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CMS to Audit All Medicare Advantage Plans Annually in Major Oversight Expansion
In a significant shift aimed at strengthening oversight of Medicare Advantage (MA) plans, the Centers for Medicare & Medicaid Services (CMS) announced on May 21, 2025 that it will begin auditing every Medicare Advantage plan annually. This marks a dramatic expansion from the agency's current practice of auditing approximately 60 plans per year to over 500.
Describing the move as part of an "aggressive" strategy to combat overpayments, CMS Administrator Mehmet Oz, MD, emphasized the agency's responsibility to ensure accurate billing. "While the administration values the work that Medicare Advantage plans do, it is time CMS faithfully executes its duty to audit these plans and ensure they are billing the government accurately for the coverage they provide to Medicare patients," Dr. Oz said. MA plans receive federal funding based on enrollees' documented health conditions, with higher payments allocated for sicker patients. However, the Medicare Payment Advisory Commission has estimated that up to $43 billion in overpayments may be issued each year due to diagnoses not supported by medical records.
To enforce its oversight, CMS conducts risk-adjustment data validation (RADV) audits, reviewing whether the diagnoses MA plans submit to justify payments are backed by patient health records. The agency will increase its auditing capacity substantially, expanding its team of from 40 to approximately 2,000 by September 1. Enhanced technology will also be deployed to support the medical record review process. CMS also intends to recover payments from previous years. In addition to the new annual audit policy, the agency will finalize outstanding audits from 2018 through 2024 and pursue uncollected overpayments. The last major recovery effort involved audits of plan year 2007.
Physicians in Medicare Advantage plans may face increased scrutiny as CMS audits focus on whether reported diagnoses are fully supported by medical records. Accurate documentation is critical to avoid denials and ensure proper reimbursement. With CMS emphasizing data integrity and compliance, providers should consider internal/independent audits to assess coding accuracy and prepare for potential impacts.
Read the press release HERE.
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