550 Plans, Quarterly RADV Audits, Five Months to Submit: What the Jan 2026 CMS Memo Means at Your Desk

The short version for coders who are already behind

In a January 27, 2026 memorandum distributed to Medicare Advantage plan sponsors through CMS's Health Plan Management System, CMS laid out what RADV looks like from PY2026 forward. If your plan operates a mid-size or large MA contract, the shift from "maybe someday" to "assume you're in the queue" is now policy.

The RADV program isn't new. What changed is the scope and pace.

What actually shifted: the comparison table

Sources: Crowell & Moring (Feb 2026); Dentons Health Law (Jan 2026); RISE Health (Jan 2026).

For the full PY2020–2024 timeline and cycle schedule, see RADV Audit Schedule 2026: What HCC Coders Should Check First — that post covers the payment year sequence in detail. This article focuses on the operational parameters above.

550 plans is a different game

Historical RADV practice covered around 60 contracts per payment year. Running all RADV-eligible contracts on a quarterly cycle means a plan that once had maybe a 10–15% chance of selection in a given year now faces near-certain eventual audit — and potentially sooner than expected if CMS executes the quarterly calendar it said it would publish.

The memo noted CMS will redesign its RADV webpages to host an audit calendar, methodology documents, and FAQs. When that lands, it removes the ambiguity coders and compliance teams have operated under for years. Plans either have their record-retrieval process ready or they're scrambling.

The five-month window: what it means in practice

After the May 2025 memo proposed a tighter submission window, the January 2026 memo restored five months. That sounds comfortable until you factor in the reality of record retrieval: chasing records from multiple providers, hospital systems that run their own timelines, and the common situation where documentation for a DOS eighteen months ago is missing a signed addendum or lacks the specific wording an IVA reviewer needs.

Five months is not five months of runway. It's more like five months to find out your documentation has problems you didn't know about.

The two-record rule and what CMS means by "one valid record"

The two-records-per-audited-HCC ceiling is maintained. CMS's stated position is that one valid record is sufficient to support a diagnosis.

That framing matters. If you're submitting two records hoping one of them sticks, you've already identified a gap. The stronger move is to have your best record clearly identified before the audit begins — not to collect volume and hope. Quality over quantity is the rule the two-record limit enforces.

For chronic conditions with pulled-forward or cloned notes, this is where plans routinely lose overpayment disputes. The IVA reviewer is looking for the condition addressed at a face-to-face encounter on the DOS, with actual MEAT in the record. A problem list entry from three years ago that was auto-populated into subsequent notes is not going to survive that review.

For a breakdown of what counts as evidence, see the MEAT Criteria Guide.

Human coders are making the calls — and CMS is building the team

CMS confirmed in the memo that AI-assisted tools support its coding review process, but all overpayment determinations are made by certified human coders. CMS also stated it planned to expand its coding workforce from roughly 40 to more than 2,000 coders.

That's a significant build-out. If it executes, CMS's throughput per quarter goes up substantially — which is consistent with the quarterly cadence target and the 550-plan scope.

The litigation backdrop

A Texas federal court vacated the CMS RADV Final Rule in a ruling favoring Humana, specifically on the fee-for-service adjuster and extrapolation methodology for PY2018. That ruling removed some of the legal underpinning for the earlier final rule's extrapolation approach.

The January 2026 memo proceeds with the accelerated audit strategy as a separate track from that litigation. The practical effect for plans and coders: the audit schedule is moving, the litigation is its own lane, and waiting to see how the legal questions resolve before tightening documentation practices is a bet most compliance teams aren't taking.

What the quarterly calendar means for coder workload

The memo says CMS will publish an audit calendar. When it does, the planning horizon for record retrieval and coder review gets much tighter than it's been. A plan notified that it's in the Q2 cycle doesn't have the luxury of the multi-year limbo that characterized older RADV timing.

Coders should expect that their plan's compliance and risk adjustment teams will be pulling documentation review into pre-submission workflows more aggressively than before. The submissions you make today become the records under review in the next cycle.