Insuring the Clawback: Why RADV Extrapolation Turned MA Risk Adjustment Into an Unreserved Balance Sheet Liability and the Case for Building a Regulatory Recoupment Insurance Market Vehicle

Medicare Advantage plans have a large, openly disclosed, completely unreserved regulatory liability. The 10-K says ‘unable to estimate range of loss.’ That is not immateriality. That is a real exposure nobody is booking. Here is why it matters.

RADV audits check whether diagnosis codes submitted for MA payment are supported by the actual chart. When they…