Provide verification to HUD that it has taken the appropriate action to correct its delinquent or default status code reporting for the borrowers affected as a result of its system change.

Implement adequate procedures and controls to ensure that borrowers’ delinquent and default information is accurately reported.

Develop and implement metrics to evaluate each nursing home’s financial data for changes in utilization, payments, profitability, and solvency (debt service credit ratios).

Develop and implement procedures for referring operators who fail to provide required financial statements to the Departmental Enforcement Center.

Develop and implement internal controls to routinely compare financial data on mortgage payments to Multifamily Delinquency and Default Reporting System data on mortgage payments and follow up on any conflicting data.

Develop and implement procedures to require owners, operators, and lenders to submit accurate and complete financial data.

Develop and implement computerized controls to flag blank data fields and illogical financial data.

Develop and implement policies and procedures to revisit the classifications at least annually.

Define the troubled and potentially troubled classifications for nursing homes and develop specific measures to identify when and how nursing homes are classified.

Require Shawnee Christian Nursing Center to return 27 beds to operation or pay down the mortgage by $815,973