Response to Comments

DV General Comments for 60-Day Comment Period
Organization

DV Area

Description of Issue or Question

Advent Advisory Likert Scale
Group (a6li)

Standards 1c, 1d, 1e, 1h and 2 e: 1.) Why were only the specific
standards listed above chosen to be impacted by this change? For
instance, why was Standard 3a not included in this proposal?
2.) It appears that Part C and D Grievances, based on the
documentation provided, are no longer at 0% threshold for error. Is
this correct? If so, this seems to run counter to CMS's goal for
differentiation in scores, as having those measures set for 100%
accuracy appeared to be a major differentiator in scores
across Advent's book of business, and we would assume across all
clients undergoing Data Validation review.
3.) It is our understanding that CMS intends that this scoring change
would be put into effect starting with the 2017 DV season (for 2016
calendar year data). As this is a major change to scoring, and will
require deeper understanding by all the SO's, training within the SO's
and for all DV clients, we would kindly
propose that should these changes be put into place, that they do not
become effective until the 2018 DVseason (for 2017 calendar year
data). This will allow all SO's and client to get up to speed and fully
understand the scope of these changes prior to them becoming
effective. All of our proprietary tools and documentation will need
updating to accommodate these changes and allowing for more time
and education on CMS's expectations will ensure all SO's are
implementing the changes in the same manner.

Medical Mutual Cover Page
of Ohio (rdwh)
MMMHC (85e4) Cover Page

The cover page cites Version 7, while header and footers on
subsequent pages cite Version 6.0.
General comment: Document header in each page has not been
updated (references Appendix B
version 6.0).

Commenter's
Recommendation
N/A

N/A
N/A

CMS Response/Action
Some standards are
better scored by a "passfail" or "yes-no"
response. The
standards scored using
the Likert Scale require
sampling and are fairly
specific. We believe that
Standard 3a is more
generic and is better
suited for an overall
assessment which does
not fit the Likert Scale 15 format. That is our
opinion at this time but
we could reconsider this
in the future.

CMS will correct the
cover page.
CMS will correct
Appendix B.

Organization

DV Area

Description of Issue or Question

Ucare (71eq)

Scoring

UCare does not support revising the scoring methodology for some
standards and sub-standards from a binary scale (i.e., Yes/No) to a
five-point Likert-type scale. This adds additional complexity to the data
validation process.

United
Healthcare
(tc7y)

Supporting
Statement:
Five Point
Likert Scale

United seeks clarification from CMS regarding whether this proposed
revision is applicable to only the 2017 and 2018 DV collection periods,
or if it also applies to the 2016 DV collection period. If the proposed
five-point Likert-type scale is not adopted for the 2016 period, United
would ask for further clarification on whether the current scoring
methodology will be applicable to the 2016 DV collection period
instead. Should CMS make this change, we understand that the
current 100% accuracy threshold for the individual grievance
categorization sub-standard measure to receive a 5-star rating would
change to a 95% threshold. If that is not the case, then we request
additional clarification regarding the weighting/scoring at the standard
level, reporting section level, and the contract level for the following
scenarios under the five-point Likert-type scale: Display Measures and
measures used for Star Ratings. We strongly encourage CMS to
consider adopting the five-point Likert-type scale starting with the 2016
DV collection period, which would correspond to the DV audit
occurring in 2017.

Commenter's
Recommendation
N/A

Additionally, we would
encourage CMS to
consider applying the
five-point Likert-type
scale at the standard
and sub-standard
levels to all reporting
sections and data
elements.

CMS Response/Action
CMS respectfully
disagrees. We believe
that using the Likert
Scale provides a more
rigorous scoring
methodology that also
offers greater feedback
to plans about the areas
that need improvement
versus areas in which
they are performing well.
CMS does not intend to
change the proposed
methodology to use the
Likert Scale at all
standard and substandard levels. Some
changes toward this end
might be considered in
the future.

Organization
United
Healthcare
(tc7y)

DV Area
Toolkit

Description of Issue or Question

Commenter's
CMS Response/Action
Recommendation
There are many references to a toolkit throughout the Coverage
We respectfully
The toolkit will be
Determinations and Reconsiderations. Specifically, Appendix L states request that CMS
released with the final
“Toolkit for universes for sponsor data validation should be used by the release a copy of the DV document.
reviewer when validating plan data. The toolkit provides a guide on
toolkit specifications
which data elements to identify from SO data, to validate data
and QC steps to allow
submitted in HPMS for this reporting section.”
plans the opportunity
to review.

BCBS
Submission
Association (8rlt) Deadline

Also one plan noted that the early February data submissions may be
a challenge for plans and lead to more resubmissions.

N/A

While this comment is
out of scope for the DV
PRA. CMS will consider
this comment.

BCBS (ymqk)

The CMS Supporting Statement indicates that for the CY2017 and CY
2018 data collection periods, the agency is proposing to revise the
Findings Data Collection Form (FDCF) by changing the scoring of six
standards (i.e., 1c, 1d, 1e, 1g, 1h, & 2e) from a binary scale to a fivepoint Likert-type scale. CMS expects that this change will improve the
precision of the data validation scores by increasing the overall
variation in total scores among Medicare Advantage Organizations
(MAOs) and Prescription Drug Plans(PDPs). While we appreciate that
the agency is proposing this modification with the intention of
improving the precision of scores, we believe additional information is
necessary to permit a comprehensive review of the change.

For example, we would
appreciate receiving
from CMS our most
recent data validation
scores for the six
impacted standards,
calculated under both
the existing and
revised scoring
methodology. We
believe data along
these lines would
permit HCSC to fully
evaluate the proposed
change and provide
the most informed
and meaningful
feedback to CMS.

At this time, CMS is not
able to provide your
current DV scores in the
new methdology.
However, you are able to
retrieve your current DV
scores in HPMS.

FDCF

Organization
Perform Rx
(8l4s)

DV Area

Description of Issue or Question

Audit Training Data Validation audits are performed by external contractors who are
compensated by plan sponsors. CMS's current data validation auditor
training is not at all rigorous. This training is at an individual level and
in its current form does not represent excellence or competence on the
part of the audit firm. To date, we understand that CMS does not have
a process to certify specific audit contractors. While most firms are
reputable, there is nothing to prevent less-than-qualified audit firms
from conducting such audits. We believe that CMS should strengthen
the data validation audit process by requiring higher auditor training
standards.

Perform Rx (8l4s)Consistent
Auditor
Interpretation

Commenter's
Recommendation
N/A

In order for the data to be reliable and valid, consistent audit
N/A
interpretation is required amongst auditors. PerformRx has
experienced inconsistency across data validation auditors first hand.
For example, for the Medication Therapy Management (MTM) data
validation, we experienced one auditor who interpreted that we are not
permitted to count the same recommendation twice to a different
provider, regardless of quarter. Conversely, another data validation
auditor interpreted that a recommendation could count twice if the
recommendation was made in a separate quarter. As illustrated by this
example, the same type of event may or may not be reported,
depending on the particular interpretation of the auditor. Reporting by
Part D sponsors therefore may not be a true measure of their services
(i.e., underreporting or overreporting). Further, comparisons among
sponsors may not be valid if data is reported differently due to data
validation auditors’ varying interpretations.

CMS Response/Action
At this time, CMS has
committed to changing
the DV questions anually
and creating more
complex questions. CMS
shares this concern and
is working towards this
goal. If you have specific
suggestions to assist us
please feel free to
provide them.
This comment is out of
scope, and there is a
procedure if you
disagree with a DV
auditor’s assessment,
and your
comments/concerns can
always be sent to the
respective CMS
mailboxes like DV or Part
D plan reporting. CMS
Action: No action taken.

Organization
Perform Rx
(8l4s)

DV Area

Description of Issue or Question

Commenter's
Recommendation
Reporting
Would CMS be willing to release final reporting requirements earlier in An earlier and
Requirements the year and on a consistent basis?
consistent release
would be especially
helpful when there are
significant changes.
This would enable Part
D sponsors and PBMs
sufficient time to adjust
and finalize logic and
make other needed
systems changes. This
could lead to higher
validation scores
across the industry
and reduce
administrative burdens
on CMS.

CMS Response/Action
At this time, this
comment is out of scope
regarding Reporting
Requirements. However,
CMS works to release
this information as soon
as possible.

Organization
Perform Rx
(8l4s)

DV Area

Description of Issue or Question

Post-Validation Post-validation guidance and best practices from CMS would be
Guidance and beneficial for Part D sponsors and PBMs to know how to adjust
Best Practices reporting to better meet CMS’ reporting requirements.

Commenter's
Recommendation
PerformRx
recommends, for
example, that CMS
issue a Best Practices
and Common Findings
memorandum, and
CMS job aids, for the
data validation audits
similar to the
memoranda that CMS
issues for CDAG and
ODAG audits.
Additional training and
communication from
CMS would also be
welcome to strengthen
the process.

CMS Response/Action
CMS agrees and this
year we have released a
"Best Practices" memo
and we can consider
doing this annually if the
industry finds this helpful.

Grievances for 60-day Comment Period
Organization
Section
BCBS Association Appendix 1 Data
(2n4c)
Validation
Standards_Version
3_061516.508.pdf:
Pages 3 & 4

Description of Issue or Question
Commenter's Recommendation
There appears to be some contradiction in that We recommend CMS confirm
Appendix 1 Data Validation Standards_
when/if expedited grievances should
Version 3_061516.508.pdf: Page 4 in the table be included in the reporting.
about REPORTING SECTION CRITERIA for
Part C grievances, #6.j states “Excludes
expedited grievances,” but #5 item c and #8,
item a.iii of the same section reference the
inclusion of expedited grievances.

CMS Response/Action
CMS agrees and will
update Appendix 1 and
Part C RR & TS
documents.

Additionally, the Medicare Part C Plan
Reporting Requirements Technical
Specifications, item # 5, Page 9, indicates that
the expedited grievances should be included
in the reporting.

Ucare (71eq)

Align the Part C and D Grievance reporting
accuracy threshold with the accuracy
thresholds for the other reporting section so
that all have a 90% accuracy threshold.

N/A

This will change with the
new Likert Scale
methodology.

SOA for 60-day Comment Period
Organization
Section
Medical Mutual Page: 35, Section:
of Ohio (rdwh) Reporting Section
Criteria #4

Description of Issue or Question
Commenter's Recommendation
Medical Mutual would like clarification
N/A
regarding the timeframe for the following
criteria: "g" cites "previous calendar
year" as the timeframe as follows:
Properly identifies and includes the
Agent/Broker Training Completion Date
for the previous calendar year products.
(Ex. If the current year is 2016 it would
be CY2015 products, etc.) "h" cites
"previous year" as the timeframe as
follows: Properly identifies and includes
the Agent/Broker Testing Completion
Date for the previous year products. (Ex.
If the current year is 2016 it would be
CY2015 products, etc.)

CMS Response/Action
CMS agrees and will update.

United
Healthcare
(tc7y)

Following the suspension of reporting
N/A
Sponsor Oversight of Agents in 2017, we
request clarification whether CMS plans
to remove it from the DV occurring in
2017. Removing Sponsor Oversight of
Agents from the DV occurring in 2017
might reduce costs incurred for the DV
occurring in 2017 as well as any costs
associated with any pre-assessment
activity for this reporting section.

The SOA 2016 data collection
will be data validated in 2017.
The SOA 2017 data collection
will not be included in the 2018
data validation.

SOA

HRA for 60-day Comment Period
Organization
Kaiser (kzdr)

Section

Description of Issue or Question

E13.1: Number DVA E13.1a doesn't specify a minimum duration of N/A
of New
enrollment for a member to count as a new
Enrollees
enrollee while the technical specifications, April 22
version. state the member must be enrolled
continuously for more than 90 days after the
effective date of enrollment to qualify as a new
enrollee

Commenter's
Recommendation

CMS Response/Action
RSC 4.a. will be revised to state:
Includes all new members who enrolled
during the measurement year, and
includes those members who may have
enrolled as early as 90 days prior to the
effective enrollment date as they will be
considered eligible for an inital HRA for
the year in which the effective
enrollment date falls.

Organization
Kaiser (kzdr)

Section

Description of Issue or Question

E13.1: Number DVA E13.1c states that a member is new if s/he
N/A
of New
disenrolled and reenrolled and an initial HRA was
Enrollees
not performed prior to disenrollment.
This means that if an initial HRA was performed
prior to disenrollment, the member would not be
new. This standard conflicts with 06/24/2016
response from CMS
(referenced above) where they indicate the
following interpretation of the 06/20/2016
Clarification of Data Elements 13.1 and 13.2
communication (refer to Example 1) is correct.
CMS's response is the blue text and indicates that
plans are to look at each enrollment separately. In
the below example, CMS confirmed that a member
who received an initial assessment and then
disenrolled, reenrolled, and received another initial
assessment would in fact be counted as a new
member twice. This guidance clearly conflicts with
the DVA standards for element 13.1.
Example 1: Member enrolls on 2/1/2016, initial
HRA completed on 3/15/2016 and member
disenrolls 6/1/2016. Same member reenrolls on
8/1/2016 and initial assessment is completed on
10/1/2016 and member remains enrolled through
year end. Based on revised guidance, we would
count the member and
the HRAs twice: 2 under E13.1 and 2 under E13.3.
That is correct

Commenter's
Recommendation

CMS Response/Action
We do not think the DV standards need
to be revised, but the guidance from
CMS should provide this clarification;
per the 7/25/16 updated version of the
Part C reporting requirements technical
specifications, enrollees who received
an initial HRA and remain continously
enrolled under a MAO that was part of
the consolidation and merger within the
same MAO or parent organization will
not need to participate in a second initial
HRA.

Organization
Kaiser (kzdr)

Section

Description of Issue or Question

E13.1: Number DVA E13.1c contradicts DVA E13.1d. As stated
N/A
of New
above, E13.1c implies a member is not new if an
Enrollees
initial HRA was performed prior to disenrollment.
DVA E13.1d requires continuous enrollment for an
HRA completed in a previous year to indicate the
member is not new. This adds a layer of
complexity beyond the discrepancies between the
DVA standards and the Technical Specifications.

Commenter's
Recommendation

CMS Response/Action
Disagree. It appears that the
commentator is assuming that there can
be only one condition to match the
scenario where a member may be
considered a ‘new enrollee and eligible
for an initial HRA’, which is not the case.
Further, the two standards are for
different scenarios and do not
contradict each other. RSC 4.d states
that members should be excluded from
the count of “new members’ if they are a
continuously enrolled member with an
initial HRA in the previous year. This
does not contradict with RSC 4.c which
states that members should be included
as “New members” if initial HRA was not
performed prior to disenrollment and
subsequent re-enrollment

Organization

Section

Description of Issue or Question

Commenter's
Recommendation

CMS Response/Action

Kaiser (kzdr)

E13.2: Number
of Enrollees
Eligible for an
Annual
Reassessment
HRA

DVA E13.2d does not include any reference to the N/A
365 day reassessmen t interval. This implies the
member is counted as eligible for a reassessment
by the close of the measurement year even if day
365 is not reachedthis does not make sense as
plans have the full 365 days to complete a
reassessment. We raised this same issue with
CMS about the technical specifications, April 22
version, and CMS indicated they would issue a
clarification. It is critical that the DVA standards
are updated to reflect any subsequent
clarifications released by CMS.

Agree. It appears that the
commentator’s contention is that by not
explicitly stating the 365-day
reassessment interval, it could be
interpreted that a member is eligible for
reassessment even before the 365 days
have passed since the reenrollment,
which is incorrect. This is different from
the case where an initial assessment
was not performed within 90 days of
reenrollment (in which case the member
becomes eligible for reassessment
within 90 days of reenrollment).Includes
members who dis-enrolled from and reenrolled into the same plan if an initial
HRA was performed within 90 days of reenrollment and the member has
remained continuously enrolled in the
same plan for 365 days since the initial
HRA.

Kaiser (kzdr)

E13.3: Number
of Initial HRAs
Performed on
New Enrollees

DVA E13.3b states only HRAs performed between N/A
1/1 and 1 2/31 of the measurement year count
which conflicts with the technical specifications
which state that if the initial HRA is performed in
the 90 days prior to the effective enrollment date, it
is included in the reporting year in which the
effective enrollment date falls. Refer to the notes
section of the technical specifications to see the
(the commenter did not finish this sentence)

We recommend that RSC 7.b be revised
to state if the initial HRA occurs before
the effective date of enrollment and in a
different calendar year, count the initial
HRA in the year that the effective date
of enrollment occurred.

OD/RC for 60-day Comment Period
Organization
CVS Health
(h8g8)

Section
Appendix 1: Data
Validation
Standards For
Data Validation
Occurring in 2017

Description of Issue or Question
The DV standard appears to limit the reporting of
service authorization to pre-services cases only.
For example: CMS requires plans to report
organization determinations and reconsiderations
requests submitted to the plan. For purposes of
Reporting Section 6: An organization determination
is a plan’s response to a request for coverage
(payment or provision) of an item or service –
including auto-adjudicated claims, prior
authorization requests, and requests to continue
previously authorized ongoing courses of
treatment. It includes requests from both contract
and non-contract providers. CMS also states, “In
contrast to claims (payment decisions), service
authorizations include all service-related decisions,
including pre-authorizations, concurrent
authorizations and post-authorizations.” We
encourage CMS to update the documents for
consistency between both the DV standards and
the Part C reporting technical specifications.
Additionally, the DV standards for data element
6.10: Number of Requests for Organization
Determinations - Dismissals, reference following
the Reconsideration Dismissal Procedure rather
than guidance for processing for Organization
Determinations - Dismissals.

Select Health
(80c8)

Elements 6.9 and In regards to Dismissals and Withdrawls, in one
6.10
place it says to exclude dismissals, but then in
another place it says to include them. (please see
elements 6.9 and 6.10)

Commenter's Recommendation
We encourage CMS to replace the
Reconsideration Dismissal
Procedure in the Appendix 1 with
the guidance for processing for
Organization Determinations Dismissals.

CMS Response/Action
We changed the term “preservice” with the term
“service” in the Data
Validation Standards
document for the standards
for Organization
Determinations/Reconsiderati
ons.

N/A

CMS will correct this in the
Appendix. Dismissals and
withdrawals should be
included per the technical
specifications.

MTM for 60-Day Comment Period
Organization
Perform Rx (814s)

Section

Description of Issue or Question

Consistent Auditor PerformRx has experienced a data
Interpretation
validation auditor questioning our
(MTM)
reporting a cognitive impairment for an
enrollee in element H of the MTM Record
Layout because we had spoken to the
person the year before but had not done a
CMR for the current year. There was no
citation provided by the data validation
auditor for his/her interpretation. The
guidance is: 2016 Reporting
Requirements: Data Element H.
Beneficiary identified as cognitively
impaired at time of comprehensive
medication review (CMR) offer or delivery
of CMR. (Y (yes), N (no), or U (unknown)).
Data Validation Standards for Data
Validation Occurring in 2016 and
proposed for 2017: Organization
accurately identifies MTM eligible
members who are cognitively impaired at
the time of CMR offer or delivery of CMR
and uploads it into Gentran, including the
following criteria: a. Properly identifies and
includes whether each member was
cognitively impaired and reports this
status as of the date of the CMR offer or
delivery of CMR.
[Data Element H]

Commenter's Recommendation CMS Response/Action
We continue to recommend
against using the data
validation audit result to validate
the CMR completion rate Star
Ratings measure until the
process is more consistent and
more transparent.

CMS disagrees and at this time
CMS will continue to use the data
validation audit result to validate
the CMR completion rate Star
Ratings measure. Please feel free
to provide any comments regarding
the CMR completion rate during the
Part D Reporting Requirements 30day PRA comment period.
CMS Action: No action taken.

Organization
Perform Rx (814s)

Section
Using Existing
MTM Data
Validation to
Support the
Program Audit
Process

Description of Issue or Question
In recent comments on CMS’ 2017 Draft
Part D Program Audit Protocols,
PerformRx asked CMS to consider
removing Table 1 2015 Universe Column
IDs A-T from the Part D MTM Program
Area PILOT Audit Process and Data
Request in Appendix A. This is because
CMS collects a similarly detailed MTM
report from Part D sponsors annually as
part of the Part D Reporting
Requirements. The contents of this report
are almost identical to the contents of the
universe and could be used by the
auditors to draw samples. Producing a
second report with the same information
in a second layout is duplicative.

Commenter's Recommendation CMS Response/Action
One option for CMS is to
amend its data validation
protocols to include a universe
validation requirement on the
part of the data validation
auditors (for the MTM detail
report specifically). CMS may
find this approach more
operationally efficient as well.

This comment is out of scope for
the DV PRA.Please submit this
comment to the Part D Reporting
Requirements and/or MTM
mailbox. CMS Action: No action
taken.

CD/RD for 60-day Comment Period
Organization
CVS Health
(h8g8)

Section

Description of Issue or Question

Appendix 1: Data
Validation
Standards For Data
Validation Occurring
in 2017

Appendix L – Toolkit for universes for
sponsor data validation should be
used by the reviewer when validating
plan data. The toolkit provides a guide
on which data elements to identify
from SO data, to validate data
submitted in HPMS for this reporting
section.

Commenter's Recommendation CMS Response/Action
"The document refers to
Appendix L will be released when the
Appendix L, but none of the
entire DV manual is released. CMS
documents in the attached 2017- Action: No action taken.
2018 DVR Update packet
contain Appendix L. We
request that CMS please
provide information on how to
obtain Appendix L. "

Organization
CVS Health
(h8g8)

Section

Description of Issue or Question

Appendix 1: Data
Appendix L includes nine universes
Validation
listed below:
Standards For Data
Validation Occurring Coverage Determinations (U1)
in 2017
Coverage Determination Exception
Requests (U2)
Member Reimbursement Request
Coverage Determinations (U3)
Coverage Determinations (U4)
Coverage Determination Exception
Request (U5)
Redeterminations (U6)
Member Reimbursement Request
Redeterminations (U7)
Redeterminations (U8)
Expedited IRE Auto-forwarded
Coverage Determination and
Redeterminations (U9)

MMMHC (85e4)Appendix 1: Data
Validation
Standards For Data
Validation Occurring
in 2017

Commenter's Recommendation CMS Response/Action
We request that CMS please:
1) Provide a definition of what
Universe Toolkits are, and
where they can be located.
2) Provide more information on
what will be included in a
Universe Toolkit.
3) Provide examples of each
Universe Toolkit.
4) Explain how a Universe
Toolkit differs from the Primary
Source Verification (PSV). For
example, would Universe Toolkit
1, which includes Standard
Coverage Determinations, have
30 samples as part of the
Toolkit, and then another set of
samples for the PSV?
5) Provide information regarding
when these universes should be
provided to the Data Validation
reviewer.
6) Provide details regarding who
should provide the universes to
the Data Validation reviewer.

We noticed that the Data Elements on N/A
page 33 (3.B.13.B.10) for the
reopening section are not aligned with
the above list.
Please clarify.

CMS developed Appendix L’s Universe
Toolkit using the universes collected for
CMS’ program audit of sponsors’ Part D
Coverage Determinations, Appeals, and
Grievances processes. This toolkit will
correlate directly with the Findings Data
Collection Form and should be used by
the reviewer as a reference to validate
plans’ reported data for the Coverage
Determinations and Redeterminations
Reporting Section. Appendix L is a
resource document, used for data
validation purposes only. CMS does not
intend to collect universes through HPMS.
Appendix L will be released with the final
DV manual. Questions and comments
should be sent via email to:
[email protected]
v.
CMS Action: No action taken.

CMS will revise the Data Elements on
page 33. CMS Action: CMS revised the
Data Elements on page 33.

Organization

Section

Description of Issue or Question

Commenter's Recommendation CMS Response/Action

MMMHC (85e4)Appendix 1: Data
Validation
Standards For Data
Validation Occurring
in 2017

The questions regarding the high cost N/A
edits for compounds were eliminated
for the 2017 Reporting Requirements;
however, we noticed that the 2017
Data Validation Standards includes
elements regarding high cost edits for
compounds. Please clarify, if high cost
edits for compounds will be a measure
for contract year 2017.
Will 2017 Reporting Requirements be
updated to include high cost edits for
compounds?

The high cost edits for compounds was
removed for 2017 reporting but will remain
in 2016 reporting therefore, it is properly
listed in the 2017 DV. The high cost edits
for compounds will be removed from 2018
DV. CMS Action: No action taken.

United
Healthcare
(tc7y)

The DV standards appear to limit the
reporting reason(s) for reopening to
Clerical Error, New and Material
Evidence, or Other. We respectfully
ask CMS to clarify whether Fraud and
Similar Fault will continue to be a
reason for reopening in the 2016
measurement period.

CMS agrees and will revise the DV
standards to include Fraud and Similar
Fault, which aligns with Chapter 13 and
the reopening reporting template. CMS
Action: CMS revised the DV Standards to
include Fraud and Similar Fault.

We encourage CMS to update
the DV standards to include
Fraud and Similar Fault, which
aligns with Chapter 13 and the
reopening reporting template.