The Centers for Medicare & Medicaid Services (CMS) on Friday sent Medicare Advantage organizations a memo that lists the deadlines to submit their risk adjustment data corrections to the Risk Adjustment Processing System (RAPS) and/or the Encounter Data Processing System (EDPS) for upcoming Risk Adjustment Data Validation (RADV) audit sampling.
The memo comes in the wake of CMS’ announcement last month that it will begin auditing all eligible Medicare Advantage contracts for each payment year in all newly initiated audits and hire thousands of coders to expedite audits for payment years 2018 through 2024.
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Due to the acceleration of MA contract auditing, CMS notified plans on Friday that it will be developing samples for upcoming contract-specific RADV audits for performance years 2020 to 2024 starting in June 2025.
Steven Ferraina, acting director of the Audits and Vulnerabilities Group, Center for Program Integrity, and Jennifer R. Shapiro, director of the Medicare Plan Payment Group, Center for Medicare, said that plans selected for performance year 2018 RADV audits received audit notices via HPMS on November 14, 2024. Plans selected for performance 2019 RADV audits will soon receive audit notices.
As part of the process, CMS officials said MA organizations must submit their known closed period deletes by the following deadlines:
|
Payment Year |
Relevant CMS System |
Dates of Service |
RA Data Submission for RADV Sampling Deadline |
|
2020 |
RAPS/ EDPS |
January 1, 2019 – December 31, 2019 |
June 16, 2025 |
|
2021 |
RAPS/ EDPS |
January 1, 2020 – December 31, 2020 |
June 23, 2025 |
|
2022 |
EDPS |
January 1, 2021 – December 31, 2021 |
June 30, 2025 |
|
2023 |
EDPS |
January 1, 2022 – December 31, 2022 |
July 8, 2025 |
|
2024 |
EDPS |
January 1, 2023 – December 31, 2023 |
July 15, 2025 |
To ensure that deleted diagnoses are not included in these RADV samples, CMS said MA organizations should suspend the submission of data corrections in RAPS and/or EDPS as of the deadlines until the agency notifies them that they can restart submissions. In addition, MA organizations should stop submitting overpayment reports and auditable estimates for performance years 2020 to 2024 in the Risk Adjustment Overpayment Reporting (RAOR) module as of these deadlines until CMS notifies them that they can begin submissions again.
CMS also said it will not make payment adjustments based on the closed period deletes submitted by the RA data submission for RADV sampling deadlines. The agency said it will announce the reruns of performance years 2020 through 2024 and their related overpayment data submission deadlines in future HPMS memos.