Mallinckrodt's "second Chapter 11 plan was confirmed on October 10, 2023." The Order notes that Mallinckrodt's Annual Report for 2018 and Quarterly Report for the First Quarter of 2019 "contained material misstatements and omissions." There was no disclosure of the magnitude of the loss contingencies inherent in the CMS claims "that Mallinckrodt was underpaying Medicaid rebates on sales of Acthar." The Commission pointed out that "[u]nder… GAAP [the Accounting Standards Codification for loss contingencies] a public company is required to disclose material loss contingencies that are reasonably possible."