Understanding the CMS RADV Audit Timeline

CMS Publishes RADV Audit Timeline and Program Updates for Medicare Advantage

On March 4, 2026, the Centers for Medicare & Medicaid Services (CMS) released an important update to the Medicare Advantage Risk Adjustment Data Validation (RADV) program.

CMS published:

• an updated RADV Questions & Answers document
• a RADV audit initiation schedule by payment year
• updated audit methodology documentation
• datasets listing audited contracts and audit results
• updated payment error calculation methodologies

While the release may appear procedural, it provides Medicare Advantage organizations with something that has historically been difficult to obtain in advance: visibility into the expected RADV audit cadence.

For risk adjustment, compliance, and coding teams, this visibility can significantly influence operational planning and audit readiness.

RADV Audit Initiation Schedule

CMS published a schedule outlining when audits are expected to begin for several payment years.

RADV Audit Initiation Timeline

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

One detail immediately stands out: the order is not strictly chronological.

CMS explains in the updated Q&A that audit years may be initiated out of order due to operational factors such as:

• data readiness
• sampling preparation
• operational capacity

Managing RADV audits across hundreds of Medicare Advantage contracts requires complex coordination, and the sequencing reflects those operational realities.

Consolidation of RADV Guidance

The March 2026 update also introduces a consolidated RADV Questions & Answers document.

Previously, CMS had published separate FAQ documents for different payment years.
Those materials have now been merged into a single reference document.

This consolidation simplifies guidance for organizations working in risk adjustment and provides a clearer view of CMS’s expectations regarding:

• audit operations
• documentation requirements
• audit timelines
• operational processes

For compliance and coding teams, this centralization makes RADV program guidance easier to reference and interpret.

Expanded RADV Documentation and Historical Data

The CMS RADV documentation page now also provides expanded access to program materials and historical audit datasets.

These include:

Audit Methodology and Instructions

CMS has published or updated RADV audit methodology documents for several payment years, including:

• PY 2019 RADV Audit Methods & Instructions
• PY 2018 RADV Audit Methods & Instructions

These documents describe the procedures CMS uses to:

• select audit samples
• review medical records
• validate diagnoses supporting HCC payments

Understanding these methodologies helps organizations anticipate how audits will be conducted.

Payment Error Calculation Methodologies

CMS also released payment error calculation methodology documents for earlier audit cycles, including:

• PY 2015
• PY 2014
• PY 2013
• PY 2012
• PY 2011

These documents explain how CMS calculates:

• payment errors identified during audits
• overpayment amounts
• financial recovery estimates

For finance and compliance teams, these methodologies provide insight into how audit findings translate into repayment obligations.

Publication of RADV Audit Results

Another significant component of the update is the release of datasets identifying audited contracts and audit findings.

CMS published downloadable spreadsheets showing:

• audited Medicare Advantage contracts
• identified overpayments
• audit results by payment year

These datasets currently cover earlier payment years, including:

• PY 2015
• PY 2014
• PY 2013
• PY 2012
• PY 2011

Making these results publicly available increases transparency into how the RADV program has historically identified payment errors across Medicare Advantage contracts.

RADV Dispute and Appeal Guidance

The CMS RADV documentation portal also includes guidance on the audit dispute and appeal process.

The document “MA RADV Audit Dispute and Appeal Guidance – Level 1: Reconsideration” outlines how Medicare Advantage organizations may challenge audit determinations through CMS’s formal reconsideration process.

This guidance is critical for organizations preparing to respond to RADV findings.

Why the Timeline Matters Operationally

The newly published audit schedule provides organizations with a clearer view of when RADV audits may begin for upcoming payment years.

This timing is particularly relevant because many organizations are simultaneously managing multiple audit programs.

In addition to Medicare Advantage RADV, some organizations are also responding to ACA RADV audits, which operate under different documentation requirements.

Although the programs share the same acronym, their scope differs significantly.

MA RADV primarily evaluates whether the medical record supports the diagnosis used to generate an HCC payment.

ACA RADV, by contrast, often requires broader documentation packages that may include:

• enrollment verification
• claims data
• additional supporting documentation

When these audit programs occur within overlapping timeframes, compliance, coding, and risk adjustment teams may need to support multiple audit activities simultaneously.

Preparing for RADV Audit Activity

With greater visibility into the audit timeline, organizations may consider reviewing their readiness across several operational areas.

Key preparation areas may include:

• Chart Retrieval Workflows

  Ensuring medical records can be retrieved quickly for sampled members.

• Coding Validation Processes

  Confirming that submitted diagnoses are fully supported by documentation.

• Documentation Review Capacity

  Verifying provider documentation meets CMS requirements for HCC validation.

• Internal RADV Response Procedures

  Establishing clear workflows for responding to audit requests and managing documentation submissions.

Organizations that maintain structured documentation and coding validation processes may be better positioned to respond effectively when audit requests are initiated.

A More Transparent RADV Environment

In many ways, this CMS release signals a broader evolution of the RADV program.

Historically, RADV audits have been difficult for organizations to anticipate.

The publication of an audit initiation schedule, consolidated program guidance, methodology documentation, and historical audit datasets suggests CMS is moving toward greater transparency around RADV operations and oversight.

For Medicare Advantage organizations responsible for risk adjustment programs, that visibility can help guide planning, prioritization, and operational readiness in the months ahead.

Sometimes a short CMS update provides exactly the information needed to prepare for what comes next.

And for organizations operating in the Medicare Advantage risk adjustment environment, understanding the RADV audit timeline is an important step toward that preparation