Seiken.ai

See what else Seiken.ai can do

The same reading, applied to different questions: tracking one requirement through every document, flagging the terms a document never defines, and putting a price on a gap between a statute and its guidance.

Find a criterion across documents

Ask for one requirement and Seiken.ai tracks it through every document, marking where each addresses it, how strongly, and where it is absent. The grid makes gaps visible at a glance.

Seiken.ai

Query Findings Library Governance

QUERYHow does each cataract coverage determination treat visual acuity and complex surgery?Criteria

Criteria map3 criteria7 documentsExportWordHTMLExcel.md

Criterion	1	2	3	4	5	6	7
Sets a numeric visual acuity threshold	Yes	No	No	No	No	No	No
Snellen acuity: how it is required	Not named	Should	Must	Considered	Not alone	Not alone	Not alone
Addresses complex cataract surgery in its text	Yes	Yes	No	Yes	Yes	Yes	Yes

Document 3 names complex cataract surgery only in its list of related documents.

YesAddressedShouldAddressed, weaker or conditionalNoAbsent

Flag undefined terms

A requirement cannot be met if its key words are never defined. Seiken.ai marks operative terms that a document relies on but does not define.

Seiken.ai

Query Findings Library Governance

QUERYWhich terms in this coverage determination are used but never defined?Vagueness

VaguenessL33954Cataract extractionExportWordHTMLExcel.md

PROVISION TEXT

For patients with a best corrected visual acuity of 20/40 or better, cataract extraction will be considered if all other criteria have been met and there is substantial documentation of the medical necessity of the procedure for that patient.

UNDEFINED TERM

substantial documentation

Defined in the documentNo

What it controlsCoverage at 20/40 or better

What a provider cannot tellHow much is enough

Put a price on a gap

A gap between a statute and its guidance has a cost. Congress tied a business tax credit to a suspension it never defined; the guidance filled the gap three ways, and the agency later narrowed one of them. Seiken.ai finds that gap in the documents, before the claims arrive.

Seiken.ai

Query Findings Library Governance

QUERYWhat must a business show to claim the Employee Retention Credit for a partial suspension of operations?Trace

VaguenessFederal taxStatute to guidanceExportWordHTMLExcel.md

The statute never defines partially suspended. The guidance supplied three different tests, and the agency's own counsel later narrowed one of them.

Statute

CARES Act § 2301(c)(2)(A)(ii)(I)

Credit when operations are fully or partially suspended by a governmental order.

No measure given

Guidance

IRS Notice 2021-20

10 percent of receipts or hours
More than a nominal effect, no number
A supplier unable to deliver

Agency counsel

Chief Counsel memo AM 2023-005

The statute does not include supply chain disruptions; the supplier test is a narrow, limited exception.

Exposure

Claims under review

$86 billion+in more than 1 million claims

60% to 70%showed an unacceptable level of risk

IRS, June 2024

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