HFF Legislative Priority 5: An Act to Prevent COVID-19 Related Evictions

When the COVID-19 pandemic struck in the early months of 2020, a temporary prohibition was placed on evictions and foreclosures in Massachusetts. This moratorium, however, was lifted just months later in October 2020. Since then, the state has faced a deadly second wave of the virus, and the housing crisis worsened significantly. The housing crisis took a dramatically disproportionate toll on communities of color and low-income households throughout Massachusetts. Since October, over 8,000 new eviction cases have been filed and over 1,000 “executions” have been issued to landlords, meaning these families can be forcibly removed from their homes by sheriffs or constables. Over 1,000 Massachusetts homeowners are currently at risk of foreclosure. 

Though some programs are providing important resources to prevent evictions, they have not nearly met the needs of the people of Massachusetts. Vulnerable residents are excluded from helpful programs due to the difficulty of navigating the process, and many homeowners are being denied forbearance, the delay of a foreclosure. 

What we need now more than ever is strong legislative action to prevent displacement, address the financial distress caused by the pandemic, and reduce the racial disparities and economic inequality that Massachusetts residents face. 


What will this bill do?

Bill H.1434/S.891 builds on the eviction protections that were passed in the FY20 budget, Chapter 257 of the Acts of 2020. It closes loopholes in Federal protections which currently leave tenants and homeowners vulnerable, and ensures new federal rental assistance funds will reach those most in need.  

The COVID-19 Housing Equity Bill will: 

  • Require landlords to pursue and cooperate with rental assistance programs before pursuing eviction 
  • Protect the most vulnerable tenants from forced removal for COVID-19 debts 
  • Pause no-fault evictions during the state of emergency and recovery period 
  • Reinstate a pause on foreclosures and require forbearance based on federal policies 
  • Require the state to adopt equitable principles, flexibility, and simplification in the distribution of rental assistance funds. 

How to get involved: 

USE YOUR VOICE: contact your state representative to urge them to vote “yes” on this bill:    

You can find your State Representative and Senator HERE. These elected officials work for you, and it is immensely important that they hear from their constituents about what you want them to do as your representative. Here is a script you can use to email or call your representatives: 

Dear Representative/Senator [NAME],  

My name is [NAME] and I am Calling/Emailing on behalf of [ORGANIZATION]. I live in your district and wanted to talk to you about a piece of legislation that is crucial to helping end family homelessness in Massachusetts. This bill is incredibly important to me and I would really appreciate your advocacy, especially by co-sponsoring the bill.  

On any given night in our state, 18,471 people experience homelessness, a number that has more than doubled since 1990, and over 12,000 of them are in families with children. Since 2007, no other State in America has seen a larger increase in family homelessness. It doesn’t have to be this way! There are concrete laws that can be passed that will drastically transform Massachusetts into a State where homelessness really is brief, rare, and non-recurring.  

As your constituent, here is the bill I’d like you to co-sponsor and support: Bill H.1434/S.891: An act to prevent COVID-19 evictions and foreclosures and promote an equitable housing recovery. 

This bill would prevent evictions for the most vulnerable populations. Many of us have been financially affected by the COVID-19 pandemic in the most detrimental way. Through no fault of our own, we are facing housing instability. We need this bill to prevent foreclosures and evictions during the state of emergency and recovery period. 

Sincerely, [NAME] 


The lead sponsors of this Bill are: 

  • Senator Patricia Jehlen, Representative Kevin Honan, & Representative Frank Moran 

To read the full Bill, please visit: https://malegislature.gov/Bills/192/SD1802 

Following the Amendments on malegislature.gov

The House Committee on Ways and Means released their budget proposal on Monday, April 10th, a change from the typical Wednesday release to accommodate for Good Friday. Representatives had until 5pm on Thursday to add amendments to the $40.3Billion spending proposal.  Amendments can add additional funding and change line item language. Amendments must be filed by at least one representative, and others can add their name as co-sponsors after the amendment has been filed.  Historically, representatives co-sponsored an amendment by signing their names next to the corresponding number in a book in the clerk’s office with a quill pen.

Advocates and others would have to go to the clerk’s office at the State House and ask to see “the book” to see who had signed on. Now, legislators can use the “quill” feature on an online system that we can all track. Technology makes the process much more transparent.

The Massachusetts Legislature’s website had a bit of a face lift since last budget season. This blog post gives an overview of how to navigate the website so that you can read the various amendments, see what amendments your representative filed, and check to see if your State Representative is supporting the Budget Amendments that are important to you.

Step 1. Go to https://malegislature.gov/

Step 2. Go to the House Debate Page

Step 3. Use the Filter

When you enter your search terms, don’t forget to click the “filter” icon; use the “clear filter” feature to start a new search.  

Search Tips

  • If you don’t know who your State Representative is, click here
  • Housing programs all are listed with line item number 7004-
  • Line items we follow are: MRVP (7004-9024); Emergency Shelter (7004-0101); and HomeBASE (7004-0108)
  • Key words include: homeless, housing, voucher…

Step 4: Find your Amendment(s)

Step 5: Review the Amendment

Amendment #780 is an example of a funding amendment; striking the budget amount of $100M for MRVP and inserting $120M.

Click here to read the “technical amendment” #382 that was filed on MRVP 

Step 6: Take Action

If your Representative is signed on: say thank you!

If your Representative is not signed on: ask him/her to consider co-sponsoring.

You can call, email, use social media, visit the State House, attend an event.

Feel free to contact us with any questions or for more information.  For a sample script and a list of the amendments we are watching, click here

Stay tuned for more information; we will do our best to keep the blog updated as the budget process continues.  Representatives have up until the debates begin to co-sponsor and get educated about the amendments.

The debates begin on Monday, April 24th!

Some context and charts around the Governor’s Proposal For Family Shelter in FY17

On January 27th, Governor Baker released his recommendations for the state’s operating budget as a bill to the House of Representatives.  This year, his budget proposal is referred to as the House 2 Budget.  This is the Governor’s opportunity to recommend spending levels and any changes to the language or policies directing how the funding should be spent and the programs run.

The chart below highlights a few of the key line items relative to housing and homelessness.  The remainder of this post will specifically focus on the Emergency Assistance, or family shelter, line item, which is [affectionately] known as line item 7004-0101 in the State Budget.

H2HousingLinesFY17

No changes were recommended relative to shelter eligibility or other program functioning.  However, the proposal removed all oversight and reporting language [and earmarks].  This is the language that mandates the Legislature have 60 day advance notice of regulatory changes, and that charges the Department on Housing and Community Development (DHCD) with basic data reporting requirements [like monthly and quarterly reports].  It seems to be commonplace for the Administration to remove this language [and the Legislature to put it back in].

As the chart indicates, the Governor has recommended $191, 893,513 for the Emergency Assistance Program.  This program funds over 3,500 shelter units; as well as the corresponding staff, service and operating costs; overflow capacity in motel rooms; additional diversion dollars; and some earmarked funding for plays spaces, transportation and food pilots, and technical assistance from Homes for Families. While this funding [$191M] is considerably higher than the $154M Governor Baker recommended last year – or the $155M the Legislature allocated in their final budget – it is less than the $197.9 that is projected to be spent this fiscal year.

Each year, since the state has had to rely on motels to meet the need for shelter, a supplemental budget has been required as the total dollar amount needed for motels is somewhat of a moving target.  Typically, 7004-0101 is underfunded from the start, much like the snow and ice line item, and additional funding is requested once actual demand and dollar amounts are determined.  Last week, the Governor filed a Supplemental Budget proposal with the Legislature; included was $41M for EA.

There is some logic to under-funding EA.  The goal is always to get out of motels – to increase prevention, to increase housing, to use short term resources, for the rent wage gap and other realities of inequality to disappear on the basis of good intentions and incremental policy changes – so why invest upfront? The graphic below, a newly updated version from last year, provides an answer:

TimeLineFY16

Click Picture to Enlarge

Not adequately funding EA from the start causes complications in a system that is constantly adapting to policy changes and new initiatives. Simply put, it is inefficient. It places an unnecessary administrative burden on shelter providers and staff at the Department of Housing and Community Development, and on the Legislature who have to field panicked calls from Homes for Families and shelter providers as they process the supplemental budget, which may include complicated issues that require more time than the shelter contracts have.

So, what do you think? Is this the year that we try stability for a system that is charged with supporting families to achieve housing stability?

Here is an idea – how about the Legislature re-inserts the advanced notice language, adds some more data and reporting language to better track the use of the funds and functioning of the program, and provides adequate funding? That way, the shelter providers can have 12 month contracts and the Legislature can keep a close eye on the program. The motel number is at its lowest since 2010.  The overall caseload is also down. These accomplishments could not have been made without shelter providers’ hard work to expand programs and implement and adapt to new policies and programs. So, hey, if there is money left over at the end of the year, the state can invest it in HOUSING!

LH

A message from the Secretary of Administration and Finance

forwarding a message from Secretary Lepore so YOU can participate in the process:

A&F Launches Regulatory Review Feedback Portal

Dear Interested Stakeholder,

As you are likely aware, on March 31st Governor Baker signed an Executive Order initiating a year-long review of Massachusetts regulations. Over the past two months, my office established clear lines of communication throughout the executive branch, developed an extensive internal database of existing regulations and is now putting the finishing touches on an elite team of subject matter experts from across state government.

When the Governor and I made this announcement, we said our goals were to make sure that state government speaks with one voice and that this review will help Massachusetts citizens and organizations of all kinds grow and succeed. An essential step towards achieving those goals is gathering feedback from you and your fellow stakeholders, the very people that are affected by state regulations on a daily basis.

To that end, we have established an online portal to solicit feedback. I hope you will consider sharing this link with any individuals or stakeholders you think are interested in participating in the process.

Link to Regulatory Review Portal: http://www.mass.gov/anf/a-clearer-code-regulatory-reform.html

Thank you in advance for your help. I look forward to both your feedback and a Massachusetts with a much clearer regulatory code.

 

Sincerely,

Kristen Lepore

Secretary

Executive Office for Administration and Finance

House Debate Week: You can’t always get what you want, but….

As our prior blog post illustrates, we wanted a lot from the House budget debates relative to housing:

We supported our amendment sponsors the best we could from outside of the ropes in front of the House Chambers (no matter how far the ropes are expanded!).  We gave them information and talking points, educated and encouraged other legislators to join them in the closed door discussions, and relied on you- our HFF community- to rally your legislators.

Unfortunately, none of our priority amendments for housing were passed. But as the Rolling Stones say, “You Can’t Always Get What You Want”.

Chart with adopted

But thankfully, the House Budget proposes things that we need:

  • A significant increase to the Massachusetts Rental Voucher Program
  • A rejection of the Governor’s proposal to further restrict shelter eligibility
  • More funding for prevention, diversion and re-housing through RAFT and HomeBASE
  • And an increased cap to the HomeBASE benefit

For more details on the House budget relative to HOUSING, check out CHAPA’s summary.

The House Budget proposes the Emergency Assistance Line item be funded at $155,058,948, which is about a $15M increase from the appropriated amount for this fiscal year and about $40M less than the total spending on shelters and motels in FY15 including supplemental funding.  Earmarks were added to the line item for playspaces and to provide additional services to families in certain motels. The line item received a bump of $180,000 to cover the cost of those additions.

The House Budget provides a strong proposal for addressing the family homelessness crisis in fiscal year 2016, and will help us to focus on maintaining and fine tuning the line items in the Senate.

Do you want to stay involved and take more action? No problem, here are a few ways:

1. We invite you to listen to this song to remind you of our MRVP ask.  We hope it inspires you to call your Senator and remind them of the need for HOUSING SOLUTIONS TO THE HOMELESSNESS CRISIS! We are very pleased with the $90.1M proposed by the House, but more $ = more vouchers! #MRVP100!

2. Stay tuned for more information about the House Budget relative to our other priority areas and for action you can take to address the shelter and HomeBASE access issues in the Senate.

3. You can also say thank you to:

  • Speaker DeLeo; Chairman Dempsey of Ways and Means; Chairman Honan of the Housing Committee; and Assistant Majority Leader Byron Rushing with a simple call or email saying “Thank you for the protections and investments for homeless families in the House Budget”
  • Representative Marjorie Decker of Cambridge for sponsoring and fighting for important amendments related to shelter, HomeBASE, welfare benefits, and EITC….and for giving an impassioned speech about her own history in public housing, the role of Government and the need for housing for all families of the Commonwealth
  • Representative Barber and Representative Gregoire for sponsoring the HomeBASE access and EA reporting amendments, respectively
  • and your representative if they signed on to the amendments that you care about

Finally, we leave you with this- a video taken at the State House.  No filming is allowed from the House Gallery where we watch the debates and the votes are taken, but thankfully this video was made of the evacuation of the State House on Wednesday morning to give you a sense of the fun and energy that is House Debate Week!

video credit: Mike Deehan from MASSter List

Thank you for all YOU do to end homelessness!

Onward….

LH

Getting Wonky With It: Information for next week’s budget debates

On April 15th, the House Committee on Ways and Means released their budget proposal.  You can read our analysis here, Mass Law Reform’s analysis on programs impacting families with low incomes here, and Mass Budget and Policy Center’s full analysis here.

Representatives filed 1,096 amendments to the proposal.  All of the amendments are posted online and can be viewed here.  Using the on-line mass.gov tool, you can search for particular amendments by key word, line item number, and amendment number and/or legislator name. If you click on the amendment number, you will be able to see the text of the amendment, as well as the names of the legislators that have signed on in support.

The chart below includes amendments that are relative to homelessness.  We included all amendments that are being filed to our priority line items, issues that correspond to our Visioning Day recommendations, amendments that are priorities of our partner organizations, earmarks, and amendments that would have a negative impact on the people experiencing housing and economic instability, so that you know what is at stake in the debates.

Amendment Chart Take 2

Click the picture to enlarge 

Next week, the House of Representatives will debate the amendments in order to finalize the FY 16 House Budget.  Much of this process is done behind closed doors in “caucus meetings”, or meetings pertaining to a particular topic, such as housing.  Legislators will have an opportunity to speak for or against a specific amendment, and then the Ways and Means committee will determine which amendments will get considered as part of a broad “consolidated” amendment relative to each topic.  Then legislators will vote on the consolidated amendment.  In other words, not every amendment will get voted on.  This is why it is so important for you to advocate and let your representative know what amendments are important to you – and to addressing our family homelessness crisis.  We need Legislators to show their support through co-sponsoring, but also for going to the caucus meetings and speaking up for the important issues. They need you to help educate them so that they can be active participants.

Click here to find out who your Representative is and their contact information.

 

TeamHFF

Taking Aim at Ending Family Homelessness in Massachusetts 

Viewpoints from Around the State: Taking Aim at Ending Family Homelessness in Massachusetts 

by Libby Hayes, featured in the Provider, a monthly newsletter from the Provider’s Council that highlights some of the biggest issues in the human services sector.

According to the 2014 report, America’s Youngest Outcasts, the number of homeless children increased by 8 percent nationally from 2012 to 2013; there were increases in the number of homeless children in 31 states and the District of Columbia. The report also states that 1 in 30 children in America are without a home.

Here in Massachusetts, the Department of Education identified 15,812 homeless students last year. Data from the U.S. Department of Housing and Urban Development shows a 94 percent increase in the number homeless families in the Commonwealth from 2007-2014. The state’s Emergency Assistance (EA) program is currently providing shelter to approximately 4,460 families each night. We were battling the issue of homelessness before the recession hit. That issue is now an epidemic. An epidemic that can – and must – be solved.

Despite the daunting statistics above, the number of families in motels has been reduced from a high of 2,200 families in December of 2013, to fewer than 1,400 in March of 2015. This reduction is a result of a combination of efforts, including an expansion of the number of family shelter units. The Department of Housing and Community Development (DHCD) and the EA shelter providers have worked to implement more efficient and specialized program models such as co-sheltering, a shelter for single fathers and enhanced services for domestic violence and substance abuse.

 Next, a pilot program was launched in July of 2014, placing EA providers in the five busiest shelter intake offices. The providers meet individually with eligible families, to explore resources and opportunities outside of the shelter system. According to DHCD data, the statewide rate of families “diverted” from shelter in January 2015 was 21 percent, a significant increase from the 5 percent diversion rate in FY ’14. At the same time, DHCD reports the total number of exits from the EA system has increased from a year-to-date total of 2,955 in January of 2014 to 3,696 year-to-date total in January of 2015.

The HomeBASE program has been a critical resource in these achievements. Investments in the Massachusetts Rental Voucher Program, Leading the Way Home Vouchers through the Boston Housing Authority, access to private developments through the New Lease Program, and augmented staffing in motels have all contributed the increase in the number of families exiting the shelter system. Building on these efforts will further reduce the reliance on motels and better support families to overcome homelessness.

The recently released On Solid Ground report outlines the economic context of the family homelessness epidemic – specifically exploring the issues of wage stagnation, a decline in housing production, disinvestments in family supports and fragmented public policies and programs. On Solid Ground calls for more coordination and accountability across all state agencies to better align policies and maximize resources and effectiveness.

Historically, homelessness has been looked at in one of two ways: through a human service lens or through a housing lens. We now recognize that we must look at housing as the foundation, and at human services, child care, education, labor and workforce, and health care as the materials needed to construct a future without homelessness. Resources are needed, and coordinating a holistic response requires leadership and vigilant tracking of data to evaluate progress.

Governor Baker has made family homelessness a priority issue for his administration. His FY ’16 budget proposal includes $20 million for a new End Family Homelessness Reserve Fund to be administered by the Executive Office of Health and Human Services (EOHHS), but has also proposed further restrictions to shelter eligibility. Further restrictions are simply not tenable; already about half of the families that apply for shelter are determined ineligible; more than 600 families entered the shelter system in FY ’14 after staying in places not meant for human habitation. These are children. Blanket categorizing and excluding subpopulations of homeless families has never proven successful in the Commonwealth’s 30-year battle against family homelessness, especially compared to successful prevention and diversion models.

 Thoughtful distribution of the Reserve Fund will be needed to avoid making the system more convoluted and confusing to families in crisis. While flexible funding has proven to be a useful tool to manage homelessness more cost effectively, it cannot solve an epidemic caused by larger systemic issues: a shortage of affordable housing and wage stagnation at our lowest income levels. But a focus on housing, children and providing the necessary opportunities and resources will do more than manage homelessness – it will end it.

-Libby Hayes, Executive Director of Homes for Families

Providers Council

The Time Has Come Today…(so what will happen with EA?)

The Time Has Come Today…

..when the 7 day shelter contract extension, from the 21 day contract extension, from the 7 month contract will expire.  This article from the State House News, and heard/posted on public radio, makes is clear that everyone knows we have a serious timing issue:

When Gov. Charlie Baker urged the Legislature to act quickly on his midyear spending bill filed late last month, he likely had this very situation in mind, cautioning that there were agencies and programs with “time-sensitive” funding needs demanding action before the end of March.

 “We need the money that’s in the supp. From our perspective this is a timing issue. The shelters are not going to close. No families are in danger and we’re working diligently with the Legislature to get the money they need,” said Paul McMorrow, a spokesman for the Executive Office of Housing and Economic Development.

House budget leaders said Thursday they were aware of “funding timelines” for the emergency assistance family shelter program, but could not comment on whether they would consider separating the shelter funding from the budget bill to get it approved faster.

It seems like an appropriate time, to share Homes for Families’ time lines illustrating the chaotic contract lengths for family shelters:

Here is what this year is looking like so far:

fy15sheltercontract

And here is how this year fits in with recent years:

timeLineEAfy15

So, what impact does this have on shelter programs you ask?

  • Well, for starters, right now providers can’t be paid. On April 1st, rent will due to landlords that lease apartments and buildings that are used as shelter units
  • When providers can’t be paid, they may have to rely on lines of credit, which they will have to pay back with interest
  • It is extremely burdensome on finance staff to manage funds when programs are not being reimbursed, and to have to amend budgets and do unnecessary paperwork
  • Last minute contract signing is a distraction and can be complicated, especially if shelters are dealing with crises, or if authorized signers are out of the office
  • DHCD contract managers have to manage the signing, resigning, and processing, when they are also responsible for monitoring programs and other assistance to providers
  • Legislators have to deal with the sudden blitz of calls from panicked advocates and shelter providers
  • Feel free to leave a comment about the other impacts that short term contracts have on you and your programs

We are hoping, and asking, that the EA supplemental funding get separated and passed independently.  This will allow the contracts to get issued, and time for the Conference Committee the time to thoughtfully work out the other compromises between the Senate and House Bills.

We have an opportunity to stop this insanity in FY16.  We think it is about time.

LH

The Senate Budget Debates: Day 1 is done (re: family homelessness)

As we have posted, the Senate Ways and Means budget was released last Wednesday at noon.  Senators had until Friday at 3pm to submit amendments.  A total of 948 were filed.  The Senate caucused on Tuesday, meaning they met behind closed doors and sorted through the amendments and made their cases. Unlike the House, Senate Amendments are listed by category on mass.gov and when the debates begin, they read them one by one.  You can follow along by watching on-line, tracking the amendment list….and get some tidbits from twitter by following #massbudget (or doing these things all at once if you can figure that out!)

Many of the amendments are announced by number and declared to be determined by the “yay’s or nay’s”…to which there is no response, or discussion, and the President says, “Yays have it” or “Nays have it” and moves on to the next.  The Minority Leader (Senator Bruce Tarr) sometimes questions the amendment and asks the lead sponsor to clarify the intent, and other times the lead sponsor requests (or has been requested) to speak on the merits of the amendment.  A roll call vote can be requested, at which time all Senators vote, majority wins and votes are recorded.

The debates started slow…at the dinner recess, they were at, or around, #120.  But then the Senate President took over when the session resumed….gavel in hand, head down, decisive and efficient… and suddenly they reached the Housing Amendments (ECO…for Economic Development). The session recessed before 10pm after going through 400 amendments.

So this is what happened:

No roll calls were requested.

Other items were held and will be discussed later in the debates.  Often these items need further discussion or were determined to be a “nay” and the sponsor(s) pulls it from the Nay Pile for further advocacy.  These items include:

Still on the list, and in the queue for tomorrow is the EA funding amendment and MRVP amendment, which has been re-drafted to exclude the prioritization of households with extremely low incomes (below 30% AMI) and inserting “ the department shall also develop a system of voucher distribution which prioritizes criteria related to need, ability to benefit, and ability to maintain sustainable housing;

There are also a few other homelessness related amendments remining- earmarks, the HCEC’s, Secure Jobs, housing authorities, HomeBASE reporting and equal treatment for families in motels (compared to non-EA families).

There will undoubtedly be some interesting discussion and debates. Stay tuned….or better yet, be there.

LH

Senate Budget Analysis: MRVP, EA and HomeBASE #mapoli

MRVP

The Money:

The Senate Ways & Means recommended funding the Massachusetts Rental Voucher Program  (MRVP, line item 7004-9024) at $70 million, a $12.5 increase over current spending and $9.5 million over the funding recommended by the House last month.

The Language: 

New language was also inserted into the MRVP line item that says:

“… any new mobile vouchers distributed in fiscal year 2015 be distributed to families currently residing on existing or new statewide housing waitlists…the method used to distribute or redistribute vouchers under this item shall not take into account participation in the state’s emergency assistance housing program…”

So, does this mean that families in the state’s shelter system would not be eligible for new vouchers that would be funded? NO! While it is unclear of the process DHCD might use to distribute new vouchers under these guidelines, this language does not exclude EA families from receiving new vouchers as they become available. The language seems to infer that families accessing EA would simply not receive a priority over other standard applicants and would have to be on the waitlist (yet to be determined) in order to be considered.

Emergency Shelter:

The Money:

The total dollar amount of $136.9M is less than the House proposal of $140M ($125M for shelter and $15M for motels) and significantly less that the Governor’s proposal of $179.6M ($167.3M for motels and $12.3M for motels).  This will leave the program underfunded, as total spending in FY14 is approximately $160M, including shelter, motel and (pending and passed) supplemental budgets.

The Language:

The language is largely unchanged from the FY14 budget in that there were no corrections made to the eligibility criteria and the other protections  (like presumptive eligibility, due process and oversight language) and program mandates (like dv services, housing search, cribs) were maintained. Some changes are proposed. They removed the language saying those placed only presumptively cannot be barred by the 12 month rule (so a family in shelter less than 30 days and never found finally eligible could be barred for 12 months). The data and reporting requirements for DHCD are simplified, and the distinct line item for motels was eliminated and language was inserted into this line item authorizing motel spending.

HomeBASE:

The Money:

The Senate proposes $24.2M for HomeBASE, which is $100,000 less than the Governor’s proposal and $1.7M less than the House proposal.

The Language:

The Senate language would mandate DHCD to establish a new maximum per family annual cap by September 1, 2014. The language also states that the cap shall be $6,000 until a new cap is established.  The language in this line item is simplified due to the elimination of the rental assistance component, so will require further analysis, but it does not appear other significant changes were made.

SWM Analysis