Your Plan Was
Selected.
Now What?
Your MA RADV medical record submission window closes August 28, 2026. The Enrollee Data List (EDL) is available April 3 and the submission window opens April 13. Sample sizes range from 35 to 200 enrollees per contract. And PY2021 Con-RADV audits are expected to launch in May 2026, before your PY2020 window even closes.
The plans best positioned will be those that move quickly with experienced external partners.
RADV Coding Is Fundamentally Different
Many plans underestimate how different MA Con-RADV HCC validation coding is from standard retrospective coding. These MA RADV audits require a fundamentally different approach — and your existing internal coding team may not be equipped for what this audit actually requires.
PY2020 Sample Sizes: 35 to 200 Enrollees Per Contract
CMS assigns sample sizes based on contract size. The top 10 contracts by sampling frame size receive 200 enrollees. The next tier receives 100, then 50, with the smallest contracts receiving 35. In PY2019, all contracts received just 35. The jump to 200 for larger plans represents a nearly 6x increase in volume — hundreds of charts, thousands of dates of service. [CMS Source ↗]
This Isn't One Audit.
It's 18 Months of Overlapping Pressure.
CMS has announced plans to restart MA RADV audits on an expedited, cascading schedule, with a new payment year launching approximately every 3 months. Plans with multiple contracts will face nearly simultaneous audits across multiple payment years.
Built for MA RADV. Ready Right Now.
Validira from ATTAC Consulting Group is a specialized MA RADV coding and audit management solution purpose-built for Con-RADV audits — not a generic coding shop repurposed for audit season. We've been doing this for nearly a decade, and our entire infrastructure is designed for the complexity of Con-RADV audits.
ATTAC has been a game-changer for us. They are agile, responsive, and willing to bend over backwards to provide us with what we need. Compared to past audit partners, the experience has been night and day. We only wish we had brought them on sooner.
No One on Your Engagement Is Figuring This Out for the First Time
Our Validira leadership team brings decades of MA RADV experience, not generalists who've been reassigned. Every lead on your engagement has done this before, many times over.
Let's Talk About
Your PY2020 Audit
Our team is ready to move immediately. A 30-minute call is all it takes to understand your contract situation and outline how Validira can support your audit response.
Frequently Asked Questions
Everything your Risk Adjustment team needs to know about navigating a PY2020 MA RADV audit — including Con-RADV coding requirements, the CMS audit schedule, sample sizes, and appeals.
CMS sends an Audit Notice to the contract's CEO, CFO, COO, and Medicare Compliance Officer. For PY2020 MA RADV audits, the Enrollee Data List (EDL) becomes available in CMS's CDAT system on April 3, 2026. The medical record submission window opens April 13 and closes August 28, 2026 at 11:59pm EST. Plans must submit up to two medical records per audited HCC for each sampled enrollee via CDAT. [CMS Source ↗]
For PY2020 Con-RADV audits, CMS assigns sample sizes based on contract size across four strata. The top 10 contracts by sampling frame size receive 200 sampled enrollees. The next group receives 100, the next 50, and the smallest contracts receive 35. In the PY2019 cycle, all contracts received 35. Plans should check their Enrollee Data List in CDAT to confirm their specific sample size. [CMS Source ↗]
MA Con-RADV HCC validation coding requires coders to document every instance of an HCC on every date of service within a record, rank documentation quality per HCC, and evaluate which records to submit. CMS allows a maximum of two medical records per audited HCC — so identifying the strongest, most defensible records is critical. Standard retrospective coding typically captures an HCC once on a single date of service, making Con-RADV coding significantly more specialized and time-intensive. [CMS Source ↗]
CMS has published an official MA RADV audit schedule covering six payment years: PY2020 through PY2025. Audits initiate approximately every two to three months beginning March 2026, running through an estimated August 2027. Notably, the order is not sequential — CMS is auditing PY2024 before PY2023 and PY2022 due to data processing schedules. For most of 2026 and into 2027, plans will be running two Con-RADV audits simultaneously on top of routine risk adjustment activities. [CMS Source ↗]
Validira from ATTAC Consulting Group provides comprehensive MA RADV support: HCC validation coding via an NLP and AI-enabled platform, medical record retrieval, RADV Cycle Management Reporting with 24/7 portal access, coding quality assurance, documentation strength ranking to guide record selection, and dedicated audit management with weekly status updates.
Validira maintains pre-audit readiness so that upon notification of a CMS Con-RADV audit, the team can begin receiving member data, claims, diagnosis, and provider information within days. Pre-configured data exchange pathways, portal access, and coder training protocols allow for rapid launch with minimal ramp-up time on your end.
According to CMS, the MA RADV audit order is not always sequential. CMS may conduct audits for certain payment years ahead of others based on data processing schedules — specifically, to use the best available data when establishing audit sampling frames and selecting enrollee samples. Plans should not assume the order reflects risk prioritization; all contracts in the schedule should prepare accordingly.
An MA Organization that disagrees with MA RADV audit results has up to 60 days to appeal medical record review determinations and/or payment error calculations included in an issued audit report. The appeals process is governed by regulations at 42 CFR 422.311(c). CMS published updated RADV Reconsideration Appeal Guidance in January 2025. Validira's coding SMEs can provide support for plans preparing appeals. [CMS Source ↗]
CMS uses a risk-based approach to select MA contracts for Con-RADV audits, applying advanced data analytics and leveraging results from past audits conducted by CMS and the HHS Office of Inspector General. Contracts are selected based on predicted risk score reduction — specifically, enrollees ranked in the top quartile of improper payment prediction models are prioritized for the sampling frame. [CMS Source ↗]
CMS has not yet decided. The PY2020 MA contract-specific RADV audit is designed to support extrapolated recoveries, but CMS has explicitly stated it will decide at a later date whether to apply extrapolation or collect only the specific overpayments tied to sampled enrollees. Note that the 2023 extrapolation rule was vacated by a federal district court in 2025 and is currently under appeal, which adds further uncertainty. [CMS Source ↗]
Per the official CMS PY2020 Audit Methods and Instructions: Audit notices sent March 20, 2026. Enrollee Data List (EDL) available in CDAT: April 3, 2026. Medical record submission window opens: April 13, 2026. Medical record submission deadline: August 28, 2026 at 11:59pm EST. Hardship Exception Request deadline: September 11, 2026 at 11:59pm EST. [CMS Source ↗]