CMS’ Race to Validate: Navigating the Rapid RADV Era

The RADV Race Is On

As of April 3, 2026, health plans selected for the Medicare Advantage Payment Year (PY) 2020 Contract-level RADV (based on 2019 Dates of Service) now have access to their sampled members and HCCs through CMS’ Centralized Data Abstraction Tool (CDAT).

And just like that, the race begins.

For plan leaders, the immediate focus is on assessing which members and HCCs were selected. But behind that urgency lies a growing list of competing questions and priorities:

• How do we handle PY2020 RADV work while simultaneously launching our PY2026 (2025 DOS) retrospective programs and maintaining prospective/concurrent initiatives?
• How can we balance quality assurance coding and RADV validation to ensure we submit the right medical records to CMS?
• Are we targeting the correct records from PY2020—in the right locations—to properly validate conditions?
• What gaps exist in our understanding of that historical population?
• How do we juggle this with any other applicable government-initiated audits (ACA RADV, OIG, etc.) requirements that also overlap with tight deadlines?
• With CMS’s proposed RADV schedule—PY2021 ConRADV expected to start in May 2026, and more to follow—how will we manage multiple concurrent MA RADVs across multiple PYs for the first time ever?

For multi-line of business plans, these questions compound across timelines, each drawing from the same internal and external resources. The result: capacity stretched thin and competing demands pulling at every thread of the organization.

Where Pareto Helps Plans Keep Pace

At Pareto, we partner with health plans navigating this high-stakes, high-speed environment. Our role is to help clients focus their limited bandwidth on what matters most — execution, accuracy, and compliance without losing sight of ongoing operational demands.

We do this by:

• Building prioritized RADV chart chase lists that layer in retrieval strategies and execution support to help plans reach the right records faster.
• Conducting onshore auditing led by tenured, certified medical coders to identify and validate the most appropriate medical record(s) for each member/HCC.
• Providing end-to-end project management and oversight to ensure progress is tracked, timelines are met, and every potential validation opportunity is explored.
• Quantifying the financial impact (e.g. overpayment) of non-validated conditions

Our goal is simple: help plans transform what feels like a sprint into a manageable, structured process; one that blends speed with precision.

Balancing RADV Capacity in a Time of Compression

Health plans today are facing unprecedented capacity constraints. The same teams driving RADV validation are the ones steering day-to-day risk adjustment operations, quality improvement, and compliance activities. As CMS accelerates RADV timelines, that overlap becomes harder to sustain without outside support.

The organizations best positioned to succeed will be those that balance compliance execution with operational stamina, using expert partnerships and data-driven prioritization to ensure accuracy and focus.

As CMS continues its “race to validate”, plans that can operationalize agility and maintain accuracy will not only survive this new era of contract-level RADVs but emerge stronger and more prepared for what’s next.