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We now find that the time may have begun to run earlier than the March 1986 date suggested in our draft decision , based on a final reimbursement rate being set then . In our draft decision we focused on the particular facts before us . " Although our review found many instances where HUD 's IDIS data overstated and potentially understated jurisdictions ' ADDI expenditures , our draft report did not contend that HUD 's data have no value . Because accurate data are essential for program evaluation , as well as program management and oversight , our draft report recommended that , if the program is reauthorized , HUD develop and implement controls and issue guidance that would ensure that data attributed to ADDI are accurate . The claiming statute may have been triggered by December 4 , 1985 , when an interim rate was apparently set , as indicated in our draft decision at page 6 , note 3 . There 's eight or nine of these functions listed in our draft resolution . HUD did not comment on our recommendations but made several comments about other aspects of our draft report . This is why it is genuinely important for our draft declaration to encourage the interim government to bring together , as soon as possible before the poll , representatives of the Iraqi political scene . While we estimated average pharmacy acquisition costs for the multiple-source outpatient prescription drugs in our sample using utilization and cost data from the first quarter of 2006 , we also acknowledged in our draft report that retail pharmacies could change their utilization of multiple-source outpatient prescription drugs in 2007 and later to lower their acquisition costs . Our draft report explained that IMS Health collects acquisition cost data from actual sales transactions from manufacturers and distribution centers , which represent over 85 percent of total market dollar volume , and projects these data to represent national average acquisition costs . In our draft decision we considered the possibility that the expenditures which started the two-year limitation running could have occurred prior to March 1986 .