In 1996, the Health Insurance Portability and Accountability Act included various changes to the tax treatment of people who give up US citizenship. First, it defined concrete criteria to determine whether an ex-citizen or ex-permanent resident was a "covered expatriate" presumed to have given up US status for tax reasons, based on the person's income and assets, or inability to certify compliance with their tax filing and payment obligations for the past five years (). Second, it required the Department of the Treasury to "name and shame" people who give up US citizenship by listing their names in the Quarterly Publication of Individuals Who Have Chosen to Expatriate in the "Federal Register" (. The list does not appear to contain the names of all people who give up US citizenship, though tax lawyers disagree whether that is because the list is only required to contain "covered expatriates", or due to bureaucratic errors or other reasons. Names of those renouncing in the last months of the year will mostly appear on the list before they have filed IRS form 8854 establishing covered or non-covered status, so it does not seem possible that the list is only required to contain covered expatriates.