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The Latest Wrinkle October 13, 2017
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PACE Policy Update


The Medical Services Administration (Michigan’s Medicaid Program) last month issued a proposed policy identifying new guidelines for PACE organization application criteria in Michigan. This new policy includes for-profit organizations in keeping with recent regulatory changes in the program by CMS.

PACE programs serve a critical role for high-need Michigan consumers who want to remain in the community. It is the only model that deeply integrates medical care with functional care needs and thus when operating well provides positive consumer outcomes.

PACE has proliferated across the lower part of Michigan over the past ten years. Currently, there are 11 PACE organizations using 15 alternative sites (one has yet to open). However, just over 60% of slots are filled as of September 2017. It is our belief that many persons could be well served by PACE programs. It is critical that the Department evaluate fully all of the barriers to enhance potential enrollment.

LeadingAge Michigan believes that comprehensive ongoing evaluation by the Department is critical to both consumers and the providers who serve them. As with any program that provides some home based services to vulnerable adults, we must ensure that we are adequately meeting needs. PACE participants must meet the Michigan Nursing Facility Level of Care in order to qualify, as do MI Choice participants. PACE participants are extremely vulnerable simply on the basis of these characteristics.

Historically, PACE regions in some Michigan areas have been quite large geographically. It is important that any new statewide policy ensures that organizations have appropriate regional partners and can address services within the local community. LeadingAge Michigan will continue to review and monitor PACE policy and program development in Michigan.


PACE – Skilled Care Contracting


Are PACE organizations required to contract at your Medicaid rate for care? Should your rate include an amount equal to the QAS?

No; under present interpretation PACE organizations are full risk managed care entities and as such are free to negotiate reimbursement rates with their providers. With such management entities, the state generally does not dictate provider rates though Medicaid rates do often serve as a benchmark.

However, when considering the recognition of the QAS component in your contracted daily rate members should recognize the PACE rate setting formula already incorporates QAS funds into the PACE Medicaid Rate. Therefore, LeadingAge Michigan members may want to review their contracts to be sure they are being fairly compensated for their QAS.


PACE - SNF Days of Care


LeadingAge Michigan members need to be thoughtful when accounting for the days of care related to a PACE admission. Nursing home days for PACE residents should be categorized based upon the types of services being offered to the consumer when admitted. For example, if a resident presents needing more rehab or complex nursing type services days of care should be reported under the Medicare ICO PACE Inpatient days. If a resident presents as a more traditional long-term stay consumer days of care should be reported under the category of Medicaid ICO & PACE Inpatient days. The following presents categories on the cost report for reporting of payer sources:

  • Medicare – ICO & PACE Inpatient days
  • Medicare – HMO Inpatient
  • Medicare – Traditional Inpatient
  • Medicaid – ICO & PACE Inpatient days
  • Medicaid – Routine Care
  • Medicaid – Healthy Michigan
  • Medicaid – Managed Care is considered a “regular” routine day, no special category.

Advocacy


Nurse Aides Reciprocity


Michigan Senate Bill 286 sponsored by Senator H. Hopgood (D- Wayne County) was voted out of the Health Policy Committee on Tuesday of this week. The bill amends the Public Health Code providing for training and registration of nurse aides as well as granting registration to applicants from another state in certain instances. Additionally, the bill cleans up other outstanding process concerns of nurse aides held by Department of Licensing and Regulatory Affairs (LARA).

This bill will now move to the Senate floor for approval and then on to the Michigan House of Representatives. Assuming it receives approval in the House it will then move to the Governor’s office for signature.


Senate Bill 378 – Unlicensed Assisted Living


On Wednesday of this week the House of Regulatory Reform Committee voted out Michigan Senate Bill 378 inclusive of the substitute amendments allowing for an exemption from licensure under certain conditions.

This bill will now return move to the House floor and then back to Senate for concurrence, due to some amendments from the original. Assuming concurrence in Senate the bill will then move to the Governor’s desk for signature into law.


PA 104 0f 2015 - SNF Inspection Reform


At the LeadingAge Michigan Regulatory Day in May, Licensing Manager Matt Jordan announced a new process that would limit the number of annual inspections for health facilities. What does all this mean? Michigan’s skilled nursing facilities will be able to apply for a waiver from the Michigan licensure survey process. This waiver, if approved, will allow a facility’s most recent certification survey to stand in the place of a state licensing visit. Since certification surveys are required to occur in the preceding 9 to 15 months, in theory, providers could soon receive inspections twice every three years. The Department is now finalizing their operational processes, and LeadingAge Michigan will pass along any updates as they occur.

Across the Continuum


Join us for the 2017 MI Night Out in NOLA


Join your Michigan friends and colleagues for a fun evening of socializing and camaraderie, a taste of acclaimed classic New Orleans cuisine (best muffulettas in town) and a glass (or two) of fabled signature Pimm's Cup aperitif at the Napoleon House. This 200 year old landmark, rated among the highest historically significant locations in New Orleans, intended as a residence for Napoleon Bonaparte after his exile, is as charming and unique as its French Quarter surroundings.

When: Monday, October 30th 
6:30 p.m. - 9:00 p.m. 

Where: Napoleon House 
500 Chartres Street, New Orleans LA 70130

Member Cost: $85 per person

Click here to reserve your spot!
If you are interested in becoming a Sponsor, click here.

With questions contact Kasia Roelant, Member Relations Director, at Kasia@LeadingAgeMI.org


Regional Meetings - You're Invited

Join us for a morning of conversations, association updates and policy discussions that are occurring around the state.

During the month of November we will be coming to a location near you. Check the listing below to find out when we will be visiting your neighborhood!

 

Agenda

 
  9am - 10am Networking Breakfast  
  10am - 12pm Association Update  
  12pm - 12:30pm Optional Community Tour

 


 

Dates & Locations

 
  Southeastern Region
Thursday, November 16th
Marycrest
Livonia
Click Here to RSVP
Northern Region
Tuesday, November 21st
Grand Traverse Pavilions
Traverse City
Click Here to RSVP
 
  Central Region
Tuesday, November 28th
Vista Grand Villa
Jackson
Click Here to RSVP
Western Region
Thursday, November 30th
Beacon Hill at Eastgate
Grand Rapids
Click Here to RSVP

 

 
With any questions, contact Kasia Roelant at Kasia@leadingagemi.org or 517-323-3687


Senior Services Receives NCQA Accreditation


LeadingAge Michigan has received word from Senior Services of Southwest Michigan that they have received accreditation from the National Committee for Quality Assurance (NCQA). After engaging in a two-year long process leading to an on-site review process in August, Senior Services just received notice of its accreditation from the NCQA. Senior Services is a member of Senior Care Resources (SCR) and John Grib, the Director of Community and Clinical Services, is a member of the SCR Board of Managers. John and his team have been vocal activists for the vertical integration of long term supports and services and as such have been working diligently with providers across the continuum of care in southwest Michigan for many years. Congratulations Senior Services!


Michigan Physical Health-Behavioral Health Coordination Initiative


The Michigan Department of Health and Human Services is moving forward with the next steps for its Section 298 Initiative, the statewide effort to coordinate physical and behavioral health services as directed by the legislature in Public Act 268 of 2016. The legislature revised Section 298 in Public Act 107 of 2017, which directs the Department to develop and implement up to three pilots and one demonstration model to integrate physical and behavioral health.

MDHHS will work with willing Medicaid Health Plans and a willing Community Mental Health Service Provider in Kent County, as well up to three pilot projects to achieve full financial integration of physical and behavioral health services. The Michigan Public Health Institute was selected as the project facilitator for the project, and the University of Michigan was selected as the project evaluator. More information can be found by clicking on this link.


Reminder! Register for Modernizing the Continuum of Care Training


The Michigan Department of Health and Human Services (MDHHS) issued a notice to Nursing Home and Hospice providers announcing training dates at locations across the state on the Modernizing the Continuum of Care (MCC) Initiative. Be sure to register for this important training so staff will be informed on changes impacting Medicaid eligibility and payment processes in the near future.

Information about the training sites and registration for training is available on the Medicaid Provider Training webpage.

Information about MCC was previously discussed in The Latest Wrinkle with a link to pertinent proposed policy changes issued by MDHHS. Those proposed policies (1717-MCC, 1718-MCC, 1719-MCC) can be found through this link.


Join us for a Free Demo Webinar - Compliance Made Easier


See the variety of tools and resources available through The Compliance Store.
Tuesday, October 17th at 2 pm EDT - To register, click here.

To learn more about how this partnership can help you and your organization efficiently and successfully navigate the complexities of the ever changing long-term care regulatory environment, contact Kasia Roelant at Kasia@LeadingAgeMI.org or 517-323-3687


Home and Community Based Services


Hospice Administrative Rules


Effective September 28, 2017, Michigan adopted revised administrative rules for Hospice and Hospice Residences, a project that was initiated in 2015. Click Here to see a copy of that final rule (2015-069LR).


Skilled Nursing


Medicaid Rate Letters Issued


Medicaid rate letters for states’ fiscal year 2018 were issued to providers via File Transfer on September 27, 2017. A memo was issued to all providers via File Transfer to notify them of the rates letters being issued. In addition to the rate letters, the Quality Assurance Supplement (QAS) Payment Notice effective for payments beginning on October 26, 2017 was also issued. These notices are available to all providers via MILogin and the CHAMPS application. The documents are located under “Archived Documents” for each provider.

Questions regarding your provider-specific rate calculation or the QAS payment notice calculation should be directed to the LTC Reimbursement and Rate Setting Section at DARS@michigan.gov or you may call (517) 335-5356.

Please note that it is important that rate letters be shared with any managed care organizations (Medicaid Health Plans and Integrated Care Organizations) with which you are contracted so that your new rates can be loaded into their systems as soon as possible.


CMS Reports Improvement in Anti-Psychotic Use


 Last week, CMS updated its reports on reducing the national prevalence of antipsychotic use in long stay nursing home residents. It has announced a new goal of an additional 15% reduction by the end of 2019 for those facilities with limited reduction rates to date. Michigan has historically been a comparatively low user of antipsychotics in nursing homes and ranks number 7 across the nation with a 12.7 percent usage rate.


OIG Studies Nursing Home Complaints


 Recently the HHS Office of the Inspector General issued an update to its series on Nursing Home Complaints. Their September 2006 OIG report identifies state compliance with complaint investigations between 2011 and 2015. Nine states ranked highest for the number of complaints per thousand residents – and Michigan was included in that group. The OIG chart indicating complaint trends in Michigan is noted below.
   
Michigan  2011  2012  2013  2014  2015
Number of Complaints Per 1,000 Michigan Nursing Home Residents  31.5 37.1 48.4 58.4 73.7
 
Number of Immediate Jeopardy Complaints  89 112 114 118 110
Number of Immediate Jeopardy Complaints Not Investigated Within 2 Days  3 3 2 3 2
 
Number of High Priority Complaints  1182 1342 1650 1842 2241
Number of High Priority Complaints Not Investigated Within 10 Days** 320 582 748 40 70

**State did not conduct an investigation for 2 high priority complaints between 2011 and 2015


Updated Medicaid Rates Setting Reimbursement Limits Posted


Updated information on the Medicaid Rate Setting Reimbursement Limits is posted on the Michigan Department of Health and Human Services website. Members may view updated information on the variable cost limits used for rate setting, the rate setting plant cost limits, and the hospital leave day rates by clicking here.


Medicaid Nursing Facility Policy Workgroup Meeting

The Medicaid Nursing Facility Policy Workgroup met on September 27, 2017. This workgroup meets on a bi-monthly basis to receive policy updates from the Medicaid program and to address policy issues of concern to Medicaid providers. Pertinent updates provided by Medicaid include:

  • The Healthy Michigan Plan will continue based on the most recent failed effort to repeal the Affordable Care Act and a renewal waiver application has been issued for public comment. See the additional article in this issue of The Latest Wrinkle for more information.
  • The SIGMA project, discussed in previous editions of The Latest Wrinkle, was implemented to replace MAIN. This resulted in payments in pay cycle 40 being delayed until pay cycle 41 on October 12, 2017. More information can be found here.
  • New Guardianship fees were effective October 1, 2017. The new the guardianship fee in Michigan is now $95 per month.
  • Quality Measurement (QM) Initiative – The Medicaid program has submitted the required State Plan Amendment (SPA) to the Centers for Medicare and Medicaid Services (CMS) for approval of the initiative that will reimburse additional QAS funds based on performance in the QM portion of the 5 Star ratings. CMS has 90 days in which to approve, deny, or ask additional questions of the state regarding the SPA. The initiative will not be implemented until the SPA is approved, although the starting date of October 1, 2017 is preserved with the SPA submission.
  • Audit, Cost Reporting and Reimbursement Updates – As noted above, rates were established and released for FY18.

The next Medicaid Policy Workgroup meeting is scheduled for November 29. If you have concerns you would like to have raised, please contact Susan@leadingagemi.org.


Medicaid Nursing Facility Policy Workgroup Meeting


On September 28, 2017, the Michigan Department of Health and Human Services (MDHHS) issued a notice to nursing facility providers advising them of a revised Medicaid Enrollment Checklist for new providers or those undergoing a change in ownership. The revised form can be found by clicking here.


Long Term Care Survey Process released by CMS


The Centers for Medicare and Medicaid Services (CMS) recently released a new procedure guide for the long term care survey process. The attached procedure is a broad overview of the key onsite parts of the survey process: sample selection, entrance protocol, investigation and other survey activities and potential citations. The policy for including complaints and facility-reported incidents with the standard survey and enforcement considerations is included at the end. Though this document is meant primarily for the surveyor’s purpose, it certainly benefits providers as it sheds light on what surveyors are focusing on.


MDS Version 1.15.1


Coding accuracy has never been more important for purposes of resident care planning, focused surveys and reimbursement considerations. Revisions to the Resident Assessment Instrument 3.0 and Minimum Data Set (MDS), and coding instructions for three new items are available here. Some of the revisions include definition clarifications, various coding instructions, tips and examples to section GG (Activities of Daily Living Assistance), the urinary tract infection, skin conditions and antipsychotic medication review sections. Member attention to new item P0200 provides definitions and assessment directions for coding alarms to help you identify when it meets the criteria as a restraint.


State Nursing Home Administrative Rules


A comprehensive rules revision project is underway to review six rule sets for the purpose of focusing on core principles and standards of Michigan licensing of health facilities, fulfilling statutory requirements, comporting with current practice standards, harmonizing with federal laws and regulations, negating redundant, obsolete, and unnecessary language and not repeating state or federal law. The workgroup assembled to review and provide recommendations to the Steering Committee designated by the Bureau of Community and Health Care Services regarding the nursing home administrative rules wrapped up this week. Many thanks for all the time and valuable input received by members and associates in helping to draft the language revisions. The next steps include sending the work to the Steering Committee for approval and then on to the legislative review process allowing another opportunity to voice support or opposition.


Free of Medication Error Rates of 5% of More; FTAG 759


In the upcoming Appendix PP revisions that become effective 11/28/17, FTAG 759 indicates that the crushing and mixing of a resident’s medications may result in a citation. The standard of practice is that crushed medications should not be combined and given all at once, either orally (e.g., in pudding or other similar food) or via feeding tube. Crushing and combining medications may result in physical and chemical incompatibilities leading to an altered therapeutic response or cause feeding tube occlusions when the medications are administered via feeding tube. Guidance in Appendix PP provides that if the surveyor observes medications being crushed and combined, then the number of errors would be equal to the number of medications crushed whether the medications are to be administered orally or via feeding tube. For example, if four medications were crushed and added altogether to applesauce or combined to be administered all at once via feeding tube, then four errors have occurred before the medications have been administered. You are encourage to become familiar with the all the Critical Element Pathways which can be accessed by clicking here.


Housing


DUNS Number Required on All Voucher Submissions


This is a reminder that effective December 1, 2017, vouchers not containing an active Dun & Bradstreet’s (DB) Data Numbering System (DUNS) Number will generate a Tenant Rental Assistance Certification System (TRACS) fatal error and payment will not be issued until corrected. Attached is the memorandum dated June 2, 2017 that implements the requirement to include the DUNS numbers on all vouchers submitted to Tenant Rental Assistance Certification System (TRACS). For technical support questions regarding a DUNS number, contact the SAM Federal Service Desk at 1-866-606-8220.


MSHDA QAP Information Hearing

The Michigan State Housing Development Authority (MSHDA) will hold an Information Hearing to take comments and recommendations from the general public on possible modifications to the Qualified Allocation Plan (QAP) for 2019-2020. The information received will be made available to the public prior to the public hearing planned in the spring of 2018. Individuals Written comments may also be submitted to Chad Benson, the Allocations Manager with MSHDA, at P.O. Box 30044, Lansing, MI 48909 or connect with LeadingAge via lfunsch@leadingagemi.org who will facilitate any of your comments/recommendations on your behalf.


Federal Funding of Housing Update Video


Hot off the digital microphone: LeadingAge’s newest QuickCast, Update on Federal Funding for Housing Programs Serving Older Adults. This is 8 minutes of information and insight on the latest in HUD funding. Linda Couch, LeadingAge’s Vice President of Housing Policy, provides the latest on fiscal 2018 funding by both the House and Senate for housing assistance programs, the expansion of preservation tools for Section 202 communities, when a final funding bill may be seen as well as the latest data on the housing needs of older adults. Click here for access to the video.


Low Income Housing Tax Credit Funding Round Applicants


Michigan State Housing Development Authority (MSHDA) has posted the list of applicants for the October 2, 2017 LIHTC Funding Round to the "2017 Funding Round Information" page.


Additional Updates to Handbook 4350.1 Posted for Review


An additional draft chapter of the “Multifamily Asset Management and Project Servicing” HUD Handbook 4350.1 has been posted to the “Multifamily Policy Drafting Table” for a 30-day review period. The handbook serves as a resource for staff, industry partners, and owners and agents. To access the following newly posted chapter 2.03 - Insurance and Loss Drafts, use this link visit the HUD website.

LeadingAge urges you to review this 40-page chapter which outlines procedures for HUD to monitor owner compliance concerning maintenance of insurance and instructions to process loss settlement drafts issued in settlement of insurance claims. This chapter describes some of the possible forms of coverage. Comments are due to HUD by November 3. However, LeadingAge would like to have your comments no later than October 23 in order to be compiled and submitted in a timely manner.


Member Value


Emergency! Prep Time


 In the shadow of devastating events such as the recent earthquake in Mexico, hurricanes Harvey and Irma, and now wildfires in California, McKnight’s has published an article regarding emergency preparedness in the long-term and post-acute fields. See here for the full article by Meg LaPorte in the October 6, 2017 issue with quotes from LeadingAge’s Director of Health Regulations and Policy, Janine Finck-Boyle.

When it comes to emergency preparedness, seemingly mundane things can be easy to forget but also are important. To assist, HD Supply has created a resource for its customers with an emergency preparedness mini-catalog that includes everything from pallets of water to signage and generators.

HD Supply is a frequently utilized Value First vendor by our members. If you are not set up with our GPO pricing, please reach out to Rob Ervin at Rob@leadingagemi.org to learn more.

   

Education Center


ATTN: Administrators & Health Care Professionals
Are you a licensed nursing home administrator in need of continuing education hours by October 31st for your license renewal? Did you know pain and symptom management and human trafficking education are now requirements for renewal?

We've got the programs you need to support the Nursing Home Administrator General Rules. R 339.14031 (7) states that an applicant for license renewal shall complete in each renewal period not less than two (2) continuing education hours in pain and symptom management (effective December 2014) and R 339.14002 states the training standards for identifying victims of human trafficking requirements (effective 2016).

Making Pain Management Less Painful
Live Webinar ~ October 17
9:30 a.m. to 11:30 a.m. 

Pain is now considered the 5th vital sign by many. Understanding the symptoms and managing pain can take many forms. This 2-hour, live webinar will explore pain, different perspectives for pain management and how to effectively assist people that are in pain.
Click Here for more information and to register.

Human Trafficking for Aging Services Providers
Live Webinar ~ October 24
9:30 a.m. to 11:30 a.m.

This webinar will provide an overview of Homeland Security Investigations and its broad investigative authority. Learn about the types of victims, red flag indicators and strategies for identifying and responding to human trafficking focusing on the vulnerabilities of potential victims and the response from those who encounter victims of labor and sexual exploitation. We will also address how the aging services industry could possibly be utilized in both types of trafficking.
Click Here for more information and to register.

All health care professionals are welcome to join the webinars.
You must be the registered attendee to receive continuing education credit.


SNF Mega Rule-Phase 2 & Interpretive Guidance
Live Webinars, 6-Part Series ~ October 25 thru November 16

On June 30, 2017, the Centers for Medicare and Medicaid Services (CMS) released their revision to the State Operations Manual – Appendix PP (the interpretive guidance) for the Phase 2 Requirements for Participation (RoPs) that become effective on November 28, 2017. The Phase 2 RoPs include changes that are significant, require additional guidance, and re-numbering of the F-Tags. This revision includes 203 new F-Tag numbers of which 49 of them have been declared as potential substandard quality of care if deficient practice is determined with scope/severity levels of F, H, I, J, K or L. Due to the enforcement issues associated with that level of care designation, LeadingAge Michigan is planning a special 6-part live webinar series focusing on those 49 F-Tags.

Click Here for more information or to register


Nurse Aide Train-the-Trainer
November 13 ~ Okemos

The Train-the-Trainer workshop is a program for registered nurses who are interested in becoming qualified instructors for Nurse Aide Training Programs with the State of Michigan. The workshop is designed to provide learners the components of a nurse aide training program, the basic Federal requirements for a nurse aide program.

Click Here 
for more information and to register.


Leadership Academy 2018

The academy is designed to equip new and emerging leaders with the essential insights, knowledge, and skills to directly improve leadership effectiveness.

The academy integrates adaptive and technical learning for a comprehensive training experience. We will focus on what it takes to be a successful and effective leader in today's workplace; specifically within the aging services industry. Each class will provide unique, thought-provoking, opportunities for dialogue with aging services coaches, mentors, and executives. The academy will cultivate your leadership excellence, develop your leadership potential, and assist you in making a positive impact within your organization.

We encourage applicants from various positions, disciplines, experience, industry knowledge, and companies of different sizes to ensure a vibrant exchange of ideas and discussion. The academy is for high-potential professionals who want to learn to become better managers and leaders.

2018 Academy brochure and application coming soon!
For more information ~ please contact the Association at 517-323-3687.


MDS RAC Certification Workshops 2018
To be offered in Southeast, West and Central Michigan locations.

Did you know you can become RAC Certified in just three days?

LeadingAge Michigan, in partnership with the American Association of Nurse Assessment Coordination (AANAC), is pleased to offer the highly esteemed Resident Assessment Coordinator-Certified (RAC-CT) a certification program for long-term care professionals. This workshop is designed to increase knowledge of clinical assessment and care planning, completion of the MDS, and the regulations surrounding the RAI/MDS process. Earning the RAC-CT designation gives you the credentials to prove your assessment expertise; making you an invaluable asset for your facility, your residents, and the long-term care profession.

Workshops will be offered again in 2018. Watch for more information coming soon.


LEAN Leadership Concepts 2018
Lean is a system for making improvement that can be applied to any aging services provider. Leaders and staff members performing the same process day after day can become blind to the inherent problems with that process. Using a Lean approach will aid in the identification of problems and provide the necessary tools to make sustainable process improvements. Many organizations solve problems by jumping to solutions before thoroughly understanding what problem they are trying to solve and/or not fully understanding the root cause of the problem. As a result, the solutions typically don’t work or are unsustainable. Most of the time it is impossible to know if the solution worked because results were not measured. Lean is often thought of as a tool for the frontline worker. In reality, the most effective Lean organizations start with leadership modeling the right behaviors which facilitate the desired culture of improvement. Using Lean leadership concepts will allow you to become a learning organization with a methodical system for process improvement and measured results.

More information and registration coming soon!


Mark Your Calendars!

2017 National Annual Meeting & Expo
October 29 - November 1, 2017 ~New Orleans, LA
Michigan Night Out - Monday, October 30th - Napoleon House

2018 Annual Conference & Trade Show
Join us for our 50th Anniversary Celebration!

May 20-23, 2018 ~ Suburban Collection Showplace, Novi

2018 Annual Leadership Institute
August 22-24, 2018 ~ Mission Point Resort, Mackinac Island


Thank You Content Contributors!


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Lansing, MI 48933
Phone: 517-323-3687
Fax: 517-323-4569

Our Mission: To advance the mission of our members to enhance the lives of seniors.
Our Vision: To become the voice of aging services in Michigan.

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