Project 2025 Tracker / What’s done, what’s next

14. Department of Health and Human Services · Notable

Restore the Risk Adjustment Data Validation (RADV) rule

Partially done

Printed page 464 14. Department of Health and Human Services

“The Risk Adjustment Data Validation (RADV) rule;”

What has happened

  1. Partially done

    No RADV rulemaking has been reopened: the Medicare Advantage RADV regulation in force is still the January 2023 final rule the Mandate calls weakened, and no proposed or final RADV rule appears in the Federal Register in the window. CMS instead delivered the substance administratively — it published a RADV audit timeline covering payment years 2020 through 2025 and a consolidated Q&A on 2026-03-04, having already updated the payment-year 2018 and 2019 audit methods and instructions in mid-2025, initiated payment-year 2020 audits on 2026-03-20 and payment-year 2021 audits on 2026-05-29. That is contract-level extrapolated auditing of every recent payment year, which is what the Trump-era proposal was for; the rule itself is untouched.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • The ask sits in the Mandate’s list of Trump-era regulations and demonstrations that were “withdrawn, weakened, or never finalized” and should be reintroduced (p. 463–464), so the object is the 2018 proposed RADV rule, not the 2023 final rule.
  • Federal Register API, phrase “Risk Adjustment Data Validation” and “RADV” since 2025-01-20: six and five documents respectively, all Medicare Advantage or ACA risk-adjustment payment rules that mention RADV in passing; none is a RADV rulemaking.
  • cms.gov can be read; the RADV Announcements page is the Primary record of the audit expansion and carries its own publication dates.
  • Leveling: partial because the substance arrived by a different instrument (audit operations) and the named object (the rule) was not restored. A reviewer who reads the ask strictly as rulemaking would hold this at not started; we note it as a close call.
Action
reinstate
Object
Risk Adjustment Data Validation (RADV) rule
ID
1255