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2025 Medicare Part C & Part D Reporting Requirements & Data Validation

Guidance for DV Standard 2

Implementation Guidance

(Sub-Standard 2a)

Assess the programming code to determine if SOs extracted the data from the system properly and if the calculations SOs used in reporting data to CMS are correct according to the reporting section under review.

A thorough review of source code examines every line of code to confirm the following for each reporting section under review:

  • Data are extracted from the appropriate source system:
    • Verify that all data sets found in the programming code can be traced back to the appropriate source data sets.
  • SOs filtered data sets correctly:
    • Verify that SOs applied data inclusion and exclusion criteria according to the standard and sub-standard criteria.
    • For example, proper inclusion of records would guarantee that source code shows that only those records falling within the reporting period date range are included in the reported data. An example of correct exclusion would document source code that shows beneficiaries aren’t eligible for a particular benefit, like the Medication Therapy Management Program.
    • Individual data sets are joined or merged correctly (especially important when moving data from source data sets to intermediate data sets).
    • Verify that SOs used the correct key data field to generate the new data set and that they used the correct type of join (or data merge) to avoid creating duplicate records or improperly combining records from various data sets.
  • Data set progression is correct:
    • Verify that required data fields in both the source and final stage files allow for file comparison and understanding of data production from source system through the final stage file.
    • If full census data isn’t extracted, verify that the sample size is sufficient and represents the population of interest.
    • While the Data Extraction and Sampling Instructions provide minimum sample sizes, DVCs often will need larger data sets to check for errors that occur infrequently. Statisticians should rely on standard statistical practices when determining the proper sample sizes so that any estimates generated are statistically significant.
  • All preliminary data sets and interim data sets are correct:
    • Verify that each data set is consistent with the standard/sub-standard description.