In Matter of Agour, the BIA confirmed that an adjustment of status qualifies as an admission, and thus, any fraud committed during the adjustment process can be waived under section 237(a)(1)(H) of the INA, even if the applicant previously entered the United States in an other status without committing any fraud to procure that entry. The BIA explored the historical evolution of the immigration laws, which have shifted the focus away from whether a person has effectuated an "entry" into the United States to whether a person has been admitted, and concluded that this evolution, as well the statutory language of section 237 of the INA (which covers inadmissibility at the time of entry or adjustment), mandated that fraud in an adjustment be treated the same as fraud in an entry - in other words, that both be waiveable under section 237(a)(1)(H) of the INA.
The full text of Matter of Agour can be found here: http://www.justice.gov/sites/default/files/pages/attachments/2015/05/18/3837_0.pdf