After 10 years, I've seen the system with & without IRF.  When Interim Reporting was developed, I felt it was a useful tool for both our clients and workers.  I do feel that it has needed some "tweaking" for quite a while. Studies have shown since 1949 the average easy to read periodicals (newspapers, magazines, books etc.) are written on a 5th grade level with average sentence lengths of 11 words. Periodicals with very easy to read styles are written on 4th grade levels with average sentence length of 8 words or less. Even Mark Twain wrote Huckleberry Finn at a 7th grade level. Our modern pulp fiction writers today write at a 5th to 7th grade levels.  If this is so, why are we not able to keep forms simple for our clients?  Clients do need to have accountability and responsibility, but they have to understand our forms. Simplified reporting is anything but simple. Policy has become so convoluted, we have clarfications, upon clarification that have to be clarified.  I think if you have an ABD case; everyone on a fixed income (SSA/SSI/PSL retirement, etc), you should not have an Interim Report. That case should a 12 month cert period!  Unstable households (no income) should have a 3 month cert period. All others, should have IRF!  I do not feel that the proposed regulatory action encourages personal responsibility, just by filing a new application.  It may just delay benefits  few days and of course a possible proration (maybe a slight one) of benefits (since they usually call on the 1st of the month or as soon therefore as possible). If the same penalty is imposed for not submitting a timely IRF (by the end of the required 1st month) we may have a better participation rate.  Thank you for allowing me the opportunity to give my opinion.