RADV Used to Be a Lottery. In 2026, It's an Annual Event for Every Plan.

For most of its history, a RADV audit was something a Medicare Advantage plan could treat as background noise. CMS audited fewer than 60 contracts a year. The odds of being selected were low enough that many plans quietly bet they wouldn’t be.

That bet no longer exists.

1. What actually changed.

CMS has moved to audit every eligible Medicare Advantage contract — more than 550 plans — every single year, and it is racing through a backlog stretching from payment year 2018 to 2024. To do it, the agency expanded its review workforce dramatically and increased the number of records pulled per plan.

The headline isn’t any single number. It’s one word: every. Every eligible plan. Every year.

2. The retrospective playbook just broke.

The old model was reactive: capture aggressively, clean up later, and hope you’re not selected. That model depended on selection being rare. When “selected” becomes “everyone, annually,” the entire logic collapses.

You cannot clean up after the fact when the fact is now a permanent, recurring condition of doing business.

3. The clock is already running.

This isn’t a future-state warning. CMS has started audits for payment year 2020 since February 2026, with findings from earlier years following close behind. For most organizations, the relevant audits are already in motion — the only question is when the record request lands.

4. What audit-ready actually looks like.

Audit readiness isn’t a binder you assemble when a request arrives. It’s a year-round posture:

Documentation that meets the standard at the point of care, not reconstructed afterward
Regular internal “mock RADV” reviews, so you know your numbers before CMS does
A clear view of which conditions and which providers carry the most risk
A process that treats accuracy as ongoing, not episodic

Final Thoughts

The plans that struggle over the next few years won’t be the ones with the sickest patients. They’ll be the ones that built their operations around an audit being unlikely — and never adjusted when it became certain.

The lottery is over. Everyone’s number just came up.

If you want to know how your organization would fare before the record request arrives, a focused readiness review is the place to start.

1. What actually changed.

2. The retrospective playbook just broke.

3. The clock is already running.

4. What audit-ready actually looks like.

Final Thoughts

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