Align data validation stakeholders to avoid last minute mistakes

By Chris Hanson-Ehlinger
Mon, Aug, 18, 2014

Dollarphotoclub 54815417Management and oversight of data validation varies between health plans. Different plans may use an audit department, a compliance unit or a Medicare oversight department. However your plan is structured, having a centralized business unit in charge of data validation reporting can ensure clear and effective communication to all stakeholders. Consider the following ideas to help make your 2015 review a success.

Research tech spec changes

It’s important to identify how data validation requirements changed between 2013 and 2014. The technical specifications (tech specs) issued by CMS are complex and lengthy. Use a systematic approach to do an exhaustive comparison. You may also want to check our blogs frequently, which identify key differences and what they mean to your plan. Other document comparison software is available or you can use the compare functions in MS Word or Adobe Acrobat. Your plan will also need experienced staff to dig deep into these documents to find the nuanced changes from year to year.

Identify responsible parties

After finding the tech spec changes make sure you have an updated list of the departments or subject matter experts (SMEs) that will be in charge of implementing the requirements. It’s best not to rely too heavily on the prior year’s list, as each year your plan should re-evaluate its resources to most effectively complete the data validation requirements. Also remember that you may need to delegate responsibility for the new 2014 reporting section, “Plan Oversight of Agents”.

Disseminate the changes

Next, the 2014 changes can be disseminated to the stakeholders for each reporting section. The SMEs can use this time to pore over the tech specs to make sure no changes have been missed and to identify resource needs. This might also be a good time to review the 2014 audit findings for any additional process fixes. Make sure each stakeholder is clear about his or her area of accountability. And don’t forget about process improvements! This is a good time to identify where IT can get involved to help systematize some of the manual processes.

Understand and test requirements

Many audit findings are due to either missing tech spec updates or not clearly understanding the changes from year to year. It is important to discuss open items or questions with the stakeholders from each reporting section. An SME checklist or worksheet is a handy way to identify reporting requirements (not only the changes) and demonstrate that the requirements are captured. A best practice is to separate individuals who test the requirements from those that implement the requirements. Also, check-in to make sure each group is moving ahead in a timely manner. Waiting until the last minute to make changes raises the risk of review findings.

Enter accurate data

Once the data is entered into HPMS, have someone double check for accuracy. You may be surprised by the high number of plans with data entry errors. Ask for help and ensure you aren’t giving away any points on your next audit.

The best way to ace your data validation audit is to start early. As always, Burchfield is here to help you clarify the data validation process. We’ll provide more in depth analysis of the 2014 changes in upcoming posts. Let us know if you have questions or best practices you’d like to share.

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Related articles:

Complex 2014 Determinations reporting section challenges plans
Bad data validation scores reduce your star rating and bottom line
Data validation element changes and what to expect in 2015 audit


describe the imageJason Hoyme, senior auditor and analyst at The Burchfield Group, manages audits and supports clients engaged with Burchfield for CMS data validation audits. For more information, please call 800-778-1359 or send us a note (

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