Quote Originally Posted by Liverpooldawg View Post
Most of the first NOA is also under the new matrix. If I remember right, and they have been accused of SO much I might not have it right, the only stuff that falls under the old one is the ACT fraud stuff with Saunders.
Liverpool, I think the difference is the amount of infractions. Louisville had one Level 1 and Mississippi has 15, Mississippi has admitted in their response that some of these infractions happened as the investigation was going on. This in itself is the definition of Lack of Institutional Control, which should raise all of the Level 1's to aggravated status.
While some of the infractions happened before the new punishment matrix was put into place. Mississippi continued to break regulations in the face of continuing investigations, The COI at this point has no other option, but to hand down the harshest penalties.