Centers for Medicare & Medicaid Services Required Initial Validation Audit (IVA) Begins in June

Posted May 22, 2018

As an insurer participating in the Affordable Care Act's (ACA) Risk Adjustment (RA) program, Blue Cross and Blue Shield of Illinois (BCBSIL) needs your participation in the Centers for Medicare & Medicaid Services (CMS) required Initial Validation Audit (IVA). The IVA will be performed on a random sample of members enrolled in ACA-compliant individual and small group plans, including plans that are available on and off the Exchange. CMS mandates that BCBSIL provide the full 2017 medical records from the physician office and hospital records for those members selected to be audited. 

A key component of the RA program is a calculation based on enrollee risk. As a reminder, enrollee risk is calculated based on the diagnosis codes submitted on a claim, as well as through supplemental codes captured through medical record review. As a BCBSIL independently contracted provider, you may be asked to provide medical records for a member to validate all the diagnosis codes submitted on claims, which are then used in the RA calculation.

Medical Record Submission Standards for the IVA

You may include the following documents for the IVA audit:

  • Progress notes, history and physical, discharge summary, consultation reports and operative/procedure notes
  • Pathology reports, physician orders, medical list and radiology may substantiate a diagnosis and be submitted, but only in conjunction with other medical documentation
  • Records must be signed and credentialed within 180 days of the date of service. (If the credentialed signature is missing, BCBSIL will contact you for a Signature Statement Attestation.)

To comply with the precise timeline requirements of the CMS IVA, we appreciate your support in submitting the requested medical records as you receive notification letters listing the enrollees selected for the audit. BCBSIL began mailing the IVA letters in June 2018. 

To expedite the retrieval process, please provide the appropriate contact name and method for retrieving medical records by completing our brief survey.

If you have any questions, email us at