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CMS WatchAugust 13, 2026·3 min read

PY2020 RADV records are due August 28. PY2024 audits start this month.

CMS's PY2020 RADV medical-record window closes August 28, 2026 at 11:59pm EST. Hardship requests are due September 11. The same month, CMS intends to initiate PY2024 audits, so two payment years overlap on the desk.

RADVMedicare AdvantagePY2020PY2024CMS Watch
HCC Buddy

By the HCC Buddy Coding Team

Published August 13, 2026

A coder's desk calendar marks the August 28 PY2020 RADV medical-record deadline as PY2024 audits start the same month.
PY2020 RADV records are due August 28, 2026, at 11:59pm EST, the same month CMS intends to start PY2024 audits.Image: HCC Buddy

Key Takeaways

  • CMS's PY2020 RADV medical-record submission window closes August 28, 2026, at 11:59pm EST.
  • Hardship exception requests for PY2020 are due September 11, 2026, at 11:59pm EST. Filing does not guarantee approval.
  • CMS's published RADV schedule intends to initiate PY2024 audits in August 2026, while PY2020 submissions are still closing. The years are not sequential.
  • PY2021's medical-record window is also open (June 22 through November 6, 2026), so some shops are running two active submission years at once.
  • CMS has designed PY2020 audits to support extrapolated recoveries but has not decided whether it will extrapolate or recover only sampled-enrollee overpayments.

On March 20, 2026, CMS published Payment Year 2020 RADV audit methods and notified selected Medicare Advantage contracts. The medical-record window that document opened is now almost shut. CMS's PY2020 methods PDF lists the submission deadline as August 28, 2026, at 11:59pm EST, with hardship exception requests due September 11, 2026, at 11:59pm EST.

The same month, CMS's public RADV schedule says PY2024 audits are intended to initiate. That's the desk story this week: one year's records are due, and the next year on the calendar is not 2021.

The dates CMS actually published

Payment yearWhat CMS publishedDate
PY2020Enrollee Data List available in CDATApril 3, 2026
PY2020Medical-record submission window opensApril 13, 2026
PY2020Medical-record submission deadlineAugust 28, 2026, 11:59pm EST
PY2020Hardship exception request deadlineSeptember 11, 2026, 11:59pm EST
PY2021Medical-record windowJune 22, 2026 to November 6, 2026, 11:59pm EST
PY2024Intended audit initiationAugust 2026

Those dates come from CMS's Payment Year 2020 methods PDF, the Payment Year 2021 methods PDF, and the public RADV audit schedule published March 4, 2026. The schedule PDF says the dates are subject to change.

Two payment years are open at once

PY2021's window opened June 22 and runs through November 6. PY2020 still has to be in CDAT by August 28. If your shop codes for a contract in both samples, the next two weeks are not "finish 2020, then start 2024." They overlap.

CMS's schedule is also not calendar order. After PY2020 (March 2026) and PY2021 (May 2026), the next initiation on the public table is PY2024 in August 2026, then PY2023 in November 2026, PY2022 in January 2027, and PY2025 in April 2027.

What the PY2020 methods actually require

The data collection period for PY2020 is January 1, 2019, through December 31, 2019. A valid medical record, as CMS defines it in that PDF, is a legibly signed and dated record of a face-to-face visit by an appropriately credentialed provider in that window.

For each sampled enrollee, the plan may submit a maximum number of medical records equal to two times the number of audited HCCs. Three audited HCCs means six records, not unlimited chart dumps.

CMS states it designed the PY2020 contract-specific audits to support extrapolated recoveries, and that it has not decided whether it will make extrapolated recoveries or recover only the overpayments tied to sampled enrollees. That's CMS's wording in the methods PDF. It's not a finding that extrapolation will or will not apply.

What this is not

This isn't a new five-month-window announcement. CMS Watch already covered the January 27, 2026 HPMS memo that restored the five-month window and moved RADV toward all eligible contracts on a quarterly cadence. The new fact is the calendar position: the PY2020 clock is days from closing, and PY2024 is on the August initiation line.

It's also not a MEAT tutorial. If you need the documentation checklist, use the existing RADV schedule guide. The job this week is whether the 2019 encounter you plan to upload actually supports the audited HCC before CDAT closes. Run it against MEAT criteria if the note is thin, and confirm the submitted code in the encoder.

What to watch for PY2024 this month

Watch for an audit notice. Initiation on the public schedule is August 2026 and can move. The methods for that year are not the PY2020 PDF. Don't treat the August 28 PY2020 cutoff as the PY2024 deadline.

What coders should do now

  1. 1If your contract is in the PY2020 sample, treat August 28, 11:59pm EST as a hard CDAT cutoff, not a target. Confirm every audited HCC has a signed 2019 face-to-face record in the queue.
  2. 2Use the two-record cap as a filter: pick the strongest 2019 encounter per HCC, not the longest chart.
  3. 3If a qualifying hardship actually applies, the PY2020 request deadline is September 11, 11:59pm EST. CMS's methods PDF says submission does not guarantee approval.
  4. 4If you also have PY2021 sampled enrollees, don't let the August 28 PY2020 close stall November 6 PY2021 work. Both windows are open now.
  5. 5For PY2024, watch for an audit notice this month. Initiation on the public schedule is August 2026 and can move.

Frequently Asked Questions

When is the PY2020 RADV medical record deadline?

CMS's Payment Year 2020 MA RADV Audit Methods and Instructions lists the medical-record submission deadline as August 28, 2026, at 11:59pm EST. The window opened April 13, 2026. Records go in through CDAT while that window is open.

When are PY2020 RADV hardship exception requests due?

CMS lists the PY2020 hardship exception request deadline as September 11, 2026, at 11:59pm EST. The methods PDF describes qualifying circumstances in Appendix B and states that filing a request does not guarantee approval.

Is CMS starting PY2024 RADV audits in August 2026?

CMS's RADV Audit Schedule, published March 4, 2026, lists August 2026 as the intended initiation month for payment year 2024. The same PDF says the dates are subject to change. Initiation is not the same as a submission deadline. PY2024 methods and a submission window come with the audit notice.

Which dates of service does a PY2020 RADV record have to cover?

The PY2020 methods PDF sets the data collection period as January 1, 2019, through December 31, 2019. A valid record is a signed, dated face-to-face visit in that period by an appropriately credentialed provider.

Will CMS extrapolate PY2020 RADV findings?

CMS has not decided. The PY2020 methods PDF says the agency designed the audits to support extrapolated recoveries and that it will decide later whether to extrapolate or to recover only sampled-enrollee overpayments.

Related topics:RADVMedicare AdvantagePY2020PY2024CMS Watch
HCC Buddy

HCC Buddy Coding Team

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