Hearth Record

Greentree of Hubbell Rehabilitation and Health

A nursing home in Hubbell, Michigan 49934

52225 B Avenue, Hubbell, Michigan 49934. (906) 296-3301.

CMS’s own record, on Care Compare

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The short answer

Record last released by CMS on Oct 28, 2026.

The last 24 months 63 citations in 6 months of the last 36. Last cited Mar 2026. Most serious: actual harm (G). Every month

Each figure’s source sits beside it, in its section below.

What these words mean7
Star ratings
CMS rates some kinds of place from 1 to 5 stars, more stars meaning better on CMS’s own measures for that kind: for a nursing home, its health inspections, staffing and quality measures. A rating is CMS’s summary of those measures; it doesn’t promise good care. Source: CMS, Care Compare and the Five-Star Quality Rating System.
Inspection (survey)
A visit by state inspectors, often unannounced, who check a place against the rules it must meet. For nursing homes and other places Medicare pays, CMS calls these visits surveys: a standard survey of a nursing home comes at least every 15 months, and a complaint survey whenever a complaint calls for one. Source: CMS; 42 CFR 488.308.
Deficiency, citation, violation
What inspectors write up when a place didn’t meet a rule: the rule, what they saw, and when. CMS calls it a deficiency; states may say citation or violation. It is the inspectors’ finding, not a court’s, and the place is usually asked for a plan to correct it. Source: CMS, statement of deficiencies (Form CMS-2567); each state’s licensing agency.
Scope and severity (A to L)
CMS grades each nursing home deficiency with a letter. A to C: no actual harm, with potential for minimal harm. D to F: no actual harm, but potential for more. G to I: actual harm. J to L: immediate jeopardy. Within each band, the letter rises as more residents were affected or could be: one or a few, a pattern, or widespread. Source: CMS, nursing home scope and severity grid (State Operations Manual, chapter 7).
Nurse staffing hours
The hours registered nurses, licensed practical nurses and nurse aides worked, per resident per day, from the payroll records each home sends CMS. Source: CMS, Payroll-Based Journal.
Fines and payment denials
A fine (civil money penalty) is money CMS makes a nursing home pay when it falls short of federal rules. A payment denial means Medicare and Medicaid stop paying for new admissions until the home meets the rules again. Source: CMS; 42 CFR 488.430 and 488.417.
Capacity
The most people the licence or certification lets the place care for at once: residents, children, beds or apartments, as the state counts them. It isn’t how many are there now. Source: Each state’s licensing agency.

What did inspectors find?

25 health citations at the latest inspection cycle

The Michigan average is 9.9.

Last standard inspection Mar 3, 2026.

Most serious in three years: actual harm (G), at a standard inspection on Mar 3, 2026

Source:

CMS, Provider Information, State and US Averages and Health Deficiencies. Released Oct 28, 2026. Updated monthly.

When those citations happened

63 citations in 6 months of the last 36. Last cited Mar 2026. Most serious: actual harm (G). The last 3 years, to Nov 5, 2026.

63 citations by month over the last 3 years. Each cell is one month.
JanFebMarAprMayJunJulAugSepOctNovDec
2023 Dec
2024 JanFebMarAprMayJunJulAugSepOctNovDec
2025 JanFebMarAprMayJunJulAugSepOctNovDec
2026 JanFebMarAprMayJunJulAugSepOctNov

Hover or focus a month to read it.

No visit on record Visited, nothing cited A stronger orange is more serious, on its source’s own levels, read onto four bands: from the least serious it publishes to the most
Source:

Hearth Record drew this from the dates and levels in the source’s own records.

All 63 citations in the last three years

Grouped by inspection, newest first. Each carries , from A, the least serious, to L, the most. 23 came from complaint inspections.

Source:

CMS, Health Deficiencies. Released Oct 28, 2026. Updated monthly.

Mar 3, 2026: standard inspection16 citations
  • Educate residents and staff on COVID-19 vaccination, offer the COVID-19 vaccine to eligible residents and staff after education, and properly document each resident and staff member’s vaccination status.

    Rule F0887. G: actual harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Ensure that residents are fully informed and understand their health status, care and treatments.

    Rule F0552. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Ensure residents have reasonable access to and privacy in their use of communication methods.

    Rule F0576. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Honor the resident’s right to request, refuse, and/or discontinue treatment, to participate in or refuse to participate in experimental research, and to formulate an advance directive.

    Rule F0578. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Give residents notice of Medicaid/Medicare coverage and potential liability for services not covered.

    Rule F0582. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Prevent the use of unnecessary psychotropic medications or use medications that may restrain a resident’s ability to function.

    Rule F0605. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Provide the required documentation or notification related to the resident’s needs, appeal rights, or bed-hold policies.

    Rule F0628. E: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • PASARR screening for Mental disorders or Intellectual Disabilities

    Rule F0645. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Provide safe and appropriate respiratory care for a resident when needed.

    Rule F0695. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Provide care or services that was trauma informed and/or culturally competent.

    Rule F0699. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Ensure therapeutic diets are prescribed by the attending physician and may be delegated to a registered or licensed dietitian, to the extent allowed by State law.

    Rule F0808. E: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Procure food from sources approved or considered satisfactory and store, prepare, distribute and serve food in accordance with professional standards.

    Rule F0812. F: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Apr 24, 2026.

  • Dispose of garbage and refuse properly.

    Rule F0814. F: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Have a plan that describes the process for conducting QAPI and QAA activities.

    Rule F0865. F: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Set up an ongoing quality assessment and assurance group to review quality deficiencies and develop corrective plans of action.

    Rule F0867. F: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

  • Develop and implement policies and procedures for flu and pneumonia vaccinations.

    Rule F0883. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Mar 31, 2026.

Mar 3, 2026: standard and complaint inspection7 citations
  • Protect each resident from the wrongful use of the resident’s belongings or money.

    Rule F0602. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Mar 31, 2026.

  • Provide enough nursing staff every day to meet the needs of every resident; and have a licensed nurse in charge on each shift.

    Rule F0725. F: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Mar 31, 2026.

  • Ensure that nurses and nurse aides have the appropriate competencies to care for every resident in a way that maximizes each resident’s well being.

    Rule F0726. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Mar 31, 2026.

  • Observe each nurse aide’s job performance and give regular training.

    Rule F0730. F: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Mar 31, 2026.

  • Ensure drugs and biologicals used in the facility are labeled in accordance with currently accepted professional principles; and all drugs and biologicals must be stored in locked compartments, separately locked, compartments for controlled drugs.

    Rule F0761. F: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Mar 31, 2026.

  • Make sure that the nursing home area is safe, easy to use, clean and comfortable for residents, staff and the public.

    Rule F0921. F: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Mar 31, 2026.

  • Ensure nurse aides have the skills they need to care for residents, and give nurse aides education in dementia care and abuse prevention.

    Rule F0947. F: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: May 1, 2026.

Feb 2, 2026: complaint inspection2 citations
  • Provide appropriate treatment and care according to orders, resident’s preferences and goals.

    Rule F0684. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Feb 23, 2026.

  • Provide and implement an infection prevention and control program.

    Rule F0880. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Feb 23, 2026.

Sep 16, 2025: complaint inspection3 citations
  • Ensure that a nursing home area is free from accident hazards and provides adequate supervision to prevent accidents.

    Rule F0689. G: actual harm. From a complaint. Correction date, as CMS recorded it: Oct 9, 2025.

  • Honor the resident’s right to a dignified existence, self-determination, communication, and to exercise his or her rights.

    Rule F0550. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Oct 9, 2025.

  • Provide enough nursing staff every day to meet the needs of every resident; and have a licensed nurse in charge on each shift.

    Rule F0725. E: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Oct 9, 2025.

Dec 12, 2024: standard inspection13 citations
  • Allow residents to self-administer drugs if determined clinically appropriate.

    Rule F0554. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Reasonably accommodate the needs and preferences of each resident.

    Rule F0558. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Honor the resident’s right to request, refuse, and/or discontinue treatment, to participate in or refuse to participate in experimental research, and to formulate an advance directive.

    Rule F0578. E: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Honor the resident’s right to a safe, clean, comfortable and homelike environment, including but not limited to receiving treatment and supports for daily living safely.

    Rule F0584. E: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Provide timely notification to the resident, and if applicable to the resident representative and ombudsman, before transfer or discharge, including appeal rights.

    Rule F0623. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Develop the complete care plan within 7 days of the comprehensive assessment; and prepared, reviewed, and revised by a team of health professionals.

    Rule F0657. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Ensure that a nursing home area is free from accident hazards and provides adequate supervision to prevent accidents.

    Rule F0689. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Implement gradual dose reductions(GDR) and non-pharmacological interventions, unless contraindicated, prior to initiating or instead of continuing psychotropic medication; and PRN orders for psychotropic medications are only used when the medication is necessary and PRN use is limited.

    Rule F0758. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Ensure medication error rates are not 5 percent or greater.

    Rule F0759. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Provide sufficient support personnel to safely and effectively carry out the functions of the food and nutrition service.

    Rule F0802. E: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Ensure food and drink is palatable, attractive, and at a safe and appetizing temperature.

    Rule F0804. E: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Procure food from sources approved or considered satisfactory and store, prepare, distribute and serve food in accordance with professional standards.

    Rule F0812. F: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

  • Make sure that the nursing home area is safe, easy to use, clean and comfortable for residents, staff and the public.

    Rule F0921. F: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 16, 2025.

Dec 12, 2024: standard and complaint inspection6 citations
  • Ensure that residents are fully informed and understand their health status, care and treatments.

    Rule F0552. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Jan 16, 2025.

  • Allow resident to participate in the development and implementation of his or her person-centered plan of care.

    Rule F0553. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Jan 16, 2025.

  • Honor the resident’s right to manage his or her financial affairs.

    Rule F0567. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Jan 16, 2025.

  • Properly hold, secure, and manage each resident’s personal money which is deposited with the nursing home.

    Rule F0568. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Jan 16, 2025.

  • Give residents notice of Medicaid/Medicare coverage and potential liability for services not covered.

    Rule F0582. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Jan 16, 2025.

  • Provide appropriate pressure ulcer care and prevent new ulcers from developing.

    Rule F0686. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: Jan 16, 2025.

Apr 17, 2024: complaint inspection5 citations
  • Reasonably accommodate the needs and preferences of each resident.

    Rule F0558. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: May 16, 2024.

  • Keep residents’ personal and medical records private and confidential.

    Rule F0583. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: May 16, 2024.

  • Honor the resident’s right to a safe, clean, comfortable and homelike environment, including but not limited to receiving treatment and supports for daily living safely.

    Rule F0584. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: May 16, 2024.

  • Ensure that a nursing home area is free from accident hazards and provides adequate supervision to prevent accidents.

    Rule F0689. D: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: May 16, 2024.

  • Provide and implement an infection prevention and control program.

    Rule F0880. E: no actual harm, potential for more than minimal harm. From a complaint. Correction date, as CMS recorded it: May 16, 2024.

Dec 19, 2023: standard inspection11 citations
  • Provide appropriate pressure ulcer care and prevent new ulcers from developing.

    Rule F0686. G: actual harm. Correction date, as CMS recorded it: Feb 9, 2024.

  • Allow residents to self-administer drugs if determined clinically appropriate.

    Rule F0554. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 22, 2024.

  • Develop and implement a complete care plan that meets all the resident’s needs, with timetables and actions that can be measured.

    Rule F0656. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 22, 2024.

  • Ensure necessary information is communicated to the resident, and receiving health care provider at the time of a planned discharge.

    Rule F0661. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 22, 2024.

  • Implement gradual dose reductions(GDR) and non-pharmacological interventions, unless contraindicated, prior to initiating or instead of continuing psychotropic medication; and PRN orders for psychotropic medications are only used when the medication is necessary and PRN use is limited.

    Rule F0758. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 22, 2024.

  • Ensure medication error rates are not 5 percent or greater.

    Rule F0759. E: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 22, 2024.

  • Ensure that residents are free from significant medication errors.

    Rule F0760. D: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 22, 2024.

  • Ensure drugs and biologicals used in the facility are labeled in accordance with currently accepted professional principles; and all drugs and biologicals must be stored in locked compartments, separately locked, compartments for controlled drugs.

    Rule F0761. E: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Feb 9, 2024.

  • Provide sufficient support personnel to safely and effectively carry out the functions of the food and nutrition service.

    Rule F0802. E: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 22, 2024.

  • Procure food from sources approved or considered satisfactory and store, prepare, distribute and serve food in accordance with professional standards.

    Rule F0812. F: no actual harm, potential for more than minimal harm. Correction date, as CMS recorded it: Jan 22, 2024.

  • Post nurse staffing information every day.

    Rule F0732. C: no actual harm, potential for minimal harm. Correction date, as CMS recorded it: Jan 22, 2024.

Is it certified, and in good standing?

  • Certified for Medicare and Medicaid since Jun 24, 1994.
  • Not on CMS’s special focus list.
  • No abuse icon from CMS.
  • No change of ownership in the last 12 months.
  • CMS lists its ownership as for profit, individual.
  • 55 certified beds.
Source:

CMS, Provider Information. Released Oct 28, 2026. Updated monthly.

Has it been fined or penalized?

  • 1 fine in the last three years, $38,961 in all.
  • 1 Medicare payment denial in the last three years.
  • 23 citations in the last three years came from complaint inspections.
Source:

CMS, Penalties and Health Deficiencies. Released Oct 28, 2026. Updated monthly.

Fines and payment denials, newest first
DateKindAmount
Feb 2, 2026Medicare payment denialNot given
Sep 16, 2025Fine$38,961

Who does the caring?

3.51 nurse hours per resident per day

The Michigan average is 4.03.

CMS publishes staffing about four months after the fact.

Source:

CMS, Provider Information and State and US Averages. Released Oct 28, 2026. Updated monthly.

Staffing measures
MeasureThis homeMichigan average
Nurse hours per resident per day3.514.03
Of which registered nurses0.770.78
At weekends3.093.50
Nursing staff turnover42.6%44.6%
Registered nurse turnover66.7%39.2%
Administrators who left2Not given

Who owns it?

  • Lighthouse at Hubbell Health LLC owns 100% directly since Dec 29, 2016.
  • 13 owners or officers are people: Benjamin T Friedman (owns 5% or more through other companies, 80%); Steven Wiener (owns 5% or more through other companies, 19%); Kelly R Fletcher (runs it (operational or managerial control)); Kelly R Fletcher (additional disclosable party (controls, leases property to, or provides services to the home)); Christian A Williams (runs it (operational or managerial control)); Benjamin T Friedman (corporate officer); Benjamin T Friedman (corporate director); Benjamin T Friedman (runs it (operational or managerial control)); Benjamin T Friedman (additional disclosable party (controls, leases property to, or provides services to the home)); Kristen Kallio (runs it (operational or managerial control)); Kristen Kallio (additional disclosable party (controls, leases property to, or provides services to the home)); Steven Wiener (corporate director); Steven Wiener (additional disclosable party (controls, leases property to, or provides services to the home)).
  • No private-equity firm among the owners CMS lists.
  • No real-estate investment trust among the owners CMS lists.
Source:

CMS, All Owners. Checked Nov 5, 2026. Updated monthly.

CMS, Provider Information. Released Oct 28, 2026. Updated monthly.

Organisations CMS lists
OrganisationRoleShareSince
Lighthouse at Hubbell Health LLCOwns 5% or more directly100%Dec 29, 2016
Lighthouse at Hubbell Health LLCAdditional disclosable party (controls, leases property to, or provides services to the home)Jun 11, 2021
Ggm Associates Inc.Additional disclosable party (controls, leases property to, or provides services to the home)Apr 1, 2024
Lighthouse at Hubbell Realty LLCAdditional disclosable party (controls, leases property to, or provides services to the home)Jun 11, 2021

How do residents fare?

  • CMS rates its quality measures 4 of 5 (Michigan average 3.9).
Source:

CMS, Provider Information and State and US Averages. Released Oct 28, 2026. Updated monthly.

CMS’s star ratings, from 1 to 5
MeasureRating
Overall rating1 of 5
Health inspections1 of 5
Staffing3 of 5
Quality measures4 of 5

How does it compare nearby?

  • Among the 12 nearest homes, within 86.4 miles, this one had the 1st most health citations at the latest inspection cycle (25; the middle value was 10).
Source:

CMS, Provider Information. Released Oct 28, 2026. Updated monthly.

The 12 nearest, by straight-line distance
PlaceMiles awayCitations, latest cycle
Greentree of Hubbell Rehabilitation and Health This nursing home25
Portagepointe7.98
Mission Point Nursing & Physical Rehabilitation Ce8.315
Canal View - Houghton County8.75
Bayside Village28.222
Marquette County Medical Care Facility59.91
Eastwood Nursing Center60.08
Norlite Nursing Center65.113
Dj Jacobetti Home for Veterans65.35
Iron County Medical Care Facility74.67
Iron River Care Center75.412
Florence Health Services86.424

What the record doesn’t say

  • Complaints that didn’t lead to a citation aren’t published.
  • Inspections reach CMS’s data about six weeks after they happen, and staffing about four months after.
  • CMS publishes the inspectors’ full written findings in a separate monthly file, which isn’t loaded yet.
  • Fines and Medicare payment denials are the only enforcement CMS publishes; state licence actions aren’t included.

Sources

  • Centers for Medicare & Medicaid Services, Provider Information (4pq5-n9py).

    Released Oct 28, 2026 and checked Nov 5, 2026. Updated monthly. Public domain (U.S. Government work).

  • Centers for Medicare & Medicaid Services, Health Deficiencies (r5ix-sfxw).

    Released Oct 28, 2026 and checked Nov 5, 2026. Updated monthly. Public domain (U.S. Government work).

  • Centers for Medicare & Medicaid Services, Penalties (g6vv-u9sr).

    Released Oct 28, 2026 and checked Nov 5, 2026. Updated monthly. Public domain (U.S. Government work).

  • Centers for Medicare & Medicaid Services, All Owners (afe44b85-cc6d-40d7-b5df-00ae8910d1d2).

    Checked Nov 5, 2026. Updated monthly. Public domain (U.S. Government work).

  • Centers for Medicare & Medicaid Services, State and US Averages (xcdc-v8bm).

    Released Oct 28, 2026 and checked Nov 5, 2026. Updated monthly. Public domain (U.S. Government work).

If you believe something here is wrong, a correction starts with the agency whose record this copies: CMS. CMS’s own record is on Care Compare. If Hearth Record copied something wrongly, it will fix it and log the correction publicly, with its date: how corrections work.

Source:

This copy of the record was made on Nov 5, 2026.

From the home

The public record above comes first. Anything the home adds will appear here, below it, and say who wrote it.

Replies

None. Replies aren’t open yet. When they open, the home will be able to answer any finding for free, and the reply will show beside that finding, unedited and dated.

Paid listing

None. Paid listings aren’t open yet. When they open, anything paid for will say “Paid by the home”, and paying will never change a finding, a rating or the order of results.

How to read a record

Four things every record does, shown on an example record made up for this guide.

An example record, made up for this guide

An example nursing home

Made up for this guide: no real place is shown

Not fully inspected in over two years (CMS flag)

11 health citations at the latest inspection cycle

The state average is 14.3.

Source:

CMS, State and US Averages and Health Deficiencies. Released Oct 28, 2026. Updated monthly.

From the homeNone yet. Replies and paid listings aren’t open, and when they open they will sit here, below the record.

1 of 4

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Who published it, when, and how often it changes sit beside each fact, with a link to the agency’s own file.

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