MA RADV Coding Is Fundamentally Different
Many plans underestimate how different MA Con-RADV HCC validation coding is from standard retrospective coding. That gap is where audit risk grows. The methodologies, documentation standards, and coder skill sets required are not interchangeable.
Sample Sizes Range from 35 to 200 Enrollees Per Contract
CMS assigns sample sizes based on contract size. The top 10 contracts receive 200 sampled enrollees; the next tier receives 100, then 50, with smaller contracts receiving 35. In PY2019, all contracts received 35. For larger plans, the jump to 200 represents a nearly 6x increase — hundreds of charts, thousands of dates of service, and surge demand that internal teams are rarely staffed to absorb alongside routine risk adjustment workflows.
This Isn't One Audit. It's Years of Overlapping Pressure.
CMS has published an official MA RADV audit schedule covering six payment years — PY2020 through PY2025 — launching approximately every two to three months from March 2026 through April 2027. For plans with multiple contracts, near-simultaneous Con-RADV audits will run concurrently with ACA HHS-RADV and ongoing retrospective coding cycles. For PY2021, CMS has also designed audits to calculate extrapolated overpayments, though whether extrapolation will be collected remains unresolved pending ongoing litigation.
MA RADV only. ACA HHS-RADV and HEDIS cycles also running. All dates per CMS RADV Audit Schedule. Subject to change.
Compiled by ATTAC Consulting Group / Validira.
Proven at Scale
Validira has supported MA Con-RADV audits across the country since the program's earliest cycles. These numbers reflect what we deliver.
Built for MA RADV. Ready When You Are.
Validira from ATTAC Consulting Group is a specialized MA Con-RADV coding and audit management solution, not a generic coding shop pressed into audit service. We've been doing this for nearly a decade, and our entire infrastructure is designed for the complexity that MA RADV demands.
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.
Frequently Asked Questions
What your Risk Adjustment team needs to know about navigating MA Con-RADV audits.
CMS sends an Audit Notice to the contract's CEO, CFO, COO, and Medicare Compliance Officer. The Enrollee Data List (EDL) is then made available in CDAT, followed by the opening of the medical record submission window. For PY2020, the submission window closes August 28, 2026 at 11:59pm EST. For PY2021, the submission window runs June 22 through November 6, 2026.
CMS assigns sample sizes across four strata based on contract size. The top 10 contracts by sampling frame receive 200 enrollees; the next group receives 100, then 50, with the smallest contracts receiving 35. In PY2019, all contracts received 35. Plans should check their EDL in CDAT to confirm their specific sample size for each audited payment year.
MA Con-RADV HCC validation coding requires documenting every HCC on every date of service within a record, ranking documentation quality per HCC, and evaluating which records are strongest for submission. CMS allows a maximum of two medical records per audited HCC. Standard retrospective coding captures an HCC once on a single date of service — making Con-RADV coding significantly more specialized and time-intensive.
CMS has published a schedule covering six payment years — PY2020 through PY2025 — running from March 2026 through April 2027. The order is not sequential: PY2024 initiates before PY2023 and PY2022. For most of the cycle, plans will be managing two Con-RADV audits simultaneously, on top of ACA HHS-RADV and routine risk adjustment cycles. PY2020 and PY2021 are both currently active. All dates are per the official CMS RADV Audit Schedule and subject to change.
Validira provides end-to-end MA RADV support: HCC validation coding via an NLP and AI-enabled platform, medical record retrieval through our partner network, RADV Cycle Management Reporting with 24/7 portal access, documentation strength ranking, coding quality assurance at 10% minimum on every chart, and dedicated audit management with weekly status updates throughout the engagement.
Validira maintains pre-audit readiness so that upon CMS notification, the team can begin receiving data and mobilizing coding within days, not weeks. Pre-configured data exchange pathways, portal access, and coder training protocols are already in place — no ramp-up delay on our end when the clock is running.
CMS has not yet decided for PY2020 or PY2021. Both audits are designed to support extrapolated overpayment calculations, but CMS will notify plans of its final decision later in each audit cycle. The 2023 extrapolation rule was vacated by a federal district court in 2025 (Humana v. Becerra) and is currently under appeal, adding further legal uncertainty.
CMS uses a risk-based approach, applying predictive analytics to identify contracts where enrollees are most likely to have unsupported diagnoses. Enrollees ranked in the top quartile of CMS's improper payment prediction models are prioritized for sampling. Selection is also informed by results from past CMS and OIG audits.
MA organizations have appeal rights under 42 CFR 422.311(c). Plans may appeal medical record review determinations and payment error calculations within the timeframe specified in the Audit Report Package. Validira's coding SMEs can support plans in preparing and evaluating appeals.
PY2020: Audit notices issued March 20, 2026. Submission deadline August 28, 2026 at 11:59pm EST. Hardship Exception Request deadline September 11, 2026. PY2021: Audit notices issued May 2026. EDL available June 12, 2026. Submission window June 22 through November 6, 2026 at 11:59pm EST. Hardship Exception Request deadline November 20, 2026.
Download the Validira MA RADV Overview
A two-page summary of what Validira brings to your audit, from day one through submission.
Download the 2-Pager (PDF) →CMS is ready. Validira is ready. Are you?
The audit calendar is set. Our coding teams are standing by. The only variable is whether your plan has the right partner in place before notices arrive.
