HCC Coding and RADV Audits in 2026: What Medicare Advantage Coders Must Do Now

After years of legal uncertainty and delayed enforcement, CMS has made one thing unmistakably clear in 2026: Risk Adjustment Data Validation (RADV) audits are back, they are accelerating, and this time the agency is bringing AI into the process. For medical coders supporting Medicare Advantage plans, the window to get documentation right is narrowing fast.

Payment Year 2020 RADV audits officially began in February 2026. CMS has also confirmed plans to deploy artificial intelligence as a coder support tool to streamline human reviews during the audit process. This combination — accelerated timelines and AI-assisted scrutiny — means the margin for underdocumented HCC codes is shrinking to near zero.