I have seen the Interim report come and change from a very simple process to a very cumbersome procedure.  It blows my mind that clients are not required to report their new address but somehow we need to get the Interim report to them.  I vote for 12 month cert periods and no Interim and put back the requirements for reporting changes as before.  Most of my clients never send in an Interim completely filled out and with verifications.  All this back and forth of forms and requests is very time consuming.  Please decide something and stick to it for a while until we can work out of the backlog we now have.