Lexology February 2, 2023
On January 30, 2023, the U.S. Centers for Medicare & Medicaid Services (CMS) issued a final rule making significant changes to the 2012 audit methodology for the Medicare Advantage (MA) Risk Adjustment Data Validation (RADV) program. The rule (RADV Final Rule) finalizes changes that were first proposed in November 2018 and is scheduled to take effect on April 3, 2023, but is certain to be the subject of litigation challenges in the coming months. With some modifications to the proposed rule, CMS determined that it will extrapolate RADV audit findings beginning in payment year 2018 (rather than 2011 as proposed) but will not apply an adjustment factor, referred to as a Fee-for-Service (FFS) Adjuster, in RADV audits.
As a result...
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