The landscape of Medicare Advantage (MA) Risk Adjustment Data Validation (RADV) has undergone a seismic shift. CMS is no longer just sampling the industry; they are auditing every eligible contract, every year. With federal estimates indicating roughly $17 billion in annual overpayments due to unsupported diagnoses, the administration has mobilized an unprecedented enforcement strategy.

The February 2026 Wave

As of February 2026, the backlog era is over. CMS is expected to initiate Payment Year (PY) 2020 audits this month, continuing its aggressive catch-up schedule for the 2018–2024 payment years.

What Has Changed?

For health plan leadership, the threat is no longer just administrative: it is existential.

  • Massive Workforce Expansion: CMS has grown its team of medical coders from 40 to approximately 2,000 to expedite reviews.

  • AI-Enabled Scrutiny: New AI-powered support tools are being deployed to flag unsupported diagnoses with higher efficiency.

  • Extrapolation Penalties: Starting with PY 2018, findings from a small sample can be extrapolated across the entire contract, potentially leading to hundreds of millions in clawbacks.

  • Restored Deadlines: While CMS has restored the five-month record submission window, the audit frequency has increased to every three months.

Strategic Advantage: The ATTAC Solution

Defending your plan’s financial integrity requires more than just reactive coding. It requires a technical partner with the scale to match the federal workforce.

  • National Defense Scale: We coded 10% of all H-Contracts nationwide in the most recent RADV rounds.

  • Multi-Model Technicality: We specialize in the high-risk V22–V28 model transition, ensuring HCC validation remains robust across shifting years.

  • Precision Through Validra: Our unified risk adjustment solution uses proprietary Chart Quality Ranking to identify the most defensible medical records before they are submitted to CMS.

  • Auditor-on-Demand: We provide the surge support needed for the immediate 90-day execution window that follows an audit notice.

“ATTAC has been a game-changer for us. Compared to past audit partners, the experience has been night and day.” — Plan Executive, Top 5 National Health Plan

Consult with our RADV Strategists

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On February 2, 2026   /   Data Audit, Medicare Advantage RADV, Risk Adjustment