In Westlaw Today, Attorneys Discuss CMS Changes to Risk Adjustment Data Validation Audits of the Medicare Advantage Program

In The News
June 13, 2025

In a Westlaw Today article, cross-practice attorneys discussed the Centers for Medicare and Medicaid Services' (CMS) plans to increase the pace and scale of Risk Adjustment Data Validation (RADV) audits of the Medicare Advantage (MA) program.

The authors note that federal False Claims Act investigations in related industry segments regularly begin when CMS auditors and program integrity contractors alert prosecutors to potential fraud based on their findings. Given the U.S. Department of Justice’s focus on combating fraud in the MA program, it is likely such DOJ referrals in the MA space will substantially increase with the expansion of the RADV audit program.

The article's authors included litigation & enforcement partner Amy Kossak, health care counsel Lauren Biggs and health care associate Peter Gilchrist, with contributions from health care partners Drew Clary and Brett Friedman and health care counsel Sam Perrone.