Develop comprehensive written documentation of the procedures to be performed by Commission staff for reviewing, evaluating, and approving or rejecting compliance transaction packages CNAs submit to PLIMS. The procedures should include roles and responsibilities with an appropriate segregation of duties and documentation requirements in PLIMS. (Finding 1B) For CVR transactions, also incorporate the following: a. OCD staff protocols and requirements for requesting access to detailed supporting documentation provided by the NPAs to the CNAs to independently verify NPA compliance with statutes, regulations, and Commission policies. The protocols should take into consideration identified risks such as NPA past performance, overall trends in compliance deficiencies, external factors such as civil settlements, and the Commission’s plan for conducting compliance visits to NPAs during the FY. (Finding 4A) b. OCD staff documentation requirements in PLIMS including any follow-up with the CNA for discrepancies between the Commission’s results and the CNA’s reported results. (Finding 4A)