CMS audits increase Medicare Advantage clawbacks

This change makes coding accuracy a direct earnings issue for every Medicare Advantage plan, because CMS is moving from slow, sample based oversight to a larger-scale repayment system that can reach back across whole contracts. Devoted gets paid monthly by CMS based partly on how sick members are documented to be, so if diagnoses are not fully supported in charts, audit findings can turn into clawbacks on a much larger dollar base as membership scales.

• CMS finalized extrapolated RADV recoveries starting with payment year 2018, which means an error found in a reviewed chart can now be projected across a broader member sample instead of staying a one off adjustment. That raises the financial stakes of coding discipline for plans like Devoted.
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• In July 2025, CMS said it would audit all eligible Medicare Advantage contracts each payment year and use much larger medical record review capacity to speed 2018 through 2024 audits. The 2,000 coder buildout matters because it turns enforcement from a backlog problem into an operating reality.
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• The pressure is industry wide, not company specific. DOJ settlements with Cigna and Independent Health show the government is targeting unsupported diagnosis submissions as a payment inflation issue, while Devoted also runs in house care, member guides, and its Orinoco platform to capture and manage documentation inside one workflow.
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The next phase of Medicare Advantage competition will reward plans that can prove each coded condition with clean documentation, not just find more conditions. For Devoted, the advantage of owning care delivery, member support, and compliance systems in one stack is that charting, follow up, and audit readiness can become part of the same daily operating loop.