On March 30, 2020, the Centers for Medicare and Medicaid Services (CMS) announced to all of the Medicare Advantage Organizations and Part D Sponsors that effective immediately, it is suspending contract-level RADV audits, related to the payment year 2015 and will not initiate any new ones until after the public health emergency has ended. 

This is another example of how the federal government is trying to ease the burdens of providers and payers tasked with the main responsibility of providing healthcare and coverage, respectively, for hundreds of thousands of U.S. citizens affected by COVID-19. However nice this temporary reprieve may be, it is vital to remember that it is only temporary and that the auditing work of CMS will not completely come to a screeching halt.

The CMS notice reminds us that although there is a temporary reprieve for the 2015 audit, they will continue to allow payers to submit medical documentation they have already received from providers. CMS will also review any of the medical records already submitted or that will be submitted for the 2014 audit. Because of this, CDAT will remain open for record submission and payer feedback. 

Although CMS is not beginning any new audits, it is important to realize they now have a little more time to scrutinize the records they do have, especially for the 2014 audit, so be sure to watch for organizational feedback that may be a bit more detailed or refined that has been in the past. As a payer organization, take the time to fortify compliance plans, education, and to carefully review the feedback CMS sends to your organization and apply it towards the 2015 audit that will begin after the current crisis has abated. 

For additional information related to contract-level RADV audits, contact CMS at RADV@cms.hhs.gov.

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