What Is RADV Extrapolation
RADV extrapolation is CMS's methodology for projecting audit findings from a sample of Medicare Advantage beneficiary records to an entire contract's enrolled population. Rather than auditing every member, CMS selects a statistically valid sample, determines the error rate, and applies that rate across the full contract to calculate payment recovery amounts.
The 2024 final rule confirmed that CMS will apply extrapolation to all MA contracts, eliminating the previous approach of contract-level adjustments only. This means a 10% error rate in a sample audit can translate to millions in payment recovery demands across a plan's full membership.
Building a Compliance Program
CMS expects MA plans to maintain standing compliance infrastructure that proactively prevents documentation errors rather than reacting to audit findings. A RADV-ready compliance program includes pre-submission validation of 100% of HCC-supporting encounters, provider-specific audit risk monitoring, and regular mock RADV audits using CMS's sampling methodology.
Plans that achieve pre-submission catch rates above 90% typically maintain RADV error rates below the 5% threshold that triggers significant financial exposure. The investment in pre-submission scrubbing delivers 10-20x ROI compared to post-audit remediation costs.
Pre-Submission Scrubbing
Pre-submission scrubbing is the practice of validating every HCC-supporting diagnosis code against its medical record documentation before submitting to CMS. Effective scrubbing catches 85-95% of documentation issues that would otherwise become audit findings, including unsupported diagnoses, insufficient specificity, and coding errors.
Three downloads risk adjustment teams actually use
Checklists, playbooks, and frameworks — built for analysts, auditors, and VPs working RAF, RADV, and HCC.
2026 RADV Audit Readiness Checklist
12-point compliance checklist for documentation, diagnosis code validation, extrapolation defense, and pre-audit scrub workflows.
RAF Score Optimization Playbook
Tactical guide for analysts: HCC recapture workflows, V28 transition impacts, prospective gap-closure plays, and KPIs that move RAF lift.
Risk Adjustment Analytics Playbook
How payer leaders sequence prospective and retrospective risk adjustment for compounding RAF lift. Deployment patterns, KPIs, and a VP-level operating rhythm.