If data is not entered into ICIS in a timely fashion, you are probably not getting credit in the ICIS for all of your disclosure initiations. Data must be entered in a timely fashion. The ICIS data entry practice established in OECA’s AA “data integrity memo” (June 2002) requires that all milestone activities be entered in ICIS within two weeks of the activity date. For example, the date of a referral to DOJ, the date a settlement is lodged or entered by the court, the date of a complaint filed by the court, the date of a voluntary disclosure letter. The date of a voluntary disclosure letter and the date you are entering the disclosure should be within two weeks of each other.
The general voluntary disclosure data entry policy says the date of the letter should be entered as the disclosed date in ICIS. The “Actual date” should be the date the Voluntary Disclosure is received into the Regions offices." When I'm entering the information, I use the date of the letter. ICIS counts voluntary disclosure initiations under the fiscal year based on this date. If a voluntary disclosure is entered in ICIS October 2005 but the disclosed date (the date on the letter) is September 2004, the disclosure will be counted as a FY 2004 activity. In this example, the Region missed the deadline and so received no credit for this activity.