Outline for DV Procedure Manual_110910

Medicare Program Audit and Compliance Infrastructure Development

Task 11: Development of Parts C & D Measure Data Validation Standards and Procedures

Outline for Data Validation Procedure Manual

Part C and Part D Reporting Requirements Data Validation Procedure Manual

1. Introduction and Background

   1. Data Validation Requirement (regulatory reference, goals of program)

   2. Types of Organizations Required to Undergo Data Validation

   3. Requirement to Use this Manual and Tools

2. Overview of Data Validation Process

   1. Introduction to the Data Validation Standards

   2. Data Validation Scope (including mention that validation is conducted at “contract” level)

   3. Reporting Requirements That are Excluded from the Validation Requirement at this time

   4. Data Validation Timeline

   5. Graphic of entire process start to finish

3. Selecting a Data Validation Contractor

   1. Timing of Data Validation Contractor Selection

   2. Standards for Selecting a Data Validation Contractor (Appendix A)

   3. Documentation of Selection Process

   4. Requesting A Contractor Change Mid-Review

4. General Data Validation Preparation Activities

   1. Complete Data Validation Training (address requirement for both Sponsoring Organization and DV contractor staff)

   2. Study and Learn the DV Standards (See Appendix B)

   3. Request Access to HPMS Plan Reporting Data Validation Module (address process for both DV contractor and sponsoring organization)

5. Planning for Data Validation Activities

1. Complete and Submit Organizational Assessment Instrument (OAI) (Appendix C)

2. Analyze OAI Responses

Perform OAI Gap Analysis

Review Source Code and Other Documentation

Prepare Supplemental Discussion Guide (Attach to Standard Interview

Discussion Guide–Appendix D)

3. Onsite Data Validation Preparations

Select Dates of Visit

Select Appropriate Location(s) of Visit

Develop Timeline and Agenda for Onsite Review

Prepare for Data Extraction and Sampling

6. Onsite Data Validation Activities

   1. Conduct Entrance Conference

   2. Conduct Interviews with Organizational Staff

   3. Observe Reporting Processes

Review of Systems

Review of Measure-Specific Criteria

Review of HPMS Report Generation Process

4. Determine Census or Sample Data Location

5. Extract Census or Sample Data (Appendix E)

6. Conduct Exit Conference

7. Determining and Documenting Data Validation Findings

   1. Request for Additional Documents (if required)

   2. Review Information Systems Standards Analysis Process

   3. Review Census or Sample Data

Populate Data Review Templates

Validate Data Quality

Compare Source Code

Determine Compliance with DV Standards including Measure-Specific Criteria

4. Determine Findings and Complete Draft FDCF (Appendix F)

5. Review Draft FDCF with Sponsoring Organization (optional)

6. Complete Final FCDF

7. Enter Findings in HPMS Plan Reporting Data Validation Module

8. Archive Work papers/Record Retention

8. Submit Findings to CMS

   1. Submit Findings in HPMS Plan Reporting Data Validation Module

   2. Sponsoring Organization Comments on Findings

9. CMS Determination of “Pass” or “Not Pass”

   1. Pass/Not Pass Criteria

   2. Pass/Not Pass Thresholds

   3. Timing and Method of CMS Notification to sponsoring organization of Pass/Not Pass Determination

   4. Organization Appeal Process

   5. Consequences of Not Pass Determination

Appendices

1. Standards for Selecting a Data Validation Contractor

2. Data Validation Standards

3. Organizational Assessment Instrument

4. Interview Discussion Guide

5. Data Extraction and Sampling Instructions

6. Findings Data Collection Form

7. Glossary and Acronyms

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This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.