Lexology June 20, 2025
On May 21, 2025, the Centers for Medicare & Medicaid Services (“CMS”) announced a substantial expansion of its Risk Adjustment Data Validation (“RADV”) audit program for all Medicare Advantage (“MA”) plans. Effective immediately, CMS will audit all eligible MA plans annually and aims to complete outstanding audits for prior payment years (“PY”) 2018-2024 by early 2026. These changes follow CMS’s 2023 final rule allowing extrapolation of RADV overpayments and signal an era of heightened scrutiny of MA billing practices under the current administration.
Background
CMS’s recent announcement aligns with broader federal efforts to curb fraud, waste and abuse in federally funded programs. The increased oversight of MA is not surprising given the program’s size and evolving federal priorities. The MA...
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