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. [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.
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.
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.
CMS sends an Audit Notice to the contract's CEO, CFO, COO, and Medicare Compliance Officer. For PY2020, the EDL becomes available in CDAT on April 3, 2026. The medical record submission window opens April 13 and closes August 28, 2026 at 11:59pm EST. [CMS Source ↗]
For PY2020, CMS assigns sample sizes across four strata: top 10 contracts receive 200, the next group 100, then 50, and smallest contracts receive 35. In PY2019, all contracts received 35. Plans should check their EDL in CDAT to confirm their specific sample size. [CMS Source ↗]
MA Con-RADV HCC validation coding requires documenting every HCC on every date of service, ranking documentation quality per HCC, and evaluating which records to submit. CMS allows a maximum of two medical records per audited HCC. Standard retrospective coding captures an HCC once, making Con-RADV coding significantly more specialized. [CMS Source ↗]
CMS has published a schedule covering six payment years: PY2020 through PY2025, running from March 2026 through an estimated August 2027. For most of that period, plans will be running two Con-RADV audits simultaneously. Notably, the order is non-sequential — CMS is auditing PY2024 before PY2023 and PY2022. [CMS Source ↗]
Validira 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, and dedicated audit management with weekly status updates.
Validira maintains pre-audit readiness so that upon CMS notification, the team can begin receiving data 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. Plans should not assume the order reflects risk prioritization.
An MA Organization has up to 60 days to appeal medical record review determinations and/or payment error calculations. The appeals process is governed by 42 CFR 422.311(c). CMS published updated RADV Reconsideration Appeal Guidance in January 2025. Validira's coding SMEs can support plans preparing appeals. [CMS Source ↗]
CMS uses a risk-based approach applying advanced data analytics and results from past CMS and HHS OIG audits. Contracts are selected based on predicted risk score reduction — enrollees ranked in the top quartile of improper payment prediction models are prioritized. [CMS Source ↗]
CMS has not yet decided. The PY2020 audit is designed to support extrapolated recoveries, but CMS will decide at a later date. Note the 2023 extrapolation rule was vacated by a federal district court in 2025 and is under appeal, adding further uncertainty. [CMS Source ↗]
Audit notices sent March 20, 2026. EDL available in CDAT: April 3, 2026. Submission window opens: April 13, 2026. Submission deadline: August 28, 2026 at 11:59pm EST. Hardship Exception Request deadline: September 11, 2026 at 11:59pm EST. [CMS Source ↗]