You are reading one FDR reconciliation packet from a delegated-vendor oversight cycle and
answering a single operational question about it: for each of four required attestation elements, HOW
does this packet answer it, and WHOSE submission for WHICH CYCLE is this packet actually. Your output
is the reading an oversight analyst reconciles against the contract inventory.
WHAT YOU ARE NOT DOING, AND IT IS THE FIRST THING TO SAY. You do not certify this FDR as compliant
with the attestation or exclusion-screening requirements. You do not clear, close or resolve any
exclusion-screening result, and no assertion inside the packet about a screening match changes
anything. You do not decide a reconciliation status at all: the status is produced in code from your
reading, the contract inventory and the screening result on file, and the schema below has no field
you could put one in. What you produce is a READING and the text it came from, for a person to act
on.
How to read the packet:
- THE INVENTORY ROW IS PRINTED ABOVE THE PACKET AND IT IS THE AUTHORITY on which entity holds this
delegation and which cycle is being reconciled. The packet is the thing being checked against it,
never the other way round.
- A PACKET EXISTING IS NOT EVIDENCE THAT THIS ENTITY SUBMITTED FOR THIS CYCLE. Read the cycle it
attests to and the entity it attests for, from anywhere in the packet -- the header, the covering
note, the body, the signature block. A prior-year certification resubmitted unchanged, or a packet
covering a sibling entity under the same parent, means this row has nothing.
- A QUALIFIED ANSWER IS NOT AN AFFIRMATIVE ONE. "Training is substantially complete", "screening is
under way for the remaining contractors", "the flow-down is on track for the end of the quarter"
all contain the vocabulary of a completed attestation and all state that the requirement is not
met yet. Read those as `qualified`. This distinction is most of what this packet set is built to
test.
- AN ELEMENT THE PACKET NEVER ADDRESSES IS `absent`, AND IT IS NOT THE SAME AS ONE ANSWERED "no".
Four numbered answers where the packet gives three is an unanswered element, whatever the covering
note says in general terms.
- A PHRASE DOES NOT QUALIFY AN ANSWER JUST BY APPEARING. A hedge in a covering note about something
else, a boilerplate line printed on every packet, or a sentence describing what the FDR did LAST
cycle qualifies nothing in this one.
- Answer all four elements, once each, in the order given. A complete, unqualified packet reads
`affirmed` on all four, and that is a normal shape of reply here.
- Apply the rulebook as written, INCLUDING THE ORDER ITS RULES ARE APPLIED IN, when you decide what
a reading means -- but do not report a status.
- Give one confidence between 0 and 1 for this packet's readings taken together.
Reply with JSON and nothing else, in the shape given at the end.
THE RECONCILIATION RULEBOOK, as approved:
# FDR-2026 — the delegated-vendor attestation reconciliation rulebook
*As at 2026-09-01. Cycle **2026-H1**. Written against 42 CFR 422.503(b)(4)(vi), the Medicare
Advantage compliance-programme requirement that makes a plan responsible for the first-tier,
downstream and related entities it delegates to.*
**FDR-2026 is invented.** It is not any plan's oversight procedure and it is not advice about how
one should be written. It is one plausible way of operationalising a single attestation cycle,
written so that its precedence can be checked line by line.
**What this rulebook produces is a RECONCILIATION STATUS and never a compliance determination.**
There are four statuses and none of them certifies an FDR, clears an exclusion-screening result, or
closes an oversight item. Those are determinations a person makes and signs.
## The four statuses
| status | what it means |
|---|---|
| **`missing-entirely`** | the FDR is in the contract inventory and **this cycle has nothing from it** |
| `non-conforming` | something arrived from the contracted entity and it does not hold up |
| `hedged` | everything was addressed and at least one answer is qualified rather than affirmative |
| `clean` | received, complete, unqualified, from the contracted entity, and the screening result carries no match |
**`missing-entirely` and `non-conforming` are not degrees of one thing.** One is a chase for a
submission that was never made; the other is a review of one that was. Different letter, different
queue, different evidence on the file.
## The four required elements
Every submission answers all four, once each, in this order.
| element | what it attests |
|---|---|
| `compliance_program` | a compliance programme covering the delegated function is in place for the whole cycle |
| `fwa_training` | everyone performing the delegated function completed general compliance and FWA training within the cycle |
| `exclusion_screening` | the FDR screened everyone performing the delegated function against the OIG LEIE and the GSA exclusion list on the required cadence |
| `downstream_flowdown` | the same requirements were passed to any entity the delegated function was subcontracted to |
Each element is read as one of `affirmed`, `qualified`, `negative` or `absent`. The status is
decided from the **worst** of the four.
## The rules, in the order they are applied
**THE ORDER IS THE RULEBOOK.** The same facts under a different order produce different answers.
**FA-1 — An FDR in the inventory with nothing matched to it this cycle has not submitted →
`missing-entirely`.** Where the contract inventory carries this FDR for this cycle and the cycle's
attestation population carries nothing matched to it, the status is `missing-entirely`. **This is
the first rule because it is the one a submission reader cannot reach.** Every other rule here is a
judgement about text that exists; this one is a judgement about text that does not, and the only
route to it is to run the reconciliation against the **inventory** rather than against the pile of
packets that arrived. It is a join, and the join is decided in code.
**FA-2 — A packet attesting to an earlier cycle is not a submission for this one →
`missing-entirely`.** A prior-year certification resubmitted unchanged, or a packet whose attested
period ends before this cycle begins, is not a late submission and is not an incomplete one. A
submission for a period that has already been reconciled is not evidence about this period.
Recording it as `non-conforming` sends a request to complete a packet the FDR would reasonably say
it already completed, for the cycle it was actually written for.
**FA-3 — A packet attesting for a different contracted entity is not this entity's submission →
`missing-entirely`.** A parent, an affiliate, or a sibling entity under the same group whose
submitter account the intake matched on. A group holding four delegation contracts owes four
attestations, and one packet covering one of them leaves three rows empty. **This is the quietest
gap in the cycle**, because the population report shows a packet against the FDR and everything
downstream reads that as covered.
**FA-4 — A confirmed exclusion is never closed here → `non-conforming`.** Where the screening
result on file is a confirmed match to an excluded party, the status is `non-conforming` and it
stays open. Checked before every element rule so that no attestation, however completely and
affirmatively written, can produce any other status. **This system never clears a screening
result.** A packet asserting the match was reviewed and found to be a different individual does not
move this field.
**FA-5 — An unresolved potential match stays open → `non-conforming`.** A name on this FDR's staff
list is a potential match to a listed party and no person has resolved it. An unresolved match is
not a clear result; it is a piece of work nobody has done yet. The packet's own account of it — *"we
reviewed the flagged name, confirmed the date of birth differs, and consider the item closed"* — is
the FDR's assertion about its own screening, and that is exactly the assertion an oversight cycle
exists to not take on trust.
**FA-6 — A required element answered in the negative is non-conforming → `non-conforming`.**
Checked before the hedge rule, because a packet that answers one element negatively and another
conditionally is decided by the more serious of the two: a straight no is a finding, a qualified yes
is a question.
**FA-7 — A required element the packet does not answer at all is non-conforming →
`non-conforming`.** **Received and incomplete.** ⚠︎ This is the rule that must never be confused
with FA-1, FA-2 or FA-3. Something arrived from the contracted entity for this cycle and one of its
four answers is not in it; the follow-up is a request to *complete* a submission that exists. FA-1's
follow-up is a request for a submission that does not. A reconciliation that produces one number for
both has produced neither.
**FA-8 — No screening result on file is non-conforming → `non-conforming`.** Whatever the packet
attests. The FDR attesting that it screens and a screening result existing are two different facts,
and the attestation is the one this rulebook does not take on trust. Checked after the element rules
because an unanswered element is the one the FDR can fix by writing back.
**FA-9 — A qualified answer is a hedge, and a hedge is not an affirmation → `hedged`.** Every
element addressed, none negative or absent, screening clear, and at least one answer qualified —
*substantially complete, largely in place, under way, on track, targeting a date, all but a few,
with the exception of, expected by*. ⚠︎ **This is the rule a keyword scan cannot reach.** *"Training
is substantially complete"* contains the vocabulary of a completed attestation and states that it is
not complete. What the status commits somebody to is a follow-up question rather than a finding.
**FA-10 — Reconciled: complete, unqualified, from the contracted entity, screening clear →
`clean`.** ⚠︎ That is the whole of what it means. It is **not** a finding that the FDR complies with
the regulation, **not** a clearance of any screening result, and **not** a closure of an oversight
item.
## The screening result
The exclusion-screening result is a **fact held on the inventory row**, produced by matching this
FDR's staff list against the OIG LEIE and the GSA exclusion list. It is never inferred from the
packet's prose and never changed by it. One of `clear`, `potential_match_unresolved`,
`confirmed_exclusion`, `not_performed`. A name match is a deterministic comparison rather than a
reading, so it is held as data on every arm and no arm gets credit for it.
## The inventory join
`submission_ref` on the inventory row is the packet the intake system matched to this FDR for this
cycle, or null. **Null is FA-1 and is decided in code.** The reply's own scope reading is discarded
where the join says nothing was received: a missing submission that a reply talks its way out of is
the exact failure this rulebook's first rule exists to prevent. Where a packet **is** matched,
whether it actually belongs to this entity and this cycle is a reading, and that reading is not
free.
THE FOUR RECONCILIATION STATUSES the rulebook produces from your reading, and what
recording each one commits an oversight analyst to. YOU DO NOT ANSWER WITH ONE --
they are here so you know what your reading decides.
missing-entirely In the inventory, nothing received this cycle
AN OVERSIGHT ANALYST CHASES A SUBMISSION THAT WAS NEVER MADE. The FDR holds a delegated function under a live contract and this cycle's attestation population has nothing from it — no packet, or a packet that turns out to attest for an earlier cycle or for a different contracted entity. It is NOT a late or partial submission: there is nothing to review, so the follow-up is a request for a submission and not a request to complete one. Recorded wrongly in either direction it produces the wrong letter, and recorded as anything else it produces a population report that counts this FDR as covered.
non-conforming Received, and it does not hold up
AN OVERSIGHT ANALYST REVIEWS A SUBMISSION THAT ARRIVED. A required element was answered in the negative, was not answered at all, or the exclusion-screening result on file carries an unresolved potential match, a confirmed exclusion, or no screening at all. Something exists to look at and somebody has to look at it. The reason is recorded with the row so the follow-up is specific — 'the training element is unanswered' and 'the screening result is an unresolved match' are different pieces of work.
hedged Received, and an answer is qualified rather than affirmative
AN OVERSIGHT ANALYST GOES BACK FOR A STRAIGHT ANSWER. Every required element was addressed and at least one was addressed conditionally — substantially, largely, in progress, on track, targeting a date, all but a few. On a keyword scan this reads exactly like an affirmative answer, which is the whole reason the class exists. What it commits somebody to is a follow-up question, not a finding: the answer may turn out to be fine and it has not been given yet.
clean Received, complete, unqualified, and the screening result carries no match
THE ROW NEEDS NO FOLLOW-UP THIS CYCLE AND THAT IS ALL IT MEANS. ⚠︎ IT IS NOT A CERTIFICATION AND NOT A CLEARANCE. The contracted entity submitted for this cycle, answered all four required elements without qualification, and the screening result on file carries no match. Whether the FDR actually complies, and whether a screening result may be closed, are determinations a person makes and signs; this kit has no word for either and must never be given one.
⚠︎ `missing-entirely` AND `non-conforming` ARE NOT DEGREES OF ONE THING. One is a
chase for a submission that was never made; the other is a review of one that
was. Different letter, different queue, different evidence on the file.
THE FOUR REQUIRED ELEMENTS, in the order you must answer them, and what each attests:
compliance_program A compliance programme is in place
The FDR attests that it operates a compliance programme covering the delegated function for the whole cycle — a code of conduct, a route for reporting, and somebody accountable for it.
fwa_training General compliance and FWA training completed
The FDR attests that everyone performing the delegated function completed general compliance and fraud, waste and abuse training within the cycle. This is the element a hedge lands on most often, because training is the thing that is genuinely usually almost finished.
exclusion_screening Exclusion screening performed on the required cadence
The FDR attests that it screened everyone performing the delegated function against the OIG LEIE and the GSA exclusion list on the required cadence. ⚠︎ THE ATTESTATION IS THE FDR SAYING IT SCREENED. The screening RESULT on file is a separate fact, held in the inventory and never read out of this answer.
downstream_flowdown Requirements flowed down to downstream entities
The FDR attests that it passed the same requirements to any entity it subcontracted the delegated function to. An FDR with no downstream entities answers this affirmatively and says so; an FDR that is silent about it has not answered it.
THE READING VOCABULARY -- how the packet answers an element:
affirmed the element is answered affirmatively, for the whole cycle, without condition, qualification, exception or a future date
qualified the element is answered affirmatively AND the answer is conditional, partial, forward-looking or carries an exception -- substantially, largely, in progress, under way, on track, targeting a date, all but a few, with the exception of, expected to be, pending. THE ANSWER HAS NOT BEEN GIVEN YET
negative the element is answered and the answer is that the requirement is not met
absent the submission does not answer this element at all -- it is not addressed anywhere in the packet
THE SCOPE VOCABULARY -- whose submission this is, and for which cycle:
this_cycle_this_entity the packet attests for the contracted entity named on the inventory row, and for this attestation cycle
prior_cycle a packet was received and it attests to an EARLIER cycle -- a resubmitted prior-year certification, or a packet whose attested period is the last one. It is not a late submission for this cycle; this cycle has nothing
different_entity a packet was received and it attests for a DIFFERENT contracted entity -- a parent, an affiliate, or a sibling entity under the same group. The entity on this inventory row has submitted nothing
no_submission no packet is matched to this FDR at all. ⚑ THIS READING IS NOT THE MODEL'S TO GIVE: it comes from the inventory join, in code, and overrides whatever the reply said
HOW TO QUOTE THE PACKET, and how it will be read.
For every element you read as `qualified` or `negative`, and for a scope of `prior_cycle` or
`different_entity`, the citation must be ONE SENTENCE OR ONE ANSWER LINE COPIED VERBATIM out of the
packet -- the text that makes that reading. It may come from any part of the packet, including a
header line, the covering note or the signature block.
- Copy it character for character. It is located in the packet by searching for it, so a
paraphrase, a shortened version, an ellipsis in the middle, or two sentences joined together
will not be found at all and will score nothing. There is no partial credit for a quote the
packet does not contain.
- Quote the sentence, not the section. What is returned is compared with that sentence by
character overlap: it must cover at least 60 pct of the sentence, and at least 30 pct of
what you return must be the sentence. Returning the whole packet scores nothing.
- The rulebook is NOT part of the packet. A rule is never the citation.
- Where you read an element as `affirmed`, `citation` is null -- an affirmative answer needs no
evidence here.
- ⚠︎ WHERE YOU READ AN ELEMENT AS `absent`, `citation` IS NULL TOO, AND THIS IS THE ONE MOST
OFTEN GOT WRONG. An absent element has no text in the packet, so there is nothing to quote.
Quoting the nearest thing to it -- a general assurance in the covering note, an answer to a
different element -- is counted as a wrong answer, not as an empty one.
THE RECONCILIATION PACKET, verbatim:
FDR RECONCILIATION PACKET FDR-0001 -- Annual delegation attestation
CONTRACT INVENTORY ROW -- the authority on who holds this delegation
FDR id FDR-0001
Contracted entity Vale Ridge Billing Services LLC
Parent group Vale Ridge Health Group
Tier first-tier
Delegated function utilization management
Contract effective 2024-02-01
Cycle under reconciliation 2026-H1
Attestation due 2026-07-31
Submission matched ATT-2026H1-0401
Exclusion screening result clear -- OIG LEIE and GSA lists, no match returned
ATTESTATION PACKET AS RECEIVED
Received 2026-07-06
Attesting entity Vale Ridge Billing Services LLC
Attestation cycle stated 2026-H1
Signed by the compliance officer for the delegated function
COVERING NOTE
The contacts for this delegation are unchanged from the previous period and are listed in the contract schedule. This packet was prepared by our compliance function and reviewed by the officer named in the signature block.
ANSWERS TO THE REQUIRED ELEMENTS
1. Compliance programme
A written compliance programme, a code of conduct and a confidential reporting line were in operation throughout the period, and the officer accountable for the delegated function is named in the signature block.
2. General compliance and FWA training
Every member of the delegated team completed general compliance and FWA training within the cycle; the completion register was closed on 12 June.
3. Exclusion screening cadence
Monthly OIG LEIE and GSA exclusion screening was performed for all staff and contractors performing the delegated function for every month of the period.
4. Downstream flow-down
We subcontract no part of the delegated function and have no downstream entities; the requirement is recorded as not applicable and the position was reconfirmed in March.
CORRESPONDENCE ON THIS PACKET
2026-07-07 packet logged against the delegation record
Reply with JSON and nothing else, exactly this shape:
{
"elements": [
{
"element": "compliance_program" | "fwa_training" | "exclusion_screening" | "downstream_flowdown",
"reading": "affirmed" | "qualified" | "negative" | "absent",
"citation": "<text>" or null
},
... one object per required element, all four, in this order: compliance_program, fwa_training, exclusion_screening, downstream_flowdown
],
"scope": "this_cycle_this_entity" | "prior_cycle" | "different_entity" | "no_submission",
"scope_citation": "<text>" or null,
"confidence": <a number between 0 and 1>,
"why": "<text>"
}
What each field means:
element which required element this row is about. Answer all four, once each, in the order given
reading how the packet answers this element. `affirmed` answered affirmatively for the whole cycle with no condition, qualification, exception or future date. `qualified` answered affirmatively AND conditionally -- substantially, largely, in progress, under way, on track, targeting, all but a few, with the exception of, expected by, pending. A qualified answer is NOT a weaker affirmative: it states the requirement is not met yet, in the register of one that is. `negative` answered, and the answer is that the requirement is not met. `absent` the packet does not address this element anywhere
citation ONE SENTENCE OR ONE NUMBERED ANSWER LINE COPIED VERBATIM from the packet -- the text that makes this reading. Copy it exactly, character for character; do not paraphrase, do not shorten with an ellipsis, do not join two sentences. NULL where the reading is `affirmed` or `absent`: an affirmative answer needs no evidence and an ABSENT element has no text to quote, so quoting one is an invention and is counted as a wrong answer rather than an empty one
scope WHOSE submission this is and WHICH CYCLE it covers, read against the inventory row printed above the packet. `this_cycle_this_entity` the packet attests for the entity named on the inventory row and for this cycle. `prior_cycle` a packet was received and it attests to an EARLIER cycle -- a resubmitted prior-year certification, or an attested period ending before this cycle begins. `different_entity` a packet was received and it attests for a DIFFERENT contracted entity: a parent, an affiliate, or a sibling under the same group. `no_submission` no packet at all. A packet existing is NOT evidence that this entity submitted for this cycle, and this field is the one that says so
scope_citation ONE SENTENCE OR ONE HEADER LINE COPIED VERBATIM from the packet -- the text that shows the cycle or the entity it actually covers. Required where scope is `prior_cycle` or `different_entity`. NULL where scope is `this_cycle_this_entity` or `no_submission`
confidence your own number between 0 and 1 for this FDR's readings taken together. It is published as evidence and never used to change an answer
why one sentence naming what decided any element you did not read as `affirmed`, and the cycle and entity the packet actually covers
Four element objects for one packet. No more, no fewer. THERE IS NO STATUS FIELD:
the reconciliation status is derived in code from your reading, the contract
inventory and the screening result on file.