oversight

Audit of the Federal Employees Health Benefits Program Operations at Physicians Health Plan of Northern Indiana

Published by the Office of Personnel Management, Office of Inspector General on 2015-06-03.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

         U.S. OFFICE OF PERSONNEL MANAGEMENT
            OFFICE OF THE INSPECTOR GENERAL
                     OFFICE OF AUDITS




            Final Audit Report

         AUDIT OF THE FEDERAL EMPLOYEES HEALTH
             BENEFITS PROGRAM OPERATIONS AT
       PHYSICIANS HEALTH PLAN OF NORTHERN INDIANA

                                          Report Number 1C-DQ-00-14-051
                                                   June 3, 2015




                                                             -- CAUTION --
This audit report has been distributed to Federal officials who are responsible for the administration of the audited program. This audit report may
contain proprietary data which is protected by Federal law (18 U.S.C. 1905). Therefore, while this audit report is available under the Freedom of
Information Act and made available to the public on the OIG webpage (http://www.opm.gov/our-inspector-general), caution needs to be exercised
before releasing the report to the general public as it may contain proprietary information that was redacted from the publicly distributed copy.
            EXECUTIVE SUMMARY 

              Audit of the Federal Employees Health Benefits Program Operations at                            

                            Physicians Health Plan of Northern Indiana 

 Report No. 1C-DQ-00-14-051                                                                           June 3, 2015

Why Did We Conduct the Audit?              What Did We Find?

The primary objectives of the audit        This report questions $89,759 for inappropriate health benefit
were to determine if Physicians            charges to the FEHBP in contract year 2011. The questioned
Health Plan of Northern Indiana            amount includes $83,505 for defective pricing and $6,254 due the
(Plan) developed the Federal               FEHBP for lost investment income, calculated through April 30,
Employees Health Benefits Program          2015.
(FEHBP) premium rates using
complete, accurate and current data,       In contract years 2008 through 2012, we found that the Plan did
and that the rates are equivalent to the   not consistently account for benefit changes in the experience
Plan’s Similarly Sized Subscriber          period for the SSSGs and the FEHBP. However, after developing
Groups (SSSGs), as provided in             our audited FEHBP rates using the SSSGs’ benefit change
Federal Employees Health Benefits          methodology, we determined there was no material cost impact to
Acquisition Regulation 1652.215-           the FEHBP in all contract years, with the exception of contract
70(a). Additional tests were               year 2011.
performed to determine whether the
Plan was in compliance with the
provisions of the laws and regulations
governing the FEHBP.

What Did We Audit?

Under contract 2648, the Office of the
Inspector General completed a
performance audit of the FEHBP’s
rates offered for contract years 2008
through 2012. Our audit fieldwork
was conducted from July 21, 2014
through August 1, 2014 at the Plan’s
office in Fort Wayne, Indiana.




_______________________
Michael R. Esser
Assistant Inspector General
for Audits
                                                        i
                ABBREVIATIONS


ACR      Adjusted Community Rating
CRC      Community Rating by Class
FEHBAR   Federal Employees Health Benefits Acquisition Regulations
FEHBP    Federal Employees Health Benefits Program
OIG      Office of the Inspector General
OPM      U.S. Office of Personnel Management
Plan     Physicians Health Plan of Northern Indiana
SSSG     Similarly Sized Subscriber Group
U.S.C.   United States Code




                               ii
IV. MAJOR CONTRIBUTORS  TO THIS REPORT
          TABLE OF CONTENTS

                                                                                                                              Page 

        EXECUTIVE SUMMARY ......................................................................................... i 


        ABBREVIATIONS ..................................................................................................... ii 


I.	     BACKGROUND ..........................................................................................................1 


II.	    OBJECTIVES, SCOPE, AND METHODOLOGY ..................................................3 


III.	   AUDIT FINDINGS AND RECOMMENDATIONS.................................................5


        Premium Rate Review ...................................................................................................5 


        1. Defective Pricing .....................................................................................................5 


        2. Lost Investment Income ...........................................................................................7 


        3. Inconsistent Rating Methodology ............................................................................8 


IV.	    MAJOR CONTRIBUTORS TO THIS REPORT ....................................................9 


        Exhibit A (Summary of Questioned Costs) .................................................................10 


        Exhibit B (Defective Pricing Questioned Costs) .........................................................11 


        Exhibit C (Lost Investment Income)............................................................................12 


        Appendix (Physicians Health Plan of Northern Indiana’s January 21, 2015, response 

        to the draft report) .......................................................................................................13


        REPORT FRAUD, WASTE, AND MISMANAGEMENT ....................................16 

 IV. MAJOR CONTRIBUTORS
            I. BACKGROUND
                        TO THIS REPORT
This final report details the audit results of the Federal Employees Health Benefits Program
(FEHBP) operations at Physicians Health Plan of Northern Indiana (Plan). The audit covered
contract years 2008 through 2012, and was conducted at the Plan’s office in Fort Wayne,
Indiana.

The audit was conducted pursuant to FEHBP contract CS 2648; 5 United States Code (U.S.C.)
Chapter 89; and 5 Code of Federal Regulations Chapter 1, Part 890. The audit was performed by
the U.S. Office of Personnel Management’s (OPM) Office of the Inspector General (OIG), as
established by the Inspector General Act of 1978, as amended.

The FEHBP was established by the Federal Employees Health Benefits Act (Public Law 86-
382), enacted on September 28, 1959. The FEHBP was created to provide health insurance
benefits for federal employees, annuitants, and dependents. The FEHBP is administered by
OPM’s Healthcare and Insurance Office. Health insurance coverage is provided through
contracts with health insurance carriers who provide service benefits, indemnity benefits, or
comprehensive medical services.

Community-rated carriers participating in the FEHBP are subject to various federal, state and
local laws, regulations, and ordinances. While most carriers are subject to state jurisdiction,
many are further subject to the Health Maintenance Organization Act of 1973 (Public Law 93-
222), as amended (i.e., many community-rated carriers are federally qualified). In addition,
participation in the FEHBP subjects the carriers to the Federal Employees Health Benefits Act
and implementing regulations promulgated by OPM.
                                                                FEHBP Contracts/Members
The FEHBP should pay a premium rate                                    March 31

that is equivalent to the best rate given to            500
either of the two groups closest in size to             450
the FEHBP. In contracting with                          400
community-rated carriers, OPM relies on                 350

carrier compliance with appropriate laws                300

and regulations and, consequently, does                 250
                                                        200
not negotiate base rates. OPM
                                                        150
negotiations relate primarily to the level of
                                                        100
coverage and other unique features of the                50
FEHBP.                                                    0
                                                                2008    2009    2010      2011   2012
                                                    Contracts    239     199     201       196    187
The chart to the right shows the number of        Members        476     389     406      408    394
FEHBP contracts and members reported
by the Plan as of March 31 for each contract year audited.


                                                1                               Report No. 1C-DQ-00-14-051
The Plan has participated in the FEHBP since 1993 and provides health benefits to FEHBP
members in Northeast Indiana. The last audit conducted by our office was a performance audit
and covered contract years 2002 through 2005. The audit identified several errors including an
incorrect rate adjustment factor, speech therapy loading, morbid obesity loading, and a Similarly
Sized Subscriber Group (SSSG) discount that was not applied to the FEHBP rates. All audit
issues from that audit have been resolved.

The preliminary results of this audit were discussed with Plan officials at an exit conference and
in subsequent correspondence. A draft report was also provided to the Plan for review and
comment. The Plan’s comments were considered in preparation of this report and are included,
as appropriate, as the Appendix to the report.




                                                 2                          Report No. 1C-DQ-00-14-051
 IV. MAJOR CONTRIBUTORS
 II. OBJECTIVES, SCOPE, AND TO THIS REPORT
                            METHODOLOGY
Objectives
The primary objectives of the audit were to determine if the FEHBP premium rates are
developed using complete, accurate and current data, and are equivalent to the Plan’s SSSGs, as
provided in Federal Employees Health Benefits Acquisition Regulation (FEHBAR) 1652.215-
70(a). Additional tests were performed to determine whether the Plan was in compliance with
the provisions of the laws and regulations governing the FEHBP.

Scope
We conducted this performance audit in
                                                                      FEHBP Premiums Paid to Plan
accordance with generally accepted government
auditing standards. Those standards require that
                                                                   $2.5
we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis                 $2.0


                                                      Millions
for our findings and conclusions based on our                      $1.5
audit objectives. We believe that the evidence                     $1.0
obtained provides a reasonable basis for our
                                                                   $0.5
findings and conclusions based on our audit
                                                                   $0.0
objectives.                                                                2008   2009   2010   2011   2012
                                                                 Revenue   $2.1   $2.0   $2.0   $2.2   $2.3

This performance audit covered contract years
2008 through 2012. For these years, the FEHBP
paid approximately $10.6 million in premiums to
the Plan.

OIG audits of community-rated carriers are designed to test carrier compliance with the FEHBP
contract, applicable laws and regulations, and the Rate Instructions to Community-Rated Carriers
(rate instructions). These audits are also designed to provide reasonable assurance of detecting
errors, irregularities, and illegal acts.

We obtained an understanding of the Plan’s internal control structure, but we did not use this
information to determine the nature, timing, and extent of our audit procedures. However, the
audit included such tests of the Plan’s rating system and such other auditing procedures
considered necessary under the circumstances. Our review of internal controls was limited to the
procedures the Plan has in place to ensure that:

        The appropriate SSSGs were selected;

        the rates charged to the FEHBP were developed using complete, accurate and current
         data, and equivalent to the best rate given to the SSSGs; and

                                                3                                   Report No. 1C-DQ-00-14-051
        the loadings to the FEHBP rates were reasonable and equitable.

In conducting the audit, we relied to varying degrees on computer-generated billing, enrollment,
and claims data provided by the Plan. We did not verify the reliability of the data generated by
the various information systems involved. However, nothing came to our attention during our
audit testing utilizing the computer-generated data to cause us to doubt its reliability. We believe
that the available data was sufficient to achieve our audit objectives. Except as noted above, the
audit was conducted in accordance with generally accepted government auditing standards,
issued by the Comptroller General of the United States.

The audit fieldwork was performed from July 21, 2014 through August 1, 2014 at the Plan’s
office in Fort Wayne, Indiana.

Methodology
We examined the Plan’s federal rate submission and related documents as a basis for validating
its Certificates of Accurate Pricing. In addition, we examined the rate development
documentation and billings to other groups, such as the SSSGs, to determine if the FEHBP rates
were reasonable and equitable. Finally, we used the contract, the FEHBAR, and the rate
instructions to determine the propriety of the FEHBP premiums and the reasonableness and
acceptability of the Plan’s rating system.

To gain an understanding of the internal controls in the Plan’s rating system, we reviewed the
Plan’s rating system policies and procedures, interviewed appropriate Plan officials, and
performed other auditing procedures necessary to meet our audit objectives.




                                                 4                          Report No. 1C-DQ-00-14-051
III. AUDIT FINDINGS AND RECOMMENDATIONS
Premium Rate Review

1. Defective Pricing                                                                     $83,505

  The Certificate of Accurate Pricing the Plan signed for contract year 2011 was defective. In
  accordance with federal regulations, the FEHBP is therefore due a rate reduction for this year.
  Application of the defective pricing remedy shows that the FEHBP is due a premium
  adjustment of $83,505 (see Exhibit A). While rating discrepancies were also identified in
  contract years 2008 through 2010, and 2012, we found that there was no material cost impact
  to the FEHBP rates in these years.

                              FEHBAR 1652.215-70 provides that carriers proposing rates to
    The FEHBP is due
                              OPM are required to submit a Certificate of Accurate Pricing
    a rate reduction of
                              certifying that the proposed subscription rates are complete,
        $83,505 for
                              accurate and current. Furthermore, FEHBAR 1652.216-70 states
    defective pricing in
                              that the subscription rates agreed to in the contract shall be
    contract year 2011.
                              equivalent to the subscription rates given to the community-rated
                              carrier’s SSSGs as defined in FEHBAR 1602.170-13. SSSGs are
  the Plan’s two employer groups closest in subscriber size to the FEHBP. If it is found that the
  FEHBP rates were increased because of defective pricing or defective cost or pricing data,
  then the rates shall be reduced in the amount by which the price was increased because of the
  defective data or information.

  2011

  We agree with the Plan’s selection of                        and                     as
  SSSGs for contract year 2011. The FEHBP and the SSSGs were rated using a blended
  Adjusted Community Rating (ACR) and Community Rating by Class (CRC) methodology.
  We found that the Plan discounted the proposed 2011 FEHBP rates. However, our analysis
  of the rates charged to the SSSGs shows that                       did not receive a
  discount and                      receiving a    percent discount.

  The Plan used a       industry factor to adjust the community rates for                      .
  The Plan used a       factor for the FEHBP. Per the 2011 rate instructions, the industry factor
  used for the Federal group must be 1.0 or less. The Federal group industry factor must also be
  no larger than the lowest industry factor used for an SSSG. As a result, we changed
                industry factor to      and held the FEHBP industry factor to      , since the
  factor only impacted a portion of the calculated rate. The change in industry factor resulted in



                                            5                             Report No. 1C-DQ-00-14-051
                      discount increasing from      percent to percent. In addition, we
removed the 2010 medical adjustment applied to the FEHBP's rates. It is the Plan's practice
not to adjust for changes within the experience period.

We then applied the largest SSSG discount of         percent to our audited rates. A
comparison of our audited line 5 rates to the Plan’s reconciled line 5 rates shows that the
FEHBP was overcharged $83,505 (see Exhibit B).

Plan’s Comments (see Appendix):

                    Industry Factor
The Plan agrees that the FEHBP was overcharged, but believes the          industry factor
should be applied to the FEHBP rate development, instead of the
industry factor being increased to . The Plan believes that                          rates were
discounted by       percent due to this error, resulting in a premium adjustment of $53,820 to
the FEHBP

2010 Medical Adjustment Removal
The Plan did not address this issue.

OIG’s Response to the Plan’s Comments:

                    Industry Factor
OIG disagrees with this approach. Although the rate instructions state the FEHBP should
receive the lowest factor, the intent of the rate instructions is for the FEHBP to be rated fairly.
Because both groups use a blended ACR and CRC methodology, the FEHBP would not
receive the same equivalent rate advantage that was given to the SSSG. This is due to the
SSSG receiving a percent reduction on percent of the rates, whereas the FEHBP would
only receive the percent reduction on percent of the rates. If the SSSG’s industry factor
is moved to    , both the SSSG and FEHBP receive an equivalent rate advantage.

Recommendation 1

We recommend that the contracting officer require the Plan to return $83,505 to the FEHBP
for defective pricing in contract year 2011.




                                               6                           Report No. 1C-DQ-00-14-051
2. Lost Investment Income                                                                 $6,254

  In accordance with FEHBP regulations and the contract between OPM and the Plan, the
  FEHBP is entitled to recover lost investment income on the defective pricing findings in
  contract year 2011. We determined the FEHBP is due $6,254 for lost investment income,
  calculated through April 30, 2015 (see Exhibit C). In addition, the FEHBP is entitled to lost
  investment income for the period beginning May 1, 2015, until all defective pricing amounts
  have been returned to the FEHBP.
                                                                             The FEHBP is due
                                                                                lost investment
  FEHBAR 1652.215-70 provides that, if any rate established in
                                                                                 income on the
  connection with the FEHBP contract was increased because the
                                                                               defective pricing
  carrier furnished cost or pricing data that was not complete, accurate,
                                                                                 finding in the
  or current as certified in its Certificate of Accurate Pricing, the rate
                                                                              amount of $6,254.
  shall be reduced by the amount of the overcharge caused by the
  defective data. In addition, when the rates are reduced due to defective pricing, the
  regulation states that the government is entitled to a refund and simple interest on the amount
  of the overcharge from the date the overcharge was paid to the carrier until the overcharge is
  liquidated.

  Our calculation of lost investment income is based on the United States Department of the
  Treasury’s semiannual cost of capital rates.

  Plan’s Comments (see Appendix):

  The Plan agrees that lost investment income should be charged; however, it does not agree
  with the amount questioned. The Plan’s lost investment income amount is based on its
  revised FEHBP overcharge calculation.

  OIG’s Response to the Plan’s Comments:

  We maintain that lost investment income is due the FEHBP in the amount of $6,254, 

  calculated through April 30, 2015. 


  Recommendation 2

  We recommend that the contracting officer require the Plan to return $6,254 to the FEHBP
  for lost investment income, calculated through April 30, 2015. We also recommend that the
  contracting officer recover lost investment income on amounts due for the period beginning
  May 1, 2015, until all defective pricing amounts have been returned to the FEHBP.




                                               7                          Report No. 1C-DQ-00-14-051
3. Inconsistent Rating Methodology

   In contract years 2008 through 2012, we found that the Plan did not have adequate rating
   system controls to ensure that the FEHBP and groups closest in size are rated consistently.
   We determined the Plan was not adjusting claims experience for experience period benefit
   changes for the SSSGs, although the adjustment was applied to the FEHBP for all years
   under review. Failure to correct this issue may result in the potential for future inaccurate
   and inconsistent calculations, and reporting of OPM’s new medical loss ratio methodology
   requirements.

   Plan’s Comments (see Appendix):

   The Plan did not address this issue in its response.

   Recommendation 3

   We recommend that the contracting officer require the Plan to correct this internal control
   weakness related to its rating system or implement mitigating controls to minimize the
   inconsistency in its rating methodology.




                                                 8                         Report No. 1C-DQ-00-14-051
  IV. MAJOR CONTRIBUTORS TO THIS REPORT

COMMUNITY-RATED AUDITS GROUP

         , Auditor-in-Charge

        , Auditor

        , Auditor

                     , Auditor


           , Senior Team Leader

           , Chief




                                  9   Report No. 1C-DQ-00-14-051
                                     EXHIBIT A




                   Physicians Health Plan of Northern Indiana
                         Summary of Questioned Costs



Defective Pricing Questioned Costs


     Contract Year 2011                                $83,505


     Total Defective Pricing Questioned Costs                         $83,505


Lost Investment Income                                                  $6,254


Total Questioned Costs                                                $89,759




                                            10             Report No. 1C-DQ-00-14-051
                                   EXHIBIT B




                     Physicians Health Plan of Northern Indiana
                         Defective Pricing Questioned Costs


Contract Year 2011
                                                    Self   Family
FEHBP Line 5 - Reconciled Rate                  $          $
FEHBP Line 5 - Audited Rate                     $          $

Bi-weekly Overcharge                            $          $

To Annualize Overcharge:
   March 31, 2011 Enrollment
   Pay Periods                                      26         26
Subtotal                                        $          $                  $83,505

Total Defective Pricing Questioned Costs                                      $83,505




                                           11                       Report No. 1C-DQ-00-14-051
                                   EXHIBIT C




                       Physicians Health Plan of Northern Indiana 

                                Lost Investment Income 



                                                                          30-Apr-
  Year                            2011      2012      2013      2014         15      Total
Audit Findings:

1. Defective Pricing             $83,505     $0        $0        $0          $0     $83,505



           Totals (per year):    $83,505     $0        $0        $0         $0      $83,505
          Cumulative Totals:     $83,505   $83,505   $83,505   $83,505    $83,505   $83,505

Avg. Interest Rate (per year):   2.5625% 1.8750% 1.5625% 2.0625% 2.1250%

      Interest on Prior Years
                    Findings:      $0      $1,566    $1,305    $1,722       $591    $5,184

      Current Years Interest:    $1,070      $0        $0        $0          $0     $1,070

   Total Cumulative Interest
         Calculated Through
             April 30, 2015:     $1,070    $1,566    $1,305    $1,722       $591    $6,254




                                            12                         Report No. 1C-DQ-00-14-051
                                   APPENDIX

                                                                         January 21, 2015


                      

Chief, Community-Rated Audits Group 

U.S. Office of Personnel Management
Office of the Inspector General
800 Cranberry Woods Drive
Suite 270
Cranberry Township, Pennsylvania 16066

Dear          :

This letter and the accompanying attachments are in response to the draft report received
by Physicians Health Plan of Northern Indiana, Inc. on November 24, 2014. The draft
report was for an audit performed in July of 2014, and covered contract years 2008
through 2012.

Of the five years reviewed in this audit, only one year was found to have defective
pricing which resulted in an inappropriate charge to the FEHBP. For contract years 2008,
2009, 2010 and 2012, the report found that the rates charged for those contract years were
appropriate. For these four years, we agree with the findings of this draft report and will
consider each of these contract years closed.

For contract year 2011, the draft report determined that the FEHBP was overcharged by
$85,673. This discrepancy in pricing was caused by an industry factor of         applied
during the calculation of the community rate for one of our SSSGs,                       .
During that same year, we used an industry factor of       for the FEHB. Per the 2011
Rate Instructions to community rated carriers, the industry factor used for the Federal
group must be 1.0 or less. The Federal group industry factor must be no larger than the
lowest industry factor used for an SSSG and must be no larger than 1.0. We agree that a
mistake was made in pricing 2011, which resulted in the FEHBP being overcharged.

The audit report corrects for this error by increasing the industry factor to    for the
SSSG (                       ) to match the factor used in pricing the FEHBP. However,
this change does not follow underwriting guidelines in use by Physicians Health Plan in
2011.                        had an SIC Code of         (                                ). I
have attached to this report (on the CD) a listing of all industry factors used by Physicians
Health Plan during 2011. The industry factor for           is     and is highlighted.

Rather than increase the factor to   for both the SSSG and the FEHBP, we believe the
2011 Rate Instructions would call for the industry factor for the FEHBP to be lowered to



                                             13                          Report No. 1C-DQ-00-14-051
the lowest appropriate factor for the SSSGs. In this case we would lower the factor for
the FEHBP to       .

I have attached a spreadsheet used by the auditors to develop Audited Rates for
                The tab labeled “BWB” includes PHP’s underwriting formula for
              . In cell I33, I have set the Industry Factor to    (matching the original
underwriting). I have also turned this factor “red” to make it easily identifiable. This is
the only change made to the auditor’s spreadsheet. Changing this factor lowers the
Audited Rates found on the Summary tab. It also recalculates the discount provided to
                      and lowers it to       %.

I have also attached a spreadsheet used by the auditors to develop Audited Rates for the
FEHBP. On the first tab titled “Lead Schedule”, the Audited Rates from each of the
SSSGs are input items. I have copied the new Audited Rates from the
       spreadsheet into this spreadsheet. Again, I have turned the rates “red” to indicate
a change in the spreadsheet.

The “FEHBP” tab includes PHP’s underwriting formula for the OPM group. In cell I36,
I have set the Industry Factor to    (which is a correction of the       factor used in the
original underwriting). We believe this correction is in compliance with the 2011 Rate
Instructions. Again, I have changed this factor to “red” to indicate a change from the
auditor’s calculation.

Deleted by OIG-Not Relevant to Final ReportD.

The tab labeled “Exhibit A” details the difference between the original plan pricing for
the FEHBP and the auditor’s pricing. Including the revised Industry Factor of        for
FEHBP Deleted by OIG-Not Relevant to Final ReportD results in an overcharge for
the FEHBP of $53,820. Physicians Health Plan agrees with this amount and is prepared
to reimburse the FEHBP as soon as possible.

The Lost Investment Income calculated by the OIG auditor was $5,810 as of December
31, 2014. This amount was calculated based upon the original assumed overcharge of
$85,673. We would respectfully ask that this Investment Income amount be recalculated
using the revised overcharge amount of $53,820 and extended to the expected date of
final payment.

Physicians Health Plan deeply regrets the pricing error committed in the 2011 contract year
and wants to make full restitutions as soon as possible. If you have any questions about the
information provided or would like to discuss the report in person, feel free to contact me at
                or by email at          @PHPNI.com. I look forward to reviewing your
response and the final audit report.

Sincerely,




                                             14                          Report No. 1C-DQ-00-14-051
Director of Actuarial & Analytical Services




                                              15   Report No. 1C-DQ-00-14-051
                                                                             



               Report Fraud, Waste, and 

                   Mismanagement 

                        Fraud, waste, and mismanagement in
                     Government concerns everyone: Office of
                         the Inspector General staff, agency
                      employees, and the general public. We
                    actively solicit allegations of any inefficient
                          and wasteful practices, fraud, and
                     mismanagement related to OPM programs
                    and operations. You can report allegations
                                to us in several ways:


     By Internet:        http://www.opm.gov/our-inspector-general/hotline-to-
                         report-fraud-waste-or-abuse


      By Phone:          Toll Free Number:                  (877) 499-7295
                         Washington Metro Area:             (202) 606-2423


        By Mail:         Office of the Inspector General
                         U.S. Office of Personnel Management
                         1900 E Street, NW
                         Room 6400
                         Washington, DC 20415-1100
  
                                                                             
                                                                             




                                        16                             Report No. 1C-DQ-00-14-051