The answer first: RADV is no longer an event, it is a calendar. Under the CMS May 2025 announcement, CMS is accelerating Risk Adjustment Data Validation audits across payment years 2018 through 2024 and auditing roughly 550 Medicare Advantage contracts annually, effectively every eligible contract, every year. PY 2020 audits begin as early as February 2026, CMS operational refinements have restored the five-month medical record submission window, and audit waves now land on a predictable quarterly calendar. The Northern District of Texas litigation over the 2023 RADV final rule's extrapolation methodology changes the size of the check, not whether the records get pulled.
The new steady state, in four numbers
The 2026 quarterly audit calendar
CMS's operational refinements replace the old episodic scramble with a predictable cadence: audit notices arrive on a quarterly schedule, and each notice starts its own five-month record clock. Gold bars mark notice windows, cyan bars mark the running record clock.
PY 2020 audits begin as early as February 2026. The five-month record clock on a February notice runs into July.
Next quarterly wave. New notices open while Q1 record clocks are still running. Retrieval capacity must overlap.
Q1 deadlines land here. A five-month window opened in February closes in July, just as a new wave arrives.
The cadence repeats. With PY 2018-2024 in the queue and ~550 contracts a year, there is no off-season anymore.
What the five-month clock actually buys you
- Month 1: sample lands, map enrollee-HCC pairs to charts, launch retrieval on the hardest custodians first.
- Months 2-3: chase closed practices, acquired groups, and out-of-network records, the ones that always run long.
- Month 4: coder-level review of every chart against the reported HCC before submission, flag unsupported codes.
- Month 5: QA, attestation, and submission with margin, not a midnight upload.
The courtroom changes the check, not the chart pull
Litigation in the Northern District of Texas is testing the extrapolation methodology in the 2023 RADV final rule (CMS-4185-F, February 1, 2023), the rule that removed the fee-for-service adjuster and authorized extrapolating audit findings rather than recovering only on sampled enrollees. Whatever the court decides about extrapolation, the audits themselves proceed: samples issue, the five-month clock runs, and unsupported HCCs are still unsupported.
Planning takeaway: build your operation for the audit cadence, and treat the litigation as a variable on financial exposure, not on workload.
Operator to-do list: what to pre-stage this quarter
- Stand up a standing RADV desk with named owners for sample intake, retrieval, coding review, and submission, sized for overlapping quarterly waves, not a one-time project team.
- Pre-stage chart retrieval for PY 2020-2021 dates of service now: refresh provider rosters, confirm record custodians for terminated and acquired groups, and pre-negotiate turnaround commitments.
- Run an unsupported-HCC self-audit on PY 2020-2021 submissions before CMS samples them, prioritizing high-value HCCs and single-encounter diagnoses.
- Build a deadline board keyed to the five-month clock, with internal milestones at months 1, 3, and 4, so the CMS deadline is never the first hard date your team sees.
- Track the Northern District of Texas extrapolation litigation for reserve-setting and finance modeling, and keep it out of the retrieval team's critical path.
- Monitor the CMS RADV Announcements page quarterly as the primary source for wave timing and operational instructions.
CMS May 2025 announcement accelerating RADV audits for payment years 2018-2024 across roughly 550 MA plans annually; CMS RADV Announcements page (PY 2020 audits beginning as early as February 2026; restored five-month medical record submission window; quarterly audit calendar); Medicare Advantage RADV Final Rule, CMS-4185-F, February 1, 2023; Northern District of Texas litigation challenging the 2023 RADV final rule's extrapolation methodology. All primary .gov and court sources; no trade press.
Make RADV a routine, not a fire drill
ASP-RCM Solutions runs risk adjustment as a standing operation: pre-staged chart retrieval, unsupported-HCC self-audits on the exact payment years CMS is sampling, and coding review workflows that sustain 95%+ coding accuracy across HCC submissions. If your team is planning for the February 2026 PY 2020 wave, we will map your quarterly readiness calendar with you.
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