appropriate and nondiscriminatory use of the System. (10) Annual report and certification Not later than 18 months after the promulgation of regulations to implement this subsection, and annually thereafter, the Secretary shall submit to Congress a report that includes the following: (A) An assessment, as submitted to the Secretary by the Inspector General of the Department of Homeland Security pursuant to paragraph (8)(C)(iii)(I), of the accuracy rates of further action notices and other System notices provided by employers to individuals who are authorized to be employed in the United States. (B) An assessment, as submitted to the Secretary by the Inspector General of the Department of Homeland Security pursuant to paragraph (8)(C)(iii)(I), of the accuracy rates of further action notices and other System notices provided directly (by the System) in a timely fashion to individuals who are not authorized to be employed in the United States. (C) An assessment of any challenges faced by small employers in utilizing the System. (D) An assessment of the rate of employer noncompliance (in addition to failure to provide required notices in a timely fashion) in each of the following categories: (i) Taking adverse action based on a further action notice. (ii) Use of the System for nonemployees or other individuals before they are offered employment. (iii) Use of the System to reverify employment authorized status of current employees except if authorized to do so. (iv) Use of the System selectively, except in cases in which such use is authorized. (v) Use of the System to deny employment or post-employment benefits or otherwise interfere with labor rights. (vi) Requiring employees or applicants to use any self-verification feature or to provide self-verification results. (vii) Discouraging individuals who receive a further action notice from challenging the further action notice or appealing a determination made by the System. (E) An assessment of the rate of employee noncompliance in each of the following categories: