For years, Risk Adjustment Data Validation (RADV) audits were largely viewed as a health-plan responsibility. Individual providers and practices often saw them as something happening in the background.

That is changing.

As RADV audits expand in 2026, the documentation created at the point of care is becoming increasingly important. Every diagnosis submitted for risk adjustment ultimately needs support in the patient's medical record.

This makes clinical chart review more than a back-office coding exercise. For practices involved in Medicare Advantage and value-based care, regular chart review can help identify documentation gaps before they become audit findings.

What Is Clinical Chart Review?

A clinical chart review is a structured evaluation of a patient's medical record to determine whether documented diagnoses are complete, specific, and clinically supported.

Depending on the purpose of the review, this may include examining:

• Provider notes
• Laboratory results
• Imaging
• Consultations
• Previous visits
• Assessment and treatment plans

Think of it as an additional clinical review of the record—not to second-guess the provider's medical judgment, but to make sure that the clinical reasoning and conditions being managed are clearly reflected in the documentation.

Why Does This Matter for RADV?

RADV reviews examine whether diagnoses submitted for payment are supported by the medical record.

If a condition was treated but the documentation does not clearly establish the diagnosis, its current status, or the appropriate clinical detail, the diagnosis may not be adequately supported during review.

That is where proactive chart review becomes valuable.

What Is Changing With RADV Audits in 2026?

According to the supplied source, CMS is moving from a relatively limited audit approach toward broader coverage of eligible Medicare Advantage contracts, with recurring review cycles.

The draft also notes that CMS has been working to close out older payment-year audits while using certified human reviewers alongside AI-supported processes.

The important takeaway for providers isn't simply the size of the audit program.

It's this:

The medical record is the evidence.

And that record starts with the documentation created during the patient encounter.

Why RADV Matters at the Provider Level

Health plans may be the organizations being audited, but providers create much of the documentation those audits rely on.

Common documentation gaps include:

1. A condition is clinically managed but not clearly documented.
2. A diagnosis is carried forward without being reassessed.
3. Important details such as staging, laterality, or relationships between conditions are implied rather than documented.
4. The encounter or provider documentation does not meet applicable audit requirements.

These aren't necessarily failures in clinical care.

Often, they're documentation gaps.

And those are exactly the types of gaps a structured clinical chart review can identify.

A Simple Example

Consider a note that says:

"Follow-up for CKD and diabetes, doing well, continue current plan."

The provider may have appropriately managed both conditions. But the documentation doesn't provide much detail about the diagnoses or their current status.

A more specific note might document:

"Follow-up for type 2 diabetes mellitus with diabetic chronic kidney disease, stage 3a, stable on current regimen. Diagnosis reassessed and confirmed at this visit."

The patient's clinical situation hasn't necessarily changed.

What has changed is the clarity and specificity of the documentation.

This distinction matters when the record is later reviewed for coding or risk adjustment.

Common Myths About Clinical Chart Review

Myth 1: "RADV audits only affect health plans."

Fact: Health plans are audited, but the documentation used to validate diagnoses comes from provider records.

Myth 2: "If a condition was documented once, it remains supported."

Fact: Chronic conditions generally need to be reassessed and appropriately documented on an ongoing basis, including each applicable calendar year.

Myth 3: "Chart review is only necessary after an audit notice."

Fact: Proactive reviews can identify documentation gaps before an external review does.

Myth 4: "AI has replaced expert chart review."

Fact: The supplied source notes that CMS uses AI to support, rather than replace, certified human reviewers.

Start With the Charts That Matter Most

Not every patient record needs to be reviewed at the same time.

For organizations with limited resources, a practical approach is to prioritize high-acuity patients with multiple chronic conditions and potentially relevant HCC diagnoses.

These charts may contain more documentation complexity and therefore offer greater opportunities to identify meaningful gaps.

A focused approach can be more practical than attempting to review every record simultaneously.

What Should a Clinical Chart Review Include?

A structured chart review program can include:

1. Full Record Evaluation

Review relevant notes, labs, imaging, consultations, and previous visits rather than relying only on the most recent encounter.

2. Diagnosis Specificity

Check whether conditions include relevant clinical details such as staging, laterality, or documented relationships.

3. Annual Reassessment

Confirm that chronic conditions are being reassessed and appropriately documented rather than simply carried forward.

4. Provider Feedback

Review findings directly with providers instead of relying solely on a written report.

5. Actionable Recommendations

Provide clear, prioritized recommendations that providers can apply to future documentation.

This provider-feedback component is particularly important. Identifying a documentation gap is useful; helping the provider understand how to avoid repeating it is where the review becomes an educational tool.

Clinical Chart Review vs. Coding Audit

These terms are sometimes used interchangeably, but they aren't exactly the same.

A clinical chart review looks at the broader clinical picture and evaluates whether documentation accurately represents the patient's conditions and care.

A coding audit is more focused on whether the codes assigned or submitted are supported by the documentation.

They overlap, but their objectives are different.

For organizations focused on documentation improvement, using both perspectives can provide a more complete view of where problems are occurring.

How Often Should Practices Conduct Chart Reviews?

There isn't necessarily a one-size-fits-all schedule.

However, practices participating in value-based care or Medicare Advantage programs can benefit from ongoing, periodic chart review rather than waiting until an audit occurs.

Regular reviews make it easier to identify recurring documentation patterns, provide targeted provider education, and address gaps while they are still manageable.

The Bottom Line

RADV audits may be directed at health plans, but the evidence being reviewed begins with the medical record created by providers.

As audit activity expands, practices have more reason to treat clinical chart review as an ongoing documentation-quality process rather than an emergency response to an audit notice.

A structured review can help identify missing specificity, outdated diagnoses, incomplete assessments, and other documentation gaps. More importantly, pairing chart review findings with direct provider feedback can turn those findings into better documentation habits.

For organizations looking to build a more consistent approach, CoDoc Academy's Member Clinical Review program combines clinical chart review with provider feedback to help address documentation gaps relevant to ICD-10 coding, HCC coding, and risk adjustment.

Ready to strengthen your documentation process?

Learn more about CoDoc Academy's Member Clinical Review program.