CMS Announces Rerun of PY 2020–2022 Risk Scores

On March 6, 2026, CMS released an important update announcing that it will rerun risk scores for Payment Years 2020, 2021, and 2022 for the purpose of payment recovery. This action affects all Medicare Advantage organizations and entities that submit risk adjustment data through RAPS and EDPS.

The memo reinforces a long‑standing requirement:
“The obligation to delete incorrect diagnosis data applies regardless of whether the MA organization identifies the incorrect diagnosis data prior to the risk adjustment deadline or after.”

In other words, plans must correct inaccurate diagnosis data even after the submission window has closed. These reruns will incorporate both open‑period and closed‑period deletes, and CMS has outlined specific deadlines for submitting corrections.

Upcoming Delete Deadlines

• Payment Year 2022 (DOS 1/1/2021–12/31/2021): April 3, 2026

• Payment Year 2021 (DOS 1/1/2020–12/31/2020): October 30, 2026

• Payment Year 2020 (DOS 1/1/2019–12/31/2019): November 30, 2026

CMS also clarified that overpayments associated with these reruns do not need to be reported through the Risk Adjustment Overpayment Reporting (RAOR) module for active contracts, as long as the relevant data has been or will be submitted before the deadlines.

What This Means for Providers

While the operational responsibility sits with Medicare Advantage plans, these reruns highlight the increasing scrutiny on documentation accuracy and the importance of defensible, clearly supported diagnoses. Strong documentation practices help ensure:

• Accurate risk score capture

• Fewer downstream deletes

• Reduced audit exposure

• Better alignment with CMS expectations

At RiskWise, we help independent primary care practices stay ahead of these shifts through clear audits, supportive education, and practical workflow guidance. We’ll continue to share updates and provider‑friendly explanations as CMS releases more information.

If your practice would benefit from a documentation review or support understanding how these changes may affect your value‑based contracts, we’re here to help.