Making all certification periods a maximum 6 months will have an adverse effect on workers who already struggle in having enough time to manage increased caseload sizes which will not likely be going down in the foreseeable future.  The same clients who do not complete the interim reports will be the same ones who do not respond to NOE's every six months.  This will increase the number of late recerts and applications which will likely be a majority requiring expedited processing.  We already have the option of using a six month cert for cases where expenses exceed income.  By changing to all cases having a mandatory six month cert, we would lose the 24 month cert on the elderly and disabled who rarely have any changes to report anyway.  While it may save the agency on postage mailing out requests for action on incomplete I/R's if we no longer had them, the alternative would nullify any cost savings in mailing out NOE's and printing out SOF's for six month recerts.