The IR requirement should be eliminated.  It is too time consuming as customers do not complete reports,  some reports are not returned timely, required verifications are not submitted with the reports, reports are not signed and some reports are not returned at all. All of these things require extra steps in getting the reports completed for evaluation.  Often times, the reports that are submitted have to be handled over and over again in order to obtain information that is requiired.  I believe that interviewing the customer every 6 or 12   months will result in more accurate information being obtained and will cut down on expense as well as the time involved.  Conducting an inteview whether via telephone or face to face, in my opinion,  is best practice for payment accuracy.  If IR requirements remain in place, I do believe that a penalty should be invoked for late filing as it is for  filing a late recertification application.