CMS Announces Risk Adjustment Data Submission Deadlines for Medicare Advantage
Relevant to: Audit Protocol
Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.
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Introduction
The Centers for Medicare & Medicaid Services (CMS) has issued important deadlines for Medicare Advantage Organizations concerning the submission of risk adjustment data for upcoming audit sampling. This memorandum highlights the necessity for these organizations to adhere to crucial submission timelines to the Risk Adjustment Processing System and the Encounter Data Processing System for various payment years. These actions are part of CMS’s efforts to improve audit efficiency and ensure compliance with regulations.
Key Dates and Deadlines
- May 30, 2025: Date of memorandum issuance
- June 16, 2025: Deadline for submitting closed period deletes for PY 2020
- June 23, 2025: Deadline for submitting closed period deletes for PY 2021
- June 30, 2025: Deadline for submitting closed period deletes for PY 2022
- July 8, 2025: Deadline for submitting closed period deletes for PY 2023
- July 15, 2025: Deadline for submitting closed period deletes for PY 2024
- November 14, 2024: Audit notices for MA contracts selected for PY 2018 RADV audit
PACE Compliance
This memo does not directly address Programs of All-Inclusive Care for the Elderly (PACE) compliance. However, for PACE organizations that use similar mechanisms for submitting Medicare data, it’s worth considering the implications on data submission timing.
PACE organizations that manage similar data submissions should stay informed about potential changes in deadlines and requirements from CMS. They should ensure that any similar submissions required are adjusted to not conflict with the periods where data submissions are suspended for Medicare Advantage (MA) organizations.
Though PACE plans may not be specifically required under this memo to submit closed period deletes or follow the same suspensions, the principles of ensuring accurate and timely data submissions apply universally. PACE organizations should continue to meet their compliance requirements under relevant CMS regulations and guidelines related to data accuracy and auditing.
Required Actions
The following actions are required for all Medicare Advantage Organizations regarding the submission of risk adjustment data corrections:
1. Ensure the submission of known closed period deletes for PYs 2020 to 2024 by the specified deadlines: June 16, 2025, for PY 2020; June 23, 2025, for PY 2021; June 30, 2025, for PY 2022; July 8, 2025, for PY 2023; and July 15, 2025, for PY 2024.
2. Suspend the submission of data corrections in RAPS and/or EDPS starting from the respective deadlines applicable to each PY until further notice from CMS.
3. Refrain from submitting overpayment reports and auditable estimates for PYs 2020 to 2024 in the Risk Adjustment Overpayment Reporting (RAOR) module from the deadlines indicated above until further notice from CMS.
FAQs
- “What are the deadlines for submitting risk adjustment data for RADV sampling?”
- “How does CMS handle the suspension of data corrections during RADV sampling?”
- “What responsibilities do MA organizations have regarding the submission of accurate risk adjustment data?”
- “Where can MA organizations find guidance related to encounter data deletes?”
- “What happens after the submission deadlines for closed period deletes?”
