns” User Group for All Organizations Who Submit Risk Adjustment Data.
Once CMS announces that the new RAOR module has been deployed, organizations can resume reporting new plan-identified overpayments when the appropriate circumstances apply. The October 2026 memorandum reinforces that organizations must continue correcting risk adjustment data through the appropriate CMS systems even while RAOR is temporarily unavailable.
In practical terms, teams need to distinguish between:
Reporting a plan-identified overpayment through RAOR, where applicable.
Submitting required risk adjustment data corrections through RAPS and/or EDS.
Tracking applicable deadlines and maintaining records of correction and reporting activities.
What Medicare Advantage Organizations Should Do Now
The immediate priority is to keep correction work moving while preparing for the updated RAOR module.
1. Review outstanding corrections
Identify work associated with the PY 2021 and PY 2020 overpayment reruns. Confirm responsibilities, progress, and the applicable deadlines.
2. Continue required RAPS and EDS submissions
Do not treat the RAOR closure as a reason to delay required risk adjustment data corrections. Continue submitting corrections through the appropriate CMS systems.
3. Maintain existing RAOR reports
Previously submitted overpayment reports can still be edited. Review outstanding reports and make necessary updates where applicable.
4. Monitor HPMS announcements
CMS will provide further information about the updated module and when new reports can resume. Ensure relevant compliance, risk adjustment, and operations teams receive the update.
5. Keep compliance and submission teams aligned
Coordinate across risk adjustment, compliance, and submission operations to track outstanding corrections, reporting responsibilities, and deadlines.
6. Document progress and follow-up actions
Maintain a clear record of outstanding correction work, submission status, responsible teams, and next steps. This helps organizations manage deadlines and maintain visibility while the RAOR module is being updated.
The Regulatory Responsibilities Remain
The CMS memorandum makes clear that the temporary closure does not relieve Medicare Advantage organizations of their legal, regulatory, and contractual responsibilities regarding accurate risk adjustment data and applicable reporting requirements.
The memorandum references the following provisions:
Section 1128J(d) of the Social Security Act and 42 CFR § 422.326: Relevant to overpayment reporting and return obligations.
42 CFR § 422.310: Addresses Medicare Advantage risk adjustment data requirements.
42 CFR § 422.504(l)(2): Addresses the obligation to correct risk adjustment data based on an organization's best knowledge, information, and belief.
These requirements remain applicable during the temporary RAOR closure. Organizations should consult the original CMS memorandum and relevant regulatory guidance when determining their specific obligations.
Why This Matters for Risk Adjustment Operations
Accurate risk adjustment data, timely corrections, and clear reporting workflows are important to Medicare Advantage compliance. A temporary system change can create confusion if teams treat overpayment reporting and data correction as the same process. Organizations should maintain visibility into outstanding submissions, coordinate responsibilities across compliance and operations teams, and monitor CMS updates for changes to the RAOR process.
At Health Data Max, we recognize the importance of accurate encounter data, timely risk adjustment corrections, and proactive regulatory monitoring in supporting Medicare Advantage compliance and operational readiness.
Key Takeaway: A System Pause Is Not a Compliance Pause
CMS is updating the RAOR module, but Medicare Advantage organizations must keep their risk adjustment correction processes moving. With the October 30, 2026, deadline for PY 2021 corrections and the November 30, 2026, deadline for PY 2020 corrections approaching, teams should review outstanding work, continue required RAPS and/or EDS submissions, maintain existing RAOR reports as necessary, and monitor HPMS for the updated module announcement.
The bottom line: Pause new RAOR reports where the module requires it, not the correction process.
Stay informed. Maintain data accuracy. Keep compliance on track.
Questions?
For questions relating to this memorandum, contact the CMS Risk Adjustment Policy team at riskadjustmentpolicy@cms.hhs.gov.
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