Medicare Advantage
CMS Launches 2023 Payment-Year Medicare Advantage Coding Audit Cycle
Medicare notified selected Medicare Advantage insurers on November 13 that their 2023 payment-year contracts are under formal review, with medical record submissions due next April.
By the Goodsurance editorial teamNovember 14, 2026
The Centers for Medicare and Medicaid Services formally launched its payment-year 2023 Risk Adjustment Data Validation, known as RADV, audit cycle on November 13, notifying Medicare Advantage insurers which of their contracts had been selected for review.
RADV audits verify whether the diagnoses that Medicare Advantage plans report for risk-adjustment payments are supported by beneficiaries' medical records. Risk-adjustment payments are designed to compensate plans according to the actual health status of their members. When a reported diagnosis cannot be found in the records, the associated payment may be recovered.
Medicare opened its 2023 coding audit cycle for Medicare Advantage plans. Selected insurers must submit supporting medical records by April 23, 2027.
Under the schedule CMS published, selected plans can begin downloading their enrollee data lists on November 30. The window for uploading supporting medical records opens December 4 and closes April 23, 2027.
The initiation follows CMS's March 2026 announcement that it would audit all eligible Medicare Advantage contracts for each payment year going forward, a sharp expansion from a prior practice of auditing only a sample of plans. Plans are now managing overlapping audit cycles covering multiple payment years simultaneously.
Litigation over the audit methodology remains active. Humana challenged the statistical extrapolation rules that govern how findings from sampled claims are scaled to full contract populations. A federal district court vacated those rules in 2025, and CMS has appealed. The agency has continued launching new audit cycles while the appeal is pending.
For enrollees, RADV audits are intended to ensure that federal payments to plans reflect members' actual health needs rather than overstated diagnoses.
In plain words
Every year, Medicare pays insurance companies extra money for patients who are sicker. Companies report their patients' health problems to decide how much money they receive. Medicare checks whether those reports are backed up by real medical records. These checks are called RADV audits. On November 13, Medicare told certain Medicare Advantage companies that their 2023 records are being checked. Companies have until April 23, 2027 to send in medical records that back up what they reported. If the records do not support a reported health problem, the company may owe money back. Medicare now runs these checks on all companies every year, not just a few at a time.
Understand the basics first
Source: CMS
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