From c620e60e809ff861b031f9465deda885864bb60c Mon Sep 17 00:00:00 2001
From: kert <kert@rack.localdomain>
Date: Thu, 12 Nov 2026 11:48:05 -0500
Subject: [PATCH] =?UTF-8?q?fix(pfs):=20cms-summaries=20=E2=80=94=20drop=20?=
 =?UTF-8?q?the=20not-believe-finalizing=20cue,=20narrow=20'inappropriate',?=
 =?UTF-8?q?=20sentence-bounded=20windows,=20action=20verbs=20break=20pure?=
 =?UTF-8?q?=20thanks?=
MIME-Version: 1.0
Content-Type: text/plain; charset=UTF-8
Content-Transfer-Encoding: 8bit

---
 src/pfs/cms_summaries.py                 | 17 ++++++++------
 tests/pfs/fixtures/fr_comment_pairs.json |  5 +++-
 tests/pfs/test_cms_summaries.py          | 30 +++++++++++++++++++++---
 3 files changed, 41 insertions(+), 11 deletions(-)

diff --git a/src/pfs/cms_summaries.py b/src/pfs/cms_summaries.py
index ec651e1..36f1e01 100644
--- a/src/pfs/cms_summaries.py
+++ b/src/pfs/cms_summaries.py
@@ -54,14 +54,14 @@ _ACTIONS = (
     (
         "finalize_as_proposed",
         re.compile(
-            r"(?<!not )\bfinaliz\w+[^.]{0,120}as proposed|\bcontinue to believe\b|\bmaintain\b",
+            r"(?<!not )\bfinaliz\w+[^.]*as proposed|\bcontinue to believe\b|\bmaintain\b",
             re.I,
         ),
     ),
     (
         "finalize_modified",
         re.compile(
-            r"\bfinaliz\w+[^.]{0,120}(?:with (?:a )?modification|\brevis)"
+            r"\bfinaliz\w+[^.]*(?:with (?:a )?modification|\brevis)"
             r"|\bwe have assigned\b|\bwe are assigning\b",
             re.I,
         ),
@@ -72,17 +72,20 @@ _ACTIONS = (
             r"\bnot (?:to )?finaliz|\bare not adopting\b|\bdecline"
             # R45, from the live responses: a plain refusal
             r"|\bdo not have (?:the )?(?:legislative )?authority\b"
-            r"|\bit would be inappropriate to (?:finalize|adopt|pay|establish|apply|implement)\b"
-            r"|\bdo not believe\b[^.]{0,100}\bare warranted\b"
-            # R46: "we do not believe that finalizing ..." refuses to finalize
-            r"|\bnot (?:believe|think)\b[^.]{0,60}\bfinaliz",
+            r"|\bwe believe (?:that )?it would be inappropriate to\b"
+            r"|\bdo not believe\b[^.]{0,100}\bare warranted\b",
             re.I,
         ),
     ),
 )
 
 _THANKS = re.compile(r"\bthank|\bappreciat", re.I)
-_CONTRAST = re.compile(r"\b(?:but|however|although|while|though)\b", re.I)
+# a thanks sentence that also acts or contrasts is not pure thanks (R48)
+_CONTRAST = re.compile(
+    r"\b(?:but|however|although|while|though)\b"
+    r"|\bfinaliz|\badopt|\brevis|\bclarif|\badding\b|\bagree\b",
+    re.I,
+)
 _SENTENCES = re.compile(r"(?<=[.!?])\s+")
 
 
diff --git a/tests/pfs/fixtures/fr_comment_pairs.json b/tests/pfs/fixtures/fr_comment_pairs.json
index 4c8553f..de7f603 100644
--- a/tests/pfs/fixtures/fr_comment_pairs.json
+++ b/tests/pfs/fixtures/fr_comment_pairs.json
@@ -26,5 +26,8 @@
  "YYAWUFQX:1476": "Response: We agree that the second criterion could be clarified, to state that it would be inappropriate to have collected the specimen other than during the procedure, and have done so in this final rule. Our intent in establishing this criterion was to ensure that tests that meet the definitions in this provision are not directly related to the care provided in the hospital, and we believe the modification we are finalizing meets that intent more clearly than our original proposal.",
  "X-PETM225D:3620": "Comment: A few comments provided general support of our proposal to make conforming changes to omit the reference to “for claims identified by place of service modifier 12” from the description for CPT codes 99341 through 99350. One commenter indicated strong support because these coding changes will help bring transparency to the services provided in ( printed page 69825) those settings. These commenters believe that under current coding and billing conventions, “home” services are all lumped together and thus difficult to untangle and analyze productively.",
  "X-PETM225D:406": "Response: We appreciate the perspective of interested parties, but we would need code-level PE details to evaluate potential code valuation issues.",
- "X-YBM4IZUS:429": "Response: We thank the commenters for their support and feedback."
+ "X-YBM4IZUS:429": "Response: We thank the commenters for their support and feedback.",
+ "WHNGCYHB:3310": "Response: To streamline the process, we proposed to have a single process with a single audit step, regardless of the reason an ACO is selected for the audit. The proposals were intended to streamline the audit process, provide audit feedback to ACOs and validate the accuracy of quality data in a timely manner that, in turn, permits timely feedback and allows accurate information to be used in the reconciliation of the ACO's performance for the prior year. Incorporating an appeals process would severely delay ACO reconciliation, and therefore, we do not agree that such a process should be included. Additionally, we believe that establishing an appeals process would be inconsistent with the statutory preclusion on administrative and judicial review of the assessment of the quality of care furnished by the ACO under section 1899(g) of the Act. Nevertheless, we are sympathetic to comments noting that simple mistakes can be made when reporting quality that, if given the opportunity to be rectified, would not reflect poorly on the actual quality of the care delivered by the ACO. We note, however, that the CMS web interface provides a number of reports that ACOs can access and use to check their data entry in the CMS Web Interface to assist ACOs in monitoring the accuracy of the quality data they submit. These reports can help ACOs to identify and correct errors in their data submission during the timeframe the CMS Web Interface is open for quality data submission. Even so, we believe there may be instances following an audit when CMS may need to employ some discretion related to the adjustment of an ACO's overall quality score. For example, an ACO may have experienced an error when reporting measures electronically (for example, an error in mapping the extensible markup language (XML) specifications) that affects all beneficiaries reported on for a quality measure. In this instance, a mapping error could be out of the control of the ACO that, based on an audit, demonstrated that it had otherwise fulfilled our quality reporting requirements. In the absence of flexibility not to apply an adjustment to the ACO's overall quality score, such an ACO may be unfairly penalized. Therefore, we are modifying our proposed policy. Specifically, we are finalizing a policy under which CMS will adjust an ACO's overall performance score to reflect audit findings when the ACO has an audit mismatch rate of greater than 10 percent. However, we will retain discretion not to apply this adjustment to the ACO's score in certain unusual circumstances where it would be inappropriate to apply the adjustment. We note that we do not intend to employ this discretion to avoid adjusting an ACO's overall performance score in instances when the ACO cannot produce adequate validation of the data submitted or did not interpret the measure specifications correctly. For example, if we determine that the ACO has not produced medical record information sufficient to validate the data the ACO submitted to the web interface, we would not exercise our discretion not to apply the adjustment to the ACO's overall performance score based on results of the audit. We believe it is reasonable to: (1) Hold ACOs accountable for the accuracy of the data submitted according to information they validate from medical record reviews; and (2) require ACOs to produce proof of such accuracy in the event of an audit. Also, if we determine that the ACO did not interpret the measure specifications correctly, we would apply the adjustment to the ACO's overall performance based on audit results because ACOs are provided numerous opportunities to receive assistance from CMS before and during the quality measure submission process. For example, ACOs may access measure specification documents that are available on our Web site, contact the dedicated help desk, and attend webinars that we hold to educate ACOs about measure specifications and reporting requirements. Therefore, we believe that this modification of our proposal addresses stakeholder ( printed page 80492) concerns while permitting us to perform timely quality validation audits that hold ACOs accountable not only for the quality of the care they provide but also for the accuracy of their quality reporting.",
+ "K292HMSA:3866": "Response: We appreciate the commenters' support and are finalizing our proposal to allow EPs to continue to report CQM results as calculated by Certified EHR Technology by attestation for the 2012 payment year.",
+ "9V89NVZG:1624": "Response: We are finalizing this policy change to remove the requirement that the medical record must document the medical necessity of furnishing the visit in the home rather than in the office, as proposed, effective January 1, 2019."
 }
\ No newline at end of file
diff --git a/tests/pfs/test_cms_summaries.py b/tests/pfs/test_cms_summaries.py
index 433c016..5b4e67b 100644
--- a/tests/pfs/test_cms_summaries.py
+++ b/tests/pfs/test_cms_summaries.py
@@ -123,16 +123,40 @@ def test_pure_thanks_is_acknowledged():
 
 
 def test_conflicting_cues_are_unclear():
-    # live CY2027 ¶5899: "we do not believe that finalizing, as proposed, ..."
-    assert response_action_of(TEXT[5899]) == "unclear"
+    # a finalized-as-proposed cue next to a not-finalized cue is unclear
+    assert (
+        response_action_of(
+            "Response: We are not finalizing X. We are finalizing Y as proposed."
+        )
+        == "unclear"
+    )
+
+
+def test_not_believe_finalizing_is_still_a_finalization():
+    # R46a, live CY2027 ¶5899: "we do not believe that finalizing, as proposed, ..."
+    assert response_action_of(TEXT[5899]) == "finalize_as_proposed"
+
+
+def test_finalizing_beyond_a_comma_clause_is_as_proposed():
+    # R47, live 9V89NVZG ¶1624: "as proposed" more than 120 characters after "finalizing"
+    assert response_action_of(TEXT[1624]) == "finalize_as_proposed"
+
+
+def test_thanks_with_an_action_verb_is_not_acknowledged():
+    # R48, live K292HMSA ¶3866: "We appreciate the commenters' support and are finalizing ..."
+    assert response_action_of(TEXT[3866]) == "unclear"
 
 
 def test_inappropriate_needs_a_refusal_object():
     # live YYAWUFQX ¶1476: "it would be inappropriate to have collected" is not a refusal
     assert response_action_of(TEXT[1476]) != "not_finalized"
     assert response_action_of(TEXT[1581]) != "not_finalized"
+    # R46a, live WHNGCYHB ¶3310: "inappropriate to apply the adjustment" is not a refusal
+    assert response_action_of(TEXT[3310]) != "not_finalized"
     assert (
-        response_action_of("Response: It would be inappropriate to finalize this.")
+        response_action_of(
+            "Response: We believe it would be inappropriate to finalize this."
+        )
         == "not_finalized"
     )