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CMS Risk Adjustment Data Validation (“RADV”) Audits

A Comprehensive Guide for Medicare Advantage (“MA”) Plans

The Risk Adjustment Data Validation (“RADV”) program is Centers for Medicare & Medicaid Services’ (“CMS”) primary mechanism for validating the accuracy of HCC-based risk-adjusted payments made to Medicare Advantage Organizations (“MAOs”). By auditing medical record documentation for a statistically valid sample of enrollees, CMS ensures that diagnosis codes used to calculate payments are properly supported.

On May 21, 2025, CMS announced plans to conduct RADV audits for all MAOs, heightening the need for proactive readiness and comprehensive response planning. With CMS expanding RADV audits to all MAOs, plans face increased regulatory risk, financial exposure, and documentation scrutiny.

Our Healthcare Risk Management & Advisory team includes certified coders and clinical experts with a proven track record in RADV and Risk Adjustment strategy. We have a scalable team that can support audits across regions and lines of business.

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