CMS Expands Medicare Advantage Audits to Tackle $43B Overpayment Risk

Strengthening audit enforcement in Medicare Advantage is crucial to safeguarding taxpayer funds and ensuring fair, accurate payments in a rapidly expanding healthcare landscape. (Source: Fotor AI)

The Centers for Medicare & Medicaid Services (CMS) has significantly ramped up its auditing of Medicare Advantage (MA) plans, targeting an estimated $43 billion in annual overpayments. This policy shift mandates comprehensive audits of all eligible MA contracts for each payment year, including retrospective reviews covering 2018 to 2024. Previously, CMS audited roughly 11% of MA plans annually; the expansion represents a strategic move to tighten regulatory oversight across the entire program.

Regulatory Focus and Implications

The surge in Medicare Advantage enrollment—reaching 54% of eligible beneficiaries in 2024 and projected to rise to 64% within ten years—has triggered intensified scrutiny on payment accuracy and compliance. Policymakers and regulatory bodies, including the Medicare Payment Advisory Commission (MedPAC), have highlighted systemic risks such as inflated risk scores due to aggressive or inaccurate coding practices. These “coding intensity” tactics artificially increase payments by overstating beneficiaries’ health risks.

Further concerns surround “favorable selection” behaviors, where MA plans may disproportionately enroll healthier individuals, skewing risk adjustment models and enabling retention of excess federal funds. Additionally, the MA quality bonus program, which funnels approximately $15 billion annually to top-rated plans, faces criticism for contributing to escalating costs without definitive proof of improved care outcomes.

CMS Enforcement Enhancements

In response, CMS is mobilizing substantial resources to reinforce compliance enforcement. The agency plans to grow its medical coder workforce from 40 to 2,000 by September 2025 and deploy advanced data analytics and automated review systems to detect unsupported diagnoses and billing irregularities promptly.

This policy and regulatory tightening aims to safeguard Medicare’s financial integrity, reduce fraud, waste, and abuse, and promote equitable allocation of federal health care dollars amid rapid MA expansion.

Impact on Providers

Health care providers and MA plan administrators must urgently reassess and strengthen their compliance infrastructures. Enhanced documentation accuracy, comprehensive audit preparedness, and transparent operational practices will be essential to meet evolving regulatory demands. Failure to adapt risks significant financial penalties and potential exclusion from MA program participation.

Conclusion

CMS’s expanded audit framework marks a decisive policy evolution toward greater accountability and fiscal stewardship in the Medicare Advantage arena. Providers should anticipate ongoing regulatory intensification and prioritize proactive compliance strategies to sustain program access and align with federal mandates for transparent, accurate Medicare billing. This paradigm shift will likely reshape risk adjustment and payment integrity standards, impacting all stakeholders in the Medicare ecosystem.

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The Real Economy Blog

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