12 MONTH CERTIFICATION PERIODS ARE TOO LONG WITHOUT AN INTERIM REPORTING OF AT LEAST 6 MONTHS, 3MONTHS WOULD BE MORE APPROPRIATE.  PEOPLE MOVE TOO MANY TIMES, MOVE PEOPLE IN AND OUT, START JOBS, STOP JOBS, DRAW UNEMPLOYMENT AND STOP DRAWING BEFORE BEING REVIEWED.  

THEY HAVE TOO MANY CHANGES TO WAIT 12 MONTHS.

NEED TO GO BACK TO MAKING ALL CHANGES REPORTABLE.