What is the current state of the law on the burden of proof in sentencing based on hearsay statements in the presentence report?

For example, the majority points to United States v. Weston, 448 F.2d 626 (9th Cir. 1971), as "stand[ing] for the proposition that if the sentencing process effectively puts the burden of proof on the defendant to refute a damaging hearsay allegation, particularly when the factual basis for believing such a charge is practically nonexistent, that process is legally flawed." Majority op. 23. But, as the majority acknowledges, the reason we were concerned about putting the burden on the defendant in Weston to refute the hearsay statements in the presentence report is that we doubted the statements' substantive reliability: "the factual basis for believing the charge was almost nil." 448 F.2d at 633. in other words, the government had failed to produce substantive indicia of reliability to support the hearsay statements, instead leaving it to the defendant to refute them. We vacated the sentence and forbid the district court from relying on the presentence report on resentencing "unless" the government "amplified [it] by information such as to be persuasive of the validity of the charge there made"-i.e., unless the government produced substantive indicia of reliability. Id. at 634. We did not suggest that reviewing the sentencing hearing but applying the correct burden of proof would suffice.