DHS put out some proposed / interim revised rules around 15 June 2006 that clarified this issue. In general, the revised rules do not require that an employer maintain supporting documentation. The interim / proposed rule is here: http://tinyurl.com/v3obb You may want to take a look at this report from my employer: http://www.hewittassociates.com/Intl/NA/en-US/KnowledgeCenter/LegislativeUpdates/LegislativeUpdatesDetail.aspx?cid=2910 Patrick Cunningham, CRM List archives at http://lists.ufl.edu/archives/recmgmt-l.html Contact [log in to unmask] for assistance