Sep 11, 2026
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RADV audit schedule 2027: PY 2022 to PY 2025 on one timeline
Short answer: CMS publishes the month it intends to start each payment year's RADV audits. Three started in 2026 (PY 2020, 2021, 2024), three more are planned through May 2027 (PY 2023, 2022, 2025) [1], and the PY 2024 instructions show what each will ask for and when [2]. Dates are CMS's; the reading is for a provider group.
PY 2024 · started Aug 28, 2026PY 2023 · Nov 2026 plannedPY 2022 · Jan to Feb 2027 plannedRecords due Feb 5, 2027 · PY 2024
Focus
RADV schedule
Audience
Provider groups
Horizon
Mar 2026 to May 2027
Metric
6 payment years
Effective date
Feb 5, 2027 records
Length
6 min
6payment years
On the CMS RADV schedule between March 2026 and May 2027 [1]
Feb 5, 2027
PY 2024 record submission deadline; hardship requests February 19 [2]
550plans a year
MA plans CMS said it would audit from 2025, up from about 60 [3]
20weeks
PY 2024 submission window, September 18, 2026 to February 5, 2027 [2]
CMS RADV audit initiation by payment year
The CMS schedule lists the intended month per payment year and the actual date once an audit starts, in a non-chronological order [1].
- 1PY 2020Mar 20, 2026Initiated
- 2PY 2021May 29, 2026Initiated
- 3PY 2024Aug 28, 2026Initiated; records due Feb 5, 2027
- 4PY 2023Nov 2026Planned
- 5PY 2022Jan to Feb 2027Planned; 2021 records
- 6PY 2025Apr to May 2027Planned; first full-weight V28 year
StartedPlanned, subject to change
Read against the PY 2024 instructions
Data collection year: the calendar year before payment. Future window lengths are our estimate from PY 2024; dates are subject to change [1] [2].
| Payment year | Records from | Initiation | What a provider group should expect |
|---|---|---|---|
| PY 2024 | 2023 | August 28, 2026 (actual) | Plan record requests now; submission deadline February 5, 2027; hardship deadline February 19, 2027 |
| PY 2023 | 2022 | November 2026 (planned) | Requests for 2022 charts beginning in the first quarter of 2027 if the window is about 20 weeks |
| PY 2022 | 2021 | January to February 2027 (planned) | Requests for 2021 charts through mid-2027; five-year-old records |
| PY 2025 | 2024 | April to May 2027 (planned) | Requests for 2024 charts, the first audit of a full-weight V28 payment year |
The operating template, published August 28, 2026
Sep 18, 2026
Window opens
- Samples of 35, 50, 100 or 200 enrollees by contract size [2]
Feb 5, 2027
Submission deadline
- 11:59 pm EST [2]
Feb 19, 2027
Hardship exception deadline
- 1Noticeto CEO, CFO, COO, MCOAudit initiation letter
- 2EDLenrollees and HCCsSampled enrollees and the HCCs under review
- 3Recordsabout 20 weeksUp to twice as many records as audited HCCs per enrollee; legibly signed, face-to-face, acceptable provider, inside the data collection year
- 4Coding reviewup to 3 readsOne outpatient record per date of service, or one inpatient record with a signed discharge summary
- 5Reportoutcome per HCCConfirmed, discrepant or exception
What CMS said in May 2025, and where extrapolation stands
RADV scale, before and after the May 2025 strategy [3]
CMS set a goal of finishing PY 2018 to PY 2024 by early 2026; the schedule now runs into 2027.
~60
Plans audited per yearbefore
~550
9x
Plans audited per yearfrom 2025
35
Records per planbefore
35 to 200
up to 6x
Records per planby contract size
40
CMS codersbefore
~2,000
50x
CMS codersby Sep 1, 2025
BeforeAfterWorkforce
| Payment years | Extrapolation status, as CMS has described it |
|---|---|
| PY 2011 to 2017 | Not extrapolated; only non-extrapolated overpayments collected (2023 final rule) [4] |
| PY 2018 onward | Extrapolation authorized by the 2023 rule, which was vacated by a federal district court in 2025 and is under appeal |
| PY 2024 | Designed to calculate extrapolated amounts; CMS collecting sampled-enrollee amounts and reserving extrapolation if legally permissible [2] |
The group holds the records; every date becomes a wave of requests
Requests arrive two to six weeks after each initiation date. Response time and note quality decide whether the HCC is confirmed.
Now
PY 2024
- Answer requests for 2023 charts within two business days; due to CMS by February 5, 2027
Dec 2026
PY 2023
- Pull 2022 charts for members who carried HCCs into 2023, ahead of requests
Jan 2027
PY 2022
- Pull 2021 charts; check signatures, credentials and dates against the CMS checklist before anyone asks
Apr 2027
PY 2025
- Pull 2024 charts, the first full-weight V28 payment year to be audited
Takeaway
Six payment years in fourteen months, in a non-chronological order. A provider group that serves several plans will see every one of those request waves.
Record readiness before the January requests
Name the record-request ownerOne template, one log: request date, receipt date, intake status.
Sample 30 charts from 2021 dates of serviceScore against the CMS checklist: signature, credential, date of service, provider type, diagnosis support.
Set the two-business-day turnaroundFor every plan request, every payment year.
Read the response planFour phases in our RADV audit response playbook; the 90-day plan in the HCC Operator. Our risk adjustment coding services attach evidence to every code, two reads per chart; the HCC risk adjustment AI finds the supporting note in de-identified charts; HCC coding AI keeps the next audit year clean.
Frequently asked questions
What payment years are open or planned on the CMS RADV schedule?
PY 2020 (started March 20, 2026), PY 2021 (May 29, 2026) and PY 2024 (August 28, 2026) are open. PY 2023 is planned for November 2026, PY 2022 for January to February 2027 and PY 2025 for April to May 2027. CMS says the dates are subject to change.
How long is the record submission window?
For PY 2024 it opened September 18, 2026 and closes February 5, 2027, about 20 weeks, with hardship exception requests due February 19, 2027. CMS has not published the windows for the later audits.
Why is PY 2022 after PY 2024 on the schedule?
CMS has not said. The published schedule simply lists PY 2024 for August 2026, PY 2023 for November 2026 and PY 2022 for January to February 2027, so plans and providers should expect overlapping audits.
Will PY 2022 findings be extrapolated?
Unknown. The 2023 rule authorizing extrapolation from PY 2018 was vacated in 2025 and is under appeal. For PY 2024 CMS is collecting sampled-enrollee amounts and reserving extrapolation if legally permissible; it has not published the PY 2022 methods yet.
- CMS: Medicare Advantage RADV Audit Schedule
- CMS: Payment Year 2024 MA Contract-Specific RADV Audit Methods and Instructions (August 28, 2026)
- CMS press release: CMS Rolls Out Aggressive Strategy to Enhance and Accelerate Medicare Advantage Audits (May 21, 2025)
- CMS fact sheet: Medicare Advantage RADV Final Rule, CMS-4185-F2 (January 30, 2023)
Checked October 25, 2026. Rules change; confirm against the source before relying on them. CMS has said the RADV audit schedule is subject to change.
Want a record-readiness check before the January requests arrive?
We sample your 2021 and 2022 charts against the CMS record checklist and set up the retrieval log, so the first PY 2022 request is answered in two business days.