OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE ICIS-AIR: REPORTING MINIMUM DATA REQUIREMENTS – DELEGATED AGENCIES This table is intended to show how the current CAA stationary source compliance and enforcement minimum data requirements (MDRs) will be reported into ICIS-Air. As a result of the modernization from the mainframe to a web-based system there are some changes to how the current MDRs will be reported. In some instances there is a difference between reporting requirements for web entry and electronic data transfer (EDT) in ICIS-Air. An example is an activity identifier. In AFS, this is referred to as the Action Number. In ICIS-Air, agencies that will report using EDT will provide an identifier for each activity reported, agencies that will report via the web will have an identifier generated for them. This difference exists to allow EDT agencies to report an identifier generated by their state or local agency system. Some data elements are only included in the table to highlight data that ICIS-Air will generate in order to make better use of the existing MDR or to make it more exact. For example, ICIS-Air will generate an Air Program Operating Status Start Date to indicate when an Air Program was first applied to the facility and, if the operating status was changed, the date it was changed. Even though the field is not required to be reported, agencies may choose to override the generated value with the actual date to make it more exact. This table reflects ICIS-Air as currently designed. Requests to change the design have been made that will affect how some MDRs are reported. As these changes are implemented, this table will be updated. Examples of changes expected include field name changes and generating values that are currently reported by the user. MDR Level Facility Record Current - AFS Facilities Facility ID Reporting via Web – ICIS-Air Facilities *ICIS-Air Programmatic ID Reporting via EDT – ICIS-Air Facilities *AirFacilityIdentifier Facility Name Street City *Facility Site Name *Address *City (GNIS City Code or City Name) *FacilitySiteName *LocationAddressText *LocationAddressCityCode State County *State >County (generated based on the City) *LocationStateCode >County (generated based on the City) Zip Code NAICS Code or SIC Code Government Ownership *Zip Code *Primary NAICS Code Facility Type of Ownership >LCON (LCON users; generated based on User ID) *LocationZipCode *NAICSPrimaryIndicatorCode FacilityTypeOfOwnershipCode *LCON (LCON users) * System Required - User Provided AS OF JULY 7, 2014 ^ Default Value Generated – User can Override + Conditionally Required Further explanation of specific data fields. The Program ID is 18 alphanumeric characters comprised of the State or Tribe, LCON (where applicable), and 13 characters unique within the reporting agency. A change request has been submitted that will allow users to report a free text city name or a GNIS Feature ID. If the GNIS Feature ID is reported, the city name will be generated. A change request has been submitted. If users report a free text city name, they will be required to report the county. If the GNIS Feature ID is reported, the county will be generated. The LCON field is used to identify a facility under a local control district’s jurisdiction. In AFS, users had to assign an LCON value to the facility in order to identify the agency with jurisdiction. In ICIS-Air, the LCON value will be generated based on the User ID of the person creating the facility. If the User ID is associated with an LCON, any facility created with that User ID will be associated with the LCON. > Value Generated – Cannot be Overridden 1 of 9 OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE Reporting via Web – ICIS-Air ^Portable Source Indicator flag (Defaults to No. User must check box to indicate if it is a Portable Source.) All Applicable FederallyEnforceable Air Program(s) *Air Program +Air Program Description Reporting via EDT – ICIS-Air ^PortableSourceIndicator (Defaults to No. User must submit the tag only to indicate that it is a Portable Source.) All Applicable FederallyEnforceable Air Program(s) *AirProgramCode +OtherProgramDescriptionText *Air Program Operating Status *AirProgramOperatingStatusCode ^Air Program Operating Status Start Date ^AirProgramOperatingStatusStartDa te +Subparts +AirProgramSubpartCode Regulated Pollutant(s) Regulated Pollutant(s) *Pollutant Name or CASN *Delegated Agency Pollutant Classification ^Delegated Agency Pollutant Classification Start Date *AirPollutantsCode *AirPollutantDAClassificationCode ^Status ^AirPollutantStatusIndicator Compliance Status N/A N/A Attainment Status N/A N/A MDR Level Current - AFS + Portable Source Indicator – County Code “777” Facility Programs All Applicable FederallyEnforceable Air Program(s) Air Program Air Program Operating Status Facility Pollutants Subparts for NSPS, NESHAP, MACT Regulated Pollutant(s) by Air Program Pollutant Code or CASN Pollutant Classification * System Required - User Provided AS OF JULY 7, 2014 ^AirPollutantDAClassificationStart Date ^ Default Value Generated – User can Override + Conditionally Required Further explanation of specific data fields. Instead of reporting ‘777’ in the county field to indicate a portable source, users will report a Portable Source flag. A permanent address should be reported for portable sources that corresponds to the owner or the address associated with a permit. If a user chooses to report the “Federally-Enforceable Requirement” air program, they will be required to provide a description (e.g., ECL § 205.3). This is not programmatically required data. This will be generated by ICIS-Air and will default to the date the air program is first added or the date the operating status is changed. It is included in this table because users can optionally choose to override the date prior to saving the record. This is not programmatically required data. This will be generated by ICIS-Air and will default to the date the pollutant is first added or the date its classification is changed. It is included in this table because users can optionally choose to override the date prior to saving the record. This is not programmatically required data. A default value of “active” is generated that users can override. The background process that generates the facility-level classification only accounts for the classification of pollutants with a status of “active.” The alternative to tracking the “status” is to delete the pollutant, which will delete the history. Therefore, there will be no historical record of the pollutant for the facility. This MDR will not be reported in ICIS-Air. But, reporting violations will continue to be required and will be reported on a Case File. This data will be provided through a data exchange with FRS. > Value Generated – Cannot be Overridden 2 of 9 OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE MDR Level CMS Record Current - AFS CMS Facility ID CMS Source Category CMS Minimum Frequency Indicator FCE Record FCEs Facility ID Action Type (Lead Agency/On or Off Site inherent in action type) Date Achieved Air Program(s) Action Number * System Required - User Provided AS OF JULY 7, 2014 Reporting via Web – ICIS-Air CMS >ICIS-Air Programmatic ID (generated based on parent Facility) *CMS Source Category ^CMS Start Date Reporting via EDT – ICIS-Air CMS *AirFacilityIdentifier ^CMS Source Frequency Indicator (if there is a default minimum for selected Source Category) *AirCMSMinimumFrequency *AirCMSSourceCategoryCode ^AirCMSStartDate *CMS Source Frequency Indicator (if there is *not* a default minimum for selected Source Category) FCEs *ICIS-Air Programmatic ID *Compliance Monitoring Activity Type FCEs *AirFacilityIdentifier *ComplianceMonitoringActivityTyp eCode *Compliance Monitoring Type *Lead Agency +Actual End Date *ComplianceInspectionTypeCode *LeadAgencyCode +ComplianceMonitoringDate *Air Programs +Other Air Program *ProgramCode +OtherProgramDescriptionText >Compliance Monitoring Identifier (generated based on *ComplianceMonitoringIdentifier ^ Default Value Generated – User can Override + Conditionally Required Further explanation of specific data fields. Like AFS, the CMS Start Date corresponds to the CMS Source Category Code and Minimum Frequency Indicator combination. When a facility is first added to a CMS plan, the current date will be applied as the CMS Start Date and users may optionally override it. If a facility CMS Source Category Code changes to a category that has a more frequent recommended minimum frequency, the CMS Start Date will change to the date the change is made. Again, users my override this date. The original CMS Start Date will be stored as the CMS Origination Date and cannot be changed. As a result of the structure of ICIS, users must first identify via an Add Link the type of activity they wish to report (e.g., Inspection/Evaluation, Judicial Enforcement); EDT users will include the activity type in their XML submission. The system will save a compliance evaluation record that only has a Planned End Date. This is to facilitate planning per the CMS. But, the programmatic MDR remains the Actual End Date (known as the Date Achieved in AFS). If a user chooses to report the “Federally-Enforceable Requirement” air program, they will be required to provide a description (e.g., ECL § 205.3). Instead of submitting “99999” to generate a value in chronological order for the action number, ICIS-Air will generate the activity identifier automatically when the record is created directly on the web. EDT users > Value Generated – Cannot be Overridden 3 of 9 OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE MDR Level Current - AFS Reporting via Web – ICIS-Air User ID of person adding record). Reporting via EDT – ICIS-Air PCE Record PCEs are an MDR when they are a discovery action for an HPV or are included in a CMS alternative plan. Facility ID Action Type (Lead Agency/On or Off Site inherent in action type) PCEs will continue to be an MDR when they are a discovery action for an HPV or are part of a CMS alternative plan. *ICIS-Air Programmatic ID *Compliance Monitoring Activity Type PCEs will continue to be an MDR when they are a discovery action for an HPV or are part of a CMS alternative plan. *Compliance Monitoring Type *Lead Agency +Actual End Date *ComplianceInspectionTypeCode *LeadAgencyCode +ComplianceMonitoringDate *Air Programs +Other Air Program *ProgramCode +OtherProgramDescriptionText Action Number >Compliance Monitoring Identifier (generated based on User ID of person adding record). *ComplianceMonitoringIdentifier All Investigations State/Tribe/LCON Investigation Conducted Facility ID Action Type (Lead Agency inherent in action type) Delegated Agency Investigation Conducted Delegated Agency Investigation Conducted *ICIS-Air Programmatic ID *Compliance Monitoring Activity Type *AirFacilityIdentifier *ComlianceMonitoringActivityType Code *Compliance Monitoring Type *Lead Agency *ComplianceInspectionTypeCode *LeadAgencyCode Date Achieved Air Program(s) Investigations * System Required - User Provided AS OF JULY 7, 2014 *AirFacilityIdentifier *ComplianceMonitoringActivityTyp eCode ^ Default Value Generated – User can Override + Conditionally Required Further explanation of specific data fields. must provide the identifier, which will better enable tracking activities in ICIS-Air for editing and linking. The identifier provided by EDT users must comprise the same format generated by ICIS-Air for the web users (State + LCON + Program Code + Unique Identifier). As a result of the structure of ICIS, users must first identify via an Add Link the type of activity they wish to report (e.g., Inspection/Evaluation, Judicial Enforcement); EDT users will include the activity type in their XML submission. The system will save a compliance evaluation record that only has a Planned End Date. This is to facilitate planning per the CMS. But, the programmatic MDR remains the Actual End Date (known as the Date Achieved in AFS). If a user chooses to report the “Federally-Enforceable Requirement” air program, they will be required to provide a description (e.g., ECL § 205.3). Instead of submitting “99999” to generate a value in chronological order for the action number, ICIS-Air will generate the activity identifier automatically when the record is created directly on the web. EDT users must provide the identifier, which will better enable tracking activities in ICIS-Air for editing and linking. The identifier provided by EDT users must comprise the same format generated by ICIS-Air for the web users (State + LCON + Program Code + Unique Identifier). As a result of the structure of ICIS, users must first identify via an Add Link the type of activity they wish to report (e.g., Inspection/Evaluation, Judicial Enforcement); EDT users will include the activity type in their XML submission. > Value Generated – Cannot be Overridden 4 of 9 OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE MDR Level Reporting via Web – ICIS-Air Actual End Date (for Investigation Conducted) +Actual Start Date (for Investigation Initiated) +Planned End Date Reporting via EDT – ICIS-Air ComplianceMonitoringDate *Air Programs +Other Air Program *ProgramCode +OtherProgramDescriptionText Action Number >Compliance Monitoring Identifier (generated based on User ID of person adding record). *ComplianceMonitoringIdentifier All Stack Tests Stack Tests Conducted for the Purpose of Determining Compliance *ICIS-Air Programmatic ID *Compliance Monitoring Activity Type Stack Tests Conducted for the Purpose of Determining Compliance *AirFacilityIdentifier *ComplianceMonitoringActivityTyp eCode *Compliance Monitoring Type ^Conducted By *ComplianceInspectionTypeCode +StackTestConductorTypeCode Observed By *Lead Agency +Actual End Date StackTestObservedAgencyTypeCod e *LeadAgencyCode +ComplianceMonitoringDate ^Stack Test Status ^StackTestStatusCode *Air Programs *ProgramCode Current - AFS Date Achieved (for Investigation Conducted) Air Program(s) Stack Tests Facility ID Action Type (Who Conducted/Who Observed, Lead Agency inherent in action type) Date Achieved Test Results (Pass, Fail, Pending) Air Program(s) * System Required - User Provided AS OF JULY 7, 2014 +ComplianceMonitoringStartDate +ComplianceMonitoringPlannedEnd Date ^ Default Value Generated – User can Override + Conditionally Required Further explanation of specific data fields. The MDR for delegated agencies is Investigation Conducted, which corresponds to reporting an Investigation with an Actual End Date (known as the Date Achieved in AFS). Users can optionally report the Actual Start Date to identify when the Investigation was initiated (this is required for EPA). Currently, the design requires either an Actual Start Date or a Planned End Date. The design will be updated to accept an Actual Start Date, Planned End Date, or Actual End Date. But, the MDR remains the Actual End Date. If a user chooses to report the “Federally-Enforceable Requirement” air program, they will be required to provide a description (e.g., ECL § 205.3). Instead of submitting “99999” to generate a value in chronological order for the action number, ICIS-Air will generate the activity identifier automatically when the record is created directly on the web. EDT users must provide the identifier, which will better enable tracking activities in ICIS-Air for editing and linking. The identifier provided by EDT users must comprise the same format generated by ICIS-Air for the web users (State + LCON + Program Code + Unique Identifier). As a result of the structure of ICIS, users must first identify via an Add Link the type of activity they wish to report (e.g., Inspection/Evaluation, Judicial Enforcement); EDT users will include the activity type in their XML submission. Since the majority of stack tests reported for compliance purposes are conducted by the owner/operator, the value will default to owner/operator. If an agency was present during the test to observe its performance, a user must select the agency that observed the test. The system will save a compliance evaluation record that only has a Planned End Date. This is to facilitate planning per the CMS. But, the programmatic MDR remains the Actual End Date (known as the Date Achieved in AFS). ICIS-Air will default the value to pending and the user must update to Pass/Fail when the actual results are known. > Value Generated – Cannot be Overridden 5 of 9 OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE MDR Level TV ACC Due/Received Current - AFS Reporting via Web – ICIS-Air +Other Air Program Reporting via EDT – ICIS-Air +OtherProgramDescriptionText Action Number >Compliance Monitoring Identifier (generated based on User ID of person adding record). *ComplianceMonitoringIdentifier All TV ACCs All TV ACCs All TV ACCs Facility ID Action Type – TV ACC Due/Received (Lead Agency inherent in action type) *ICIS-Air Programmatic ID *Compliance Monitoring Activity Type *AirFacilityIdentifier >ComplianceMonitoringActivityTy peCode *Compliance Monitoring Type >ComplianceInspectionTypeCode *Lead Agency +Planned End Date (Due Date) *LeadAgencyCode +ComplianceMonitoringPlannedEnd Date +ComplianceMonitoringDate Due/Received (Date Scheduled/Date Achieved, Federal Users Only, unless otherwise negotiated) Results Code Air Program(s) Action Number * System Required - User Provided AS OF JULY 7, 2014 +Actual End Date (Date Received) N/A As a result of the structure of ICIS, users must first identify via an Add Link the type of activity they wish to report (e.g., Inspection/Evaluation, Judicial Enforcement); for EDT the Compliance Monitoring Activity Type will be generated based on the XML submission type for TV ACC records. Typically this requirement is negotiated between EPA and the permitting authority where the permitting authority enters the data. However, if EPA is responsible for reporting this data, they may enter the data on behalf of the permitting authority, but it will appear as a state or local agency activity. For EDT the Compliance Monitoring Type will be generated based on the XML submission type for TV ACC records. If a “violation” is determined as a result of late submittal of a TV ACC or discovered during the review of the TV ACC, it will be reported as such using the Case File module. In cases, where an agency chooses to report a result for each TV ACC record in ICIS-Air a User Defined Field (UDF) shall be used. N/A *Air Programs +Other Air Program *ProgramCode +OtherProgramDescriptionText >Compliance Monitoring Identifier (generated based on User ID of person adding record). *ComplianceMonitoringIdentifier ^ Default Value Generated – User can Override Further explanation of specific data fields. If a user chooses to report the “Federally-Enforceable Requirement” air program, they will be required to provide a description (e.g., ECL § 205.3). Instead of submitting “99999” to generate a value in chronological order for the action number, ICIS-Air will generate the activity identifier automatically when the record is created directly on the web. EDT users must provide the identifier, which will better enable tracking activities in ICIS-Air for editing and linking. The identifier provided by EDT users must comprise the same format generated by ICIS-Air for the web users (State + LCON + Program Code + Unique Identifier). + Conditionally Required If a user chooses to report the “Federally-Enforceable Requirement” air program, they will be required to provide a description (e.g., ECL § 205.3). Instead of submitting “99999” to generate a value in chronological order for the action number, ICIS-Air will generate the activity identifier automatically when the record is created directly on the web. EDT users must provide the identifier, which will better enable tracking activities > Value Generated – Cannot be Overridden 6 of 9 OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE MDR Level Current - AFS Reporting via Web – ICIS-Air Reporting via EDT – ICIS-Air TV ACC Review All TV ACCs All TV ACCs All TV ACCs Action Type – TV ACC Review (Lead Agency inherent in action type) Date Achieved (Review action, Lead Agency inherent in action type) Deviations? (Federal Users Only, unless otherwise negotiated) (Yes/No/# of) Notices of Violation Reviewer Agency ReviewerAgencyCode Reviewed on [Date] *TVACCReviewedDate Did Facility Report Deviations? FacilityReportDeviationsIndicator Notification of a Violation Notification of a Violation Facility ID Action Type (Type/Lead Agency inherent in action type) *ICIS-Air Programmatic ID *Enforcement Action Forum *AirFacilityIdentifier >Forum *Enforcement Action Type *Lead Agency Achieved Date *Programs Violated >Enforcement Action Identifier (generated based on User ID of person adding record). *EnforcementActionTypeCode *LeadAgencyCode AchievedDate *ProgramsViolatedCode *AirDAEnforcementActionIdentifer Formal Enforcement Actions Formal Enforcement Actions Formal Enforcement Actions Facility ID Action Type (Type/Lead Agency inherent in action type) *ICIS-Air Programmatic ID *Enforcement Action Forum *AirFacilityIdentifier *Forum Informal Enforcement Actions Date Achieved Air Program Code(s) Action Number Formal Enforcement Actions * System Required - User Provided AS OF JULY 7, 2014 ^ Default Value Generated – User can Override + Conditionally Required Further explanation of specific data fields. in ICIS-Air for editing and linking. The identifier provided by EDT users must comprise the same format generated by ICIS-Air for the web users (State + LCON + Program Code + Unique Identifier). As a result of the structure of ICIS, users must first identify via an Add Link the type of activity they wish to report (e.g., Inspection/Evaluation, Judicial Enforcement); for EDT the forum for Informal Enforcement Actions will be generated based on the XML submission type. Instead of submitting “99999” to generate a value in chronological order for the action number, ICIS-Air will generate the activity identifier automatically when the record is created directly on the web. EDT users must provide the identifier, which will better enable tracking activities in ICIS-Air for editing and linking. The identifier provided by EDT users must comprise the same format generated by ICIS-Air for the web users (State + LCON + Program Code + Unique Identifier). As a result of the structure of ICIS, users must first identify via an Add Link the type of activity they wish to report (e.g., Inspection/Evaluation, Judicial Enforcement); EDT users will include the activity type in their XML submission. > Value Generated – Cannot be Overridden 7 of 9 OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE MDR Level Reporting via Web – ICIS-Air *Enforcement Action Type Reporting via EDT – ICIS-Air *EnforcementActionTypeCode *Lead Agency *LeadAgencyCode Milestones: Referral Date (Judicial Actions Only) – Actual Date *Programs Violated >Enforcement Action Identifier (generated based on User ID of person adding record). MilestoneActualDate (Judicial Actions Only) Formal Enforcement Actions Action Number Final Orders Final Orders >Final Order ID *FinalOrderIdentifier Facility ID Action Type (Type/Lead Agency inherent in action type) Date Achieved *ICIS-Air Programmatic ID *Final Order Type *FinalOrderAirFacilityIdentifier *Final Order Type Code +Final Order Issued Date (Admin) +FinalOrderIssuedEnteredDate Current - AFS Air Program(s) Action Number Final Order Resolving Action (and Date Achieved) Cash Assessed Penalty Compliance Status Instead of submitting “99999” to generate a value in chronological order for the action number, ICIS-Air will generate the activity identifier automatically when the record is created directly on the web. EDT users must provide the identifier, which will better enable tracking activities in ICIS-Air for editing and linking. The identifier provided by EDT users must comprise the same format generated by ICIS-Air for the web users (State + LCON + Program Code + Unique Identifier). Instead of submitting “99999” to generate a value in chronological order for the action number, ICIS-Air will generate the Final Order identifier automatically when the record is saved. EDT users must provide the identifier. This will enable tracking activities in ICIS-Air using an identifier generated by the state or local agency data system. This will facilitate linking and editing activities. AirResolvedDate Compliance Status Violation Tracking CashCivilPenaltyRequiredAmount (populates Penalty Assessed to be Paid To: State/Local Agency) Violation Tracking Facility ID *ICIS-Air Programmatic ID *AirFacilityIdentifier * System Required - User Provided AS OF JULY 7, 2014 Final Order Entered Date (Judicial) Air Resolved Date (HPV Resolving Action only) Penalty Assessed to be Paid To: *ProgamsViolatedCode *AirDAEnforcementActionIdentifie r Further explanation of specific data fields. In order to report a Final Order (e.g., Administrative Compliance Order) users must first create the Enforcement Action Type (e.g., Administrative Order). ^ Default Value Generated – User can Override + Conditionally Required A penalty will be required for some enforcement action types. Violation data will be reported using the Case File module. Underlying data reported on the Violation sub link will roll-up to the Case File (e.g., HPV). > Value Generated – Cannot be Overridden 8 of 9 OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE MDR Level Reporting via Web – ICIS-Air *Programs +Program Description Reporting via EDT – ICIS-Air *ProgramCode +OtherProgramDescriptionText Pollutants ^Lead Agency >Case File Identifier (generated based on User ID of person adding record). AirPollutantCode ^LeadAgencyCode *CaseFileIdentifier Violation Tracking *Violation Type Violation Tracking *AirViolationTypeCode *Air Program *AirViolationProgramCode Date Achieved +Pollutant +HPV Day Zero Date Method of Advisement (aka notification of violation) Date of Advisement +AirViolationPollutantCode +HPVDayZeroDate AdvisementMethodTypeCode (aka notification of violation) AdvisementMethodDate HPV Action Linking HPV Action Linking HPV Action Linking Discovery Action Addressing Action Resolving Action Discovery Action/Date Addressing Action/Date Resolving Action/Date +OtherPathwayCategoryCode Current - AFS Air Program Pollutant Violation Details Compliance Status Air Program Pollutant Compliance Status (FRV)/HPV Day Zero/HPV Violation Type Code/HPV Violating Pollutant Date Achieved (Day Zero) Informal Enforcement HPV Action Linking Further explanation of specific data fields. If a user chooses to report the “Federally-Enforceable Requirement” air program, they will be required to provide a description (e.g., ECL § 205.3). FRVs will no longer be reported as the compliance status of an air program pollutant. In ICIS-Air, FRVs and HPVs are reported on a Case File, which is treated similar to other activities in ICIS-Air. The concept is similar to reporting a key action in AFS. Each Case File will be assigned an identifier, similar to an action number on a key action in AFS. But, instead of submitting “99999” to generate a number, ICISAir will generate the activity identifier automatically when the record is saved. EDT users must provide the identifier. This will enable tracking activities in ICIS-Air using an identifier generated by the state or local agency data system. This will facilitate editing activities. A unique identifier will also assist with linking for HPVs. This data will be enforcement sensitive. In ICIS-Air the list of violation types is more descriptive than the options used to report violations in AFS. Instead of reporting “InViolation with regard to procedural compliance” users will report, for example, “Failure to maintain records as required by permit or regulation.” If a user chooses to report the “Federally-Enforceable Requirement” air program, they will be required to provide a description (e.g., ECL § 205.3). This field meets the requirement to report when notice was provide to the regulated entity. This corresponds to the date when the facility was initially advised of any potential violation. +OtherPathwayTypeCode +OtherPathwayDate * System Required - User Provided AS OF JULY 7, 2014 ^ Default Value Generated – User can Override + Conditionally Required > Value Generated – Cannot be Overridden 9 of 9