Federal Reports

The Office of the Inspector General included an audit of the Tennessee Valley Authority’s (TVA) Back to Business Credit Program (Program) in our annual audit plan due to reputational and financial risks associated with the Program. Our audit objective was to determine if adequate controls were in place to ensure Back to Business credits were provided to businesses in compliance with Program guidelines. Our audit scope was all $13.1 million in credits issued during the life of the Program (April 2020 through September 2021).We found controls were adequate to ensure the Program credits were accurately calculated in accordance with Program guidance. However, we found some credits were not passed from the local power company to the customer. We also determined the Program did not have controls needed to more appropriately achieve the stated objective. Specifically, the Program did not include controls needed to (1) verify the reduced on-peak demand was due to a reduced level of operations as a result of COVID-19 and (2) specify how/when customers were considered back to prepandemic operating conditions.

For this report, we assessed the adequacy of the U.S. Census Bureau’s (the Bureau's) quality control processes to ensure the data collected during the 2020 Decennial Census (2020 Census) was complete and accurate. This report discusses lessons learned during the nonresponse followup (NRFU) operations for the 2020 Census: I. Students were likely undercounted at off-campus addresses despite outreach efforts; II. A significant number of NRFU enumerations were completed using a proxy; and III. The Bureau’s improper execution of its 2020 Census Quality Assurance Plan may have adversely affected data quality. While the 2020 Census operations have concluded, we suggest proposed actions for change from these lessons learned to inform the research and planning efforts for the 2030 Census.

For our final report on our audit of the U.S. Department of Commerce’s (the Department’s) security controls for cloud-based high value assets (HVAs), our objective was to verify that the Department implemented security controls for cloud-based HVAs in accordance with federal requirements. We found that the Department does not incorporate all customer responsibility controls for its cloud-based HVAs into system security plans.

The DOI has not finalized its body camera policy, and not all of its bureaus have finalized and implemented their body camera policies.

The objectives of the audit were to determine whether the State of Michigan (Michigan) designed and implemented awarding processes that ensured that the Governor’s Emergency Education Relief Fund (GEER grant) was used to support local educational agencies (LEAs) and institutions of higher education (IHEs) that were most significantly impacted by the coronavirus or LEAs, IHEs, or other education-related entities within the State that were deemed essential for carrying out emergency educational services; and monitoring processes to ensure that subgrantees used GEER grant funds in accordance with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and other applicable Federal requirements.Grant Awards - For five of the seven programs that Michigan funded with its GEER grant (Evolution Labs, Building Healthy Communities: Step Up for School Wellness, Statewide public television, teacher professional learning, and Early On), Michigan could not support that it awarded the funds to eligible entities that were deemed essential for carrying out emergency educational services, providing childcare and early childhood education, providing social and emotional support, or protecting education-related jobs. As a result, Michigan lacks assurance that its awards to four entities under these programs— totaling $5.4 million of the State’s $89.4 million GEER grant—aligned with the purpose of the GEER grant fund. Monitoring Processes - MDE did not have a written plan to monitor its GEER grant subgrantees. It had planned to contract with an audit firm to conduct monitoring of its GEER grant subgrantees; however, as of March 30, 2022, the contract had not been finalized. MDE did, however, conduct some monitoring activities and implement reimbursement processes for its subgrantees.

Independent Review of 4003(b) Loan Recipient’s Validation Memo – Republic Airways, Inc.

A Trackman/Watchman based in New York resigned on April 12, 2022, prior to his disciplinary hearing. The former employee failed to report his two alcohol related arrests in August 2017 and August 2019 and their corresponding convictions in July 2019 and April 2021.

We evaluated the U.S. Small Business Administration’s (SBA) controls to flag or prevent potentially fraudulent Coronavirus Disease 2019 (COVID-19) Economic Injury Disaster Loan (EIDL) applications submitted from foreign Internet Protocol (IP) addresses.Although the agency implemented several layers of controls to prevent or reduce fraud from foreign countries, individuals at foreign IP addresses were able to access the COVID-19 EIDL application system. SBA received millions of attempts to submit COVID-19 EIDL applications from foreign IP addresses and stopped most of them; however, the agency processed more than 233,000 of these applications from March 20, 2020 to November 12, 2021, our review period. Of this amount, SBA approved and disbursed 41,638 COVID-19 EIDLs, advances, and grants for $1.3 billion.The numerous applications submitted from foreign IP addresses are an indication of potential fraud that may involve international criminal organizations. OIG has ongoing investigations into international organized crime operations that applied for and stole pandemic relief funds. SBA officials were aware of and concerned about the potential fraud from overseas.We recommended the agency thoroughly review the loans in our test sample and the $1.3 billion disbursed to applicants from foreign IP addresses. The agency should stop any further or future disbursements to any applicants deemed to be ineligible or fraudulent. We also recommended SBA recover any disbursed loans and advances determined to be ineligible or fraudulent. Additionally, we recommended that the agency examine controls related to foreign IP addresses and ensure these controls are more effective in future disaster processing systems.Management partially agreed with recommendation 1, stating they would conduct a proactive review of COVID-19 EIDL applications that received funds for potentially ineligible or fraudulent businesses. They will attempt recovery and continue to refer suspected fraud to the OIG. SBA agreed with recommendation 2, stating the agency will examine controls related to foreign IP addresses and ensure these controls are more effective in future disaster processing systems.

A distribution and routing (D&R) tag is a self-adhesive barcoded label attached to a handling unit, which is a piece of mail or a sack that contains multiple mail pieces. Proper preparation of handling units includes removing old tags before applying new ones and verifying that tags are accurately formatted and legible.The U.S. Postal Service is contractually required to pay an additional relabeling fee of [redacted] per handling unit for [redacted] to replace D&R tags when units arrive at a [redacted] facility and tags are missing or illegible. Handling units with unreadable or missing D&R tags are redirected to a designated area where [redacted] employees conduct the relabeling process. From fiscal year 2019 to 2021, [redacted] created about [redacted] D&R tags, and the number of relabeled tags has steadily increased year over year since 2019.

The VA Office of Inspector General (OIG) conducted a healthcare inspection related to community care coordination delays for a patient with oral cancer at the Veterans Health Care System of the Ozarks (facility) in Fayetteville, Arkansas.The OIG determined that the facility’s Office of Community Care (OCC) staff failed to schedule radical resection surgery within 30 days of an initial consult and failed to act or delayed taking action on five community care consults for the patient’s surgery. As a result, the patient’s surgery took place 205 days after the first consult was placed. Facility OCC staff could not provide an explanation for the failure to act or the delays.The OIG substantiated that facility OCC staff failed to coordinate radiation therapy and delayed coordinating chemotherapy to begin within six weeks after surgery, as requested. Community hospital staff did not use a request-for-services form when seeking approval for the patient’s radiation therapy and chemotherapy evaluation appointment. Facility OCC staff denied the referral for radiation therapy at the community hospital, citing a lack of Veterans Health Administration OCC guidance on community care referrals. Although facility OCC staff entered a consult for chemotherapy at the facility, they failed to communicate the urgency of the care to facility oncology providers.A facility oncology provider saw the patient nine weeks after surgery and documented changes to the patient’s oral cancer and that radiation therapy would not be beneficial. The patient was placed on palliative care and died.The OIG made one recommendation to the Under Secretary for Health related to standardizing community care coordination for follow-up requests from the community provider and two recommendations to the Facility Director related to completing consults within the 30 days and coordinating oncology care in the community.

Objective: To determine whether the Social Security Administration’s (SSA) Information Technology Investment Process (ITIP) supports strategic decision making and allows the Agency to plan for, manage, and implement information technology (IT) investments as projected.

DHS’ IT systems did not effectively allow CBP and ICE personnel to track migrants from apprehension to release or transfer. Instead, DHS personnel and partner agencies at the border implemented manual and ad hoc workarounds to process migrants apprehended illegally entering the United States. DHS personnel also faced challenges when data was not consistently documented in DHS’ systems of record. For example, migrant apprehension times were not recorded in a consistent manner, and we identified missing migrant data that prevented DHS from determining family status. Also, CBP did not always document a migrant’s intended U.S. address before releasing the individual into the United States using prosecutorial discretion to await immigration proceedings. We made eight recommendations that will help prioritize funding needs and make integration improvements to DHS IT systems to promote timely and accurate information sharing within DHS and with external partners. The Department concurred with all recommendations.

Background: We conducted this review to determine the extent to which the data files the Social Security Administration (SSA) provided the Internal Revenue Service (IRS) to facilitate economic impact payments (EIP) under the American Rescue Plan Act of 2021 (ARPA) were accurate and complete when they were transmitted.ARPA became law on March 11, 2021 and authorized a third round of IRS-administered EIPs (EIP3). To assist in identifying Old-age, Survivors and Disability Insurance (OASDI) beneficiaries and Supplemental Security Income (SSI) recipients potentially eligible for EIP3s, the IRS requested SSA provide beneficiary and recipient data.On March 25, 2021, SSA completed delivery of OASDI and SSI production data that provided IRS with information on approximately 72 million beneficiaries and recipients.

BSEE addressed many issues identified in our previous report; however, we identified areas in which BSEE could further strengthen internal controls.

This report presents the results of our performance of the procedures agreed upon by the Office of the Chief Financial Officer of the U.S. Office of Personnel Management (OPM). The report responds to the U.S. Office of Management and Budget’s (OMB) requirement to assist the OPM in assessing the reasonableness of employee withholdings and U.S. Postal Service contributions reported in the Report of Withholdings and Contributions for Health Benefits, Life Insurance and Retirement. Postal Service management is responsible for withholdings and contributions reported in the Report of Withholdings and Contributions for Health Benefits, Life Insurance and Retirement; and the enrollment information reported in the Supplemental Semiannual Headcount Report (Headcount Report). The sufficiency of the agreed-upon procedures is solely the responsibility of OPM’s Office of the Chief Financial Officer. Consequently, we make no representation regarding the sufficiency of the agreed-upon procedures either for the purpose for which this report has been requested or any other purpose.

The National Credit Union Administration (NCUA) Office of Inspector General (OIG) conducted this self-initiated audit to assess the NCUA’s Minority Depository Institutions Preservation Program (MDIPP). The objective of our audit was to determine whether the NCUA’s MDIPP achieved its goals. The scope of our audit covered the NCUA’s actions to execute the MDIPP from January 1, 2019, through December 31, 2021

At the request of the Tennessee Valley Authority's (TVA) Supply Chain, we examined the cost proposal submitted by a company for coal combustion residual program management services. Our examination objective was to determine if the company's cost proposal was fairly stated for a planned 20-year contract.In our opinion, the company's cost proposal was unsupported and overstated. The company informed us that it did not have financial statements or other actual historical cost documentation to support its proposed costs. Therefore, we could not completely verify (1) certain aspects of the company's proposal for a Gallatin Fossil Plant (GAF) ash pond closure and restoration project or (2) if the labor and labor markup rates included in the company's proposed rate attachments were fairly stated. However, based on our review of the company's estimation methodology and the limited supporting documentation provided by the company, we found: The company's proposal for an $892.8 million GAF project was overstated because the company's proposal included (1) inflated subcontract costs, (2) overstated noncraft labor cost, (3) overstated markup rates for the recovery of the company's indirect costs, and (4) a fee rate that exceeded the maximum allowable fee rate in TVA's request for proposal. We estimated TVA could avoid $117.6 million on the proposed $892.8 million GAF project by negotiating appropriate reductions to the proposal.The company's proposed contract rate attachments included (1) craft labor rates that were overstated and did not conform to TVA's project labor agreement, (2) noncraft cost-reimbursable labor rates that included excessive burden, and (3) noncraft time and material rates that included excessive burden. We suggested TVA negotiate to revise the company's rate attachments to (1) comply with the project labor agreement and (2) eliminate excessive burden on noncraft cost-reimbursable and time and material labor rates.(Summary Only)

OIG issues this advisory letter to alert consumers and providers to an improper and fraudulent enrollment practice by some providers of Affordable Connectivity Program (ACP) services. Providers and their agents have enrolled many households into the ACP based on the eligibility of a single Benefit Qualifying Person (BQP) child or dependent. A single BQP cannot be used to qualify multiple households for ACP support simultaneously.

For veterans seeking disability compensation benefits, the Veterans Benefits Administration (VBA) requires a disability exam to determine the severity of a disability or a medical opinion on whether a current condition can be connected to military service. VBA has committed an estimated total of $6.8 billion in contracts to complete disability examinations and medical opinions over a five-year period starting in 2016. Because medical opinion requests can be vital to ensuring veterans receive the benefits to which they are entitled, the VA Office of Inspector General (OIG) examined whether VBA staff correctly followed procedures when requesting medical opinions.The review team found that VBA can reduce inadequate medical opinions, incorrect or delayed claims decisions, and wasted resources by improving internal controls, personnel training, and monitoring of medical opinion requests. The team estimated that 27,900 of 41,100 requests (68 percent) did not follow required procedures during the review period (October 1, 2020–September 30, 2021). Claims processors did not consistently identify relevant medical evidence for the examiner’s review, did not always use clear and accurate language, did not regularly request all warranted medical opinions, and sometimes requested unnecessary medical opinions. These failings can lead to inaccurate medical opinions, incorrect decisions on veterans’ claims, delayed decisions for veterans, and inefficient use of resources (such as when the medical opinion requires rework).VBA concurred with OIG-identified deficiencies and recommendations to (1) implement electronic system enhancements to require claims processors to identify relevant evidence before a medical opinion request can be submitted, (2) enhance mandated training for all claims processors and demonstrate progress in achieving its intended impact, and (3) strengthen monitoring by refining quality review processes to help identify areas for improvement and show advancements in complying with required procedures.

What We Looked AtThe Federal Information Security Modernization Act of 2014 (FISMA) requires agencies to implement information security programs. FISMA also requires agencies to have annual independent evaluations performed to determine the effectiveness of their programs and report the results of these reviews to the Office of Management and Budget (OMB). To meet this requirement, the Surface Transportation Board (STB) requested that we perform its fiscal year 2022 FISMA review. We contracted with Williams Adley & Company-DC LLP (Williams Adley), an independent public accounting firm, to conduct this audit subject to our oversight. The audit objective was to determine the effectiveness of STB’s information security program and practices in five function areas—Identify, Protect, Detect, Respond, and Recover. What We FoundWe performed a quality control review (QCR) of Williams Adley’s report and related documentation. Our QCR disclosed no instances in which Williams Adley did not comply, in all material respects, with generally accepted Government auditing standards. RecommendationsWhile there are no new recommendations issued for fiscal year 2022, STB concurs with the audit’s findings with respect to the remaining eight open recommendations from the fiscal year 2021 FISMA audit.

The CSB's operations are challenged by vacancies in mission-critical positions and an inability to fully use the resources allocated by Congress.

During a prior review, the VA Office of Inspector General (OIG) discovered three scenarios in which the VA improperly collected debts from veterans without first providing them with legally required notice and due process and notified VA. This management advisory memorandum gives VA the information it needs to determine whether to take further action to address similarly situated veterans.VA provides veterans tax-free monthly compensation in recognition of disabilities incurred or aggravated during active military service. These payments may change over time for various reasons, such as improved or worsening conditions or a change in dependents. If a decision retroactively reduces a veteran’s payment rate, a veteran incurs a debt that may be repaid through reductions in the retroactive benefits or reductions in future monthly benefits. Regulations require that VA notify affected veterans of the amount and reasons for the debt. VA must also inform veterans they have the right to dispute the debt, request a waiver of collection, request a hearing on the waiver request, and appeal the decision that caused the debt.In three example cases in which VBA improperly collected debts without notifying veterans of the debt amount or of their right to dispute it or request a waiver, VA agreed the debts were collected improperly due to automated actions in VA’s electronic systems that triggered debt collection.VA agreed to review these systems to help prevent improper debt collection from veterans in comparable circumstances and ensure they receive required notice and due process. The OIG asked VA to report on what actions it takes as a result of these findings. VBA’s comments provided in the memorandum appendix propose corrective electronic system updates.

We determined that USCIS did not apply the IT access controls needed to restrict unnecessary access to its systems, networks, and information. Specifically, USCIS did not consistently manage access for personnel, service accounts, and privileged users. We attribute these deficiencies to insufficient internal controls and day-to-day oversight to ensure access controls are administered appropriately and effectively to prevent unauthorized access. Additionally, we determined USCIS did not implement all the required security settings and updates for its IT systems and workstations to help reduce the risks that may result from an access control weakness. Although USCIS systems and workstations were generally compliant with required security standards, not all required settings and updates were implemented due to concerns that they may negatively impact system operations. Lastly, we determined that while USCIS appropriately relied on departmental guidance for access control policies and procedures, the guidance was outdated and did not include the latest Federal requirements. These deficiencies may limit the Department’s ability to reduce the risk of unauthorized access to its network, which may disrupt mission operations. We made 10 recommendations to improve USCIS’ access controls and system security and DHS’ access control guidance. USCIS and DHS concurred with all 10 recommendations.

The CSB's operations are challenged by vacancies in mission-critical positions and an inability to fully use the resources allocated by Congress.

EAC OIG, through the independent public accounting firm of McBride, Lock & Associates, LLC, audited funds received by the State of Washington under the Help America Vote Act, including state matching funds and program income, totaling $30.3 million. This included Election Security and Coronavirus Aid, Relief, and Economic Security Act grants.

We determined DHS encountered obstacles to screen, vet, and inspect all Afghan evacuees arriving as part of OAR/OAW. Specifically, U.S. Customs and Border Protection (CBP) did not always have critical data to properly screen, vet, or inspect Afghan evacuees. We determined some information used to vet evacuees through U.S. Government databases, such as name, date of birth, identification number, and travel document data, was inaccurate, incomplete, or missing. We also determined CBP admitted or paroled evacuees who were not fully vetted into the United States. We attribute DHS’ challenges to not having: (1) a list of Afghan evacuees without sufficient identification documents; (2) a contingency plan to support similar emergency situations; and (3) standardized policies. As a result, DHS may have admitted or paroled individuals into the United States who pose a risk to national security and the safety of local communities. We made two recommendations to improve the Department’s screening and vetting of current Afghan evacuees and coordination and planning efforts for future similar emergency situations. The Department did not concur with these recommendations.

The Federal Election Commission (FEC) Office of the Inspector General (OIG) initiated an investigation to inquire into an anonymous hotline complaint that alleged a senior agency employee was engaged in outside employment without agency approval or clearance in violation of federal regulations and FEC rules. Investigation of the matter determined the allegation was not substantiated because the employee in question (the subject) was not employed by the company while also an FEC employee.

EAC OIG, through the independent public accounting firm of McBride, Lock & Associates, LLC, audited funds received by the State of Indiana under the Help America Vote Act, including state matching funds and program income, totaling $26.3 million. This included Election Security and Coronavirus Aid, Relief, and Economic Security Act grants.

The Office of the Inspector General conducted a review of Bull Run Fossil Plant (BRF) organization to identify factors that could impact BRF’s organizational effectiveness. Additionally, the scope of this evaluation included identifying lessons learned for future coal plant closures. During the course of our evaluation, we identified positive interactions between coworkers and with various levels of plant management. In addition, TVA’s communication of BRF’s retirement plans, the support provided through Power Operations’ long term workforce strategy, and having an on-site Human Resources representative were seen as positive. However, BRF employees expressed concerns related to: the ability to operate BRF until retirement due to longstanding deteriorated conditions, inadequate staffing, and increased safety risk. We also found opportunities exist to improve site-specific plant knowledge and fire brigade staffing.

This report is Sensitive But Unclassified. To obtain further information about this Classified Report, please contact the OIG Office of Counsel at OIGCounsel@oig.treas.gov, (202) 927-0650, or by mail at Office of Treasury Inspector General, 1500 Pennsylvania Avenue, Washington DC.

This report is Sensitive But Unclassified. To obtain further information about this Classified Report, please contact the OIG Office of Counsel at OIGCounsel@oig.treas.gov, (202) 927-0650, or by mail at Office of Treasury Inspector General, 1500 Pennsylvania Avenue, Washington DC.

We determined that CISA and FEMA could better ensure program efforts are mutually reinforcing; they did not have compatible policies, procedures, and other means to operate across component boundaries; and CISA did not regularly update and monitor written agreements with Energy Sector partners. Increased coordination between CISA and FEMA could improve the outcomes of their efforts. Further, without a comprehensive framework for Energy Sector activities, DHS risks losing important data that would strengthen Energy Sector relationships, programs, and outcomes. We made three recommendations to improve CISA’s and FEMA’s coordination efforts to ensure Energy Sector resilience. The Department concurred with all three recommendations.

This report is classified. To obtain further information about this Classified Report, please contact the OIG Office of Counsel at OIGCounsel@oig.treas.gov, (202) 927-0650, or by mail at Office of Treasury Inspector General, 1500 Pennsylvania Avenue, Washington DC.

The VA Office of Inspector General (OIG) assessed the oversight and stewardship of funds by the VA Cincinnati Healthcare System. The review team looked at four areas to determine if appropriate controls and oversight were in place for open obligations oversight, purchase card use, Medical/Surgical Prime Vendor–Next Generation (MSPV-NG) program use, and pharmacy operations. The team reviewed data from fiscal years 2019 through 2021. The report includes the below findings:• Reviews were not completed for nine inactive obligations from a judgmental sample of 20 obligations that totaled about $7.2 million from September 30, 2021.• The healthcare system did not comply with VA policy for three of the 36 sampled transactions (about 8 percent), totaling about $10,200.• The healthcare system did not meet the formulary utilization goal recommended by the VA Medical Supplies Program Office (MSPO) to purchase 90 percent of formulary items from the MSPV-NG prime vendor.• Pharmacy efficiency could be improved by narrowing the gap between observed and expected drug costs.The OIG made eight recommendations to the healthcare system director: ensure finance office staff review inactive open obligations and pharmacy invoice reconciliations, develop a plan to work with the prime vendor to address having adequate stock for system needs, submit MSPV-NG waiver requests and obtain approval before purchasing formulary items from nonprime vendor sources, ensure logistics staff and contracting officer’s representatives use tools to inform the MSPO and Strategic Acquisition Center of prime vendor performance concerns and challenges, create formal processes for achieving efficiency targets and use data to make business decisions, prepare and implement a plan to increase inventory turnover closer to the VHA-recommended level, and develop a plan to complete facility-based inventory audits of noncontrolled drug line items.

Due to the risk of employee exposure to toxic vapors, gases, dust, or oxygen deficiency, the Tennessee Valley Authority (TVA) Office of the Inspector General (OIG) performed an evaluation of TVA’s Respiratory Protection Program at nonnuclear facilities. The objective of this evaluation was to determine if selected respiratory protection procedures were being performed at nonnuclear facilities.The OIG determined some respiratory protection procedures were not being performed as required. Specifically, we determined some (1) requirements were not being met for training, fit tests, facepiece seal protection, and respirator storage and (2) employees were delinquent on medical evaluation requirements.

This Office of Inspector General (OIG) Comprehensive Healthcare Inspection Program (CHIP) report highlights the results of a focused evaluation of Veterans Health Administration (VHA) facilities’ medication management related to remdesivir use. The report describes medication management-related findings from healthcare inspections performed at 34 VHA medical facilities during fiscal year 2021. Each inspection involved interviews with key staff and reviews of clinical and administrative processes.The OIG found that VHA met many elements of expected performance, including the availability of staff to receive remdesivir shipments. However, the OIG found that VHA did not consistently provide patient/caregiver education for remdesivir or report adverse events to the Food and Drug Administration in accordance with Emergency Use Authorization requirements.Given the FDA’s approval of remdesivir for use in adult patients hospitalized with COVID-19, the OIG made no recommendations related to the Emergency Use Authorization requirements. However, because VHA facility staff continue to administer other medications under emergency use authorizations, the OIG issued one recommendation related to informing patients and caregivers when the medication is not FDA-approved; the option to refuse the medication; and the known risks, benefits, and alternatives prior to administration.

Darius Lopez, a resident of Tampa, Florida, pleaded guilty in U.S. District Court, Middle District of Florida, to fraud and related activity in connection with access devices on September 1, 2022. Lopez was arrested on April 15, 2021, by the Citrus County Sheriff’s Department for using counterfeit credit cards to purchase over $20,000 of landscaping equipment. At the time of his arrest, Lopez was in possession of numerous counterfeit credit cards, including a fake GSA SmartPay purchase card with a purchase card number that was issued to Amtrak. This investigation is being conducted jointly with the GSA Office of Inspector General.

This report contains information about recommendations from the OIG's audits, evaluations, reviews, and other reports that the OIG had not closed as of the specified date because it had not determined that the Department of Justice (DOJ) or a non-DOJ federal agency had fully implemented them. The list omits information that DOJ determined to be limited official use or classified, and therefore unsuitable for public release.The status of each recommendation was accurate as of the specified date and is subject to change. Specifically, a recommendation identified as not closed as of the specified date may subsequently have been closed.