
RADV Audits For Payment Year 2020 Announced
CMS plows ahead on RADV without underlying rule On March 20, the Centers for Medicare and Medicaid Services (CMS) announced that it will proceed with Payment Year 2020 Risk Adjustment Data Validation (RADV) audits. In May 2025, CMS Administrator Dr. Mehmet Oz promised to audit every contract every year to reduce overpayments in the Medicare Advantage (MA) program. But that promise took a bit of a hit when a federal judge in September 2025 sided with Humana and struck the RADV rule finalized by the Biden administration in 2023. The judge nullified the entire rule, not just portions of it. The decision was not unexpected. The Biden administration included so many far-fetched and indefensible provisions. The court in the RADV case found that CMS did not follow the procedural requirements of the Administrative Procedure Act (APA). There were inadequate notice requirements. CMS did not justify its decisions via the comment









