RADV Audit Schedule 2026: What HCC Coders Should Check First

Quick Answer

CMS has published a RADV audit schedule listing intended initiation months by payment year.

The current schedule:

CMS notes these dates can change.

The practical takeaway: every submitted HCC needs support in the medical record. If the record does not back the dx, the code becomes an overpayment issue. The audit letter comes later, but the documentation has to be there in the original chart.

Why the Schedule Matters Now

RADV is not new. It just gets louder when specific payment years show up on a published calendar.

CMS uses RADV to confirm that diagnoses MA organizations submitted for risk adjustment are supported in enrollee medical records. If a submitted dx is not supported, CMS may collect overpayments.

CMS published PY2020 audit methods and instructions in March 2026 and notified selected MA organizations the same day. PY2024 initiation is on the calendar for August 2026.

That spread matters. It is not one audit year. It is several, running in parallel, covering PY2020 through PY2025 dates of service. If a chart from any of those years has a pulled-forward dx with no current support, that risk does not age out.

The Four Checks Before a Diagnosis Leaves Your Desk

Before an HCC gets submitted, run it through these four questions.

1. Is There a Valid Encounter?

The dx needs to be tied to a valid encounter, not floating in a chart review note without a service connection.

Look for the date of service, provider type, encounter context, signature status, and whether the dx appears in the visit being coded. A dx that drifted away from any specific encounter is the first thing an auditor flags.

2. Did the Provider Address It?

A problem list entry alone does not support an HCC.

The provider needs to do something with the condition. That means Monitoring, Evaluating, Assessing, or Treating. Coders shorthand this as MEAT.

What solid MEAT looks like in practice:

What should make you stop:

"No MEAT, no code" is not just a mnemonic. It is what the RADV reviewer is checking.

3. Is the Code Specific Enough?

RADV is not only about whether a condition exists. It is also about whether the submitted code matches the documentation.

Common places to slow down:

If the chart supports a more specific code, code to it. If it does not, do not invent specificity from labs, meds, or old notes.

4. Is the Support Current?

Risk adjustment runs calendar year, but RADV reviews come back to the original record.

A dx from last year, a cloned problem list, or an old specialist assessment may not hold up if the current provider did not address the condition at this encounter. Ask one plain question: can you point to the sentence, lab review, treatment plan, or assessment that supports this dx for this encounter? If the answer is no, the code is not ready.

The Documentation Traps That Create RADV Exposure

Coding From the Problem List Alone

The classic trap. The condition may be real. The patient may have had it for years. The problem list may be accurate.

It does not matter. If the provider did not address it during the encounter, that entry is not enough for risk adjustment.

Treating Medication Clues as Documentation

Medication lists can help a coder spot a gap or build a query. They cannot replace provider documentation.

Insulin may suggest DM. Entresto may suggest heart failure. Inhalers may suggest COPD. The provider still has to document and address the condition. The medication list is a clue, not the support.

Ignoring Specificity Because the HCC Looks Identical

Two codes can map to the same HCC, and specificity still matters.

If the documentation supports a specific condition and the submitted code is vague, the chart looks sloppy under review. Specific coding is part of defensible coding.

Carrying Forward Resolved Conditions

History of cancer is not active cancer. Old myocardial infarction is not acute MI. Prior stroke does not automatically support an active CVA code.

Resolved and historical conditions need the right code path. The ICD-10-CM structure has Z codes and sequela codes for a reason.

What Team Leads Should Do This Week

Pull 10 charts with high-risk HCCs. For each one, ask:

A 10-chart review can surface whether your team has a documentation habit problem, a specificity gap, or a workflow issue. It does not need to be dramatic. Do it before an audit initiates.

If you want a structured checklist to run against each record, the RADV and MEAT support checklist walks through the same questions encounter by encounter.

Preparing for Multiple Payment Years at Once

The schedule runs from PY2020 through PY2025 across the next calendar year. That means documentation standards are being evaluated across a wide window of past dates of service.

For teams doing retrospective chart sweeps, pay attention to any year that shows audit initiation on the horizon. The RADV audit prep guide covers the record retrieval and documentation review workflow once an audit letter actually arrives.

The work before the letter is lighter. The work after is heavier.

HCC Buddy for Pre-Audit Lookups

When you are working through a chart and need to check an ICD-10-CM code, its V28 HCC mapping, or whether a more specific code path exists, the ICD-10 encoder does the lookup without leaving your review.

HCC Buddy does not decide whether the documentation supports the dx. That call stays with the coder and the chart. It handles the code-detail lookup so you can spend more time on the documentation question that actually matters at audit.

Sources

CMS RADV audit schedule

CMS Medicare Advantage RADV program

CMS RADV questions and answers

CMS payment year 2020 RADV audit methods and instructions

CMS CY 2027 Medicare Advantage and Part D final payment policies — policy context for MA coders in 2026

Open the RADV and MEAT support checklist