# Medicaid



Iowa Privatized Medicaid: It Has Been A Disaster. Here’s Why.

By Simon Davis-Cohen for Tarbell.org

This is a reprint from Tarbell.org, a news website pioneering journalism that reveals who runs America and empowers readers with solutions. Read this on Tarbell.org.

If you have any feedback on this piece, please contact Tarbell’s engagement editor, Danielle Keeton-Olsen, at danielle@tarbell.org.

In 2016, Iowa privatized Medicaid under then-Governor Terry Branstad. He was a founding member of the American Legislative Exchange Council (ALEC). “Obamacare” is often attacked by the David and Charles Koch-backed group that opposes government action in health care or the economy.

Branstad claimed outsourcing Medicaid would save the state and taxpayers money. However, Iowa has not been able to provide any data that shows privatization saved the state money. In fact, privatization is now costing Iowa money. (Branstad resigned the governorship in 2017 to become the U.S. Ambassador to China.)

Continue Reading...

Elizabeth Warren is running to do the job

Dubuque Democrat Rachel Wall didn’t plan to commit to a candidate this early but “lost my own bets with myself” after seeing Elizabeth Warren in person last month. -promoted by Laura Belin

I will preface this piece by stating my only commitment for the 2020 cycle was to caucus for a woman. Some may say that is blind feminism, but it is the promise I made to myself. In order to normalize women running for all offices, I made that pledge.

Continue Reading...

An army of misery forced to decamp with UnitedHealthcare's departure

John Morrissey is a longtime Des Moines resident who has investigated state spending increases, financial anomalies, and payment disruptions associated with Medicaid privatization in Iowa. -promoted by Laura Belin

The “he said/she said” controversy between an insurance company CEO and Iowa’s governor about why UnitedHealthcare decided to leave the state’s Medicaid program might make entertaining copy, but it doesn’t address who is going to manage the care of 420,000 Iowans left in the lurch.

Nor does it address whether the remaining company (Amerigroup) is adequately prepared to handle more members, and whether a new player poised to enter our state’s Medicaid market (Iowa Total Care) has the expertise to handle special populations in Iowa such as the elderly, disabled, and very ill.

It also doesn’t consider whether the state’s traditional fee-for-service Medicaid offering has the financial wherewithal to shoulder an even larger share of the enrollment and cost. Fee-for-service was held over from the old state-run program when most of the Medicaid program was privatized in 2016. The fee-for-service program pays the claims of Iowa’s sickest and most frail Medicaid members, which the for-profit managed care organizations (MCOs) don’t want or can’t handle.

The Iowa Deparment of Human Services (DHS) did not respond to a request for comment on these issues.

Continue Reading...

Where things stand with Republican bills targeting Iowa workers

Republican attacks on working Iowans have received less attention this year than in 2017, when new laws shredded public employee collective bargaining rights, blocked local governments from raising the minimum wage, and reduced workers’ compensation benefits, especially for those who hurt their shoulder on the job.

But below the radar, GOP lawmakers have moved several bills lately that would make life harder for working people, including some facing the difficult circumstances of unemployment or workplace injury.

Continue Reading...

The 2007 votes that made 2019 a historic year for transgender Iowans

Only three months in, 2019 is already the most significant year for transgender equality in Iowa since 2007, when state lawmakers and Governor Chet Culver added sexual orientation and gender identity to the list of protected classes in the Iowa Civil Rights Act. That 1965 law hadn’t been significantly amended in decades.

The crucial Iowa House and Senate votes on the civil rights law happened during the first year since the 1960s that Democrats controlled both legislative chambers and the governor’s office. Support for LGBTQ equality is often taken for granted now in Democratic circles, but the issue was seen as more politically volatile twelve years ago. The bill amending the civil rights act came late in the 2007 legislative session and could not have passed without some Republican votes.

Continue Reading...

State auditor to Iowa Medicaid recipients, providers: "Know your rights"

Iowans affected by UnitedHealthcare’s impending exit as a Medicaid managed-care provider should be aware that they have rights under the contract the state signed with the insurer, State Auditor Rob Sand announced at an April 1 news conference.

Sand reviewed the company’s 287-page contract with the Iowa Department of Human Services before news broke on March 29 that UnitedHealthcare will not continue to manage care for Iowans on Medicaid in the coming fiscal year, which begins on July 1. That development suddenly made the contract’s termination provisions “very important and relevant.”

Continue Reading...

Laughable spin casts Reynolds as hero of latest Medicaid fiasco

When a government press release arrives at 4:45 pm on a Friday, you know it’s not bearing good news. UnitedHealthcare will soon pull out of Iowa’s Medicaid program, the governor’s office announced on March 29. The company “manages health care for more than two-thirds of Iowans on Medicaid,” at least 425,000 people, Tony Leys reported for the Des Moines Register.

The official spin portrayed Governor Kim Reynolds as a hero who resisted a for-profit insurer’s “unreasonable” and “unacceptable” demands.

The real story is that nearly three years into our costly Medicaid privatization experiment, Iowa’s dominant managed-care organization (MCO) still can’t handle normal business practices like paying health care providers on time.

Continue Reading...

Senate ignores deadbeat corporations while targeting Iowans on Medicaid

Matt Chapman closely follows Iowa legislative happenings, including bills affecting Iowans on public assistance. -promoted by Laura Belin

Iowa Senate Republicans on March 19 approved new work requirements for tens of thousands of Iowans on Medicaid or receiving food assistance. Senate File 538 would instruct the Iowa Department of Human Services to request a federal waiver for the Iowa Health and Wellness Plan, our state’s version of Medicaid expansion. Approximately 170,000 adults receive Medicaid through that plan, and roughly 61,000 of them also receive Supplemental Assistance Nutrition Program (SNAP) benefits.

If the waiver were approved, Medicaid recipients would face new reporting obligations for “community engagement.” If not part of an exempted group, they could lose coverage due to paperwork errors, even if they were working the requisite number of hours per week. Nonpartisan analysis estimated this bill would cost the state budget nearly $5 million the first year after the waiver and nearly $12 million each subsequent year.

During floor debate (beginning at 11:53:20 of this video), Republicans characterized the bill as a way to hold Iowans accountable. Democrats offered two amendments that would have extended that accountability to large employers and the for-profit insurers known as managed-care organizations (MCOs), which oversee Iowa’s privatized Medicaid.

Continue Reading...

"Workfare" bill for Iowa Medicaid would cost nearly $17 million over two years

Matt Chapman has closely followed this year’s legislative proposals affecting Iowans on public assistance. He previously reported on a separate bill with a $40 million price tag. -promoted by Laura Belin

A Republican bill seeking to impose new work requirements on some 170,000 Medicaid recipients in Iowa would cost the state budget nearly $5 million more the first year and an additional $12 million every year thereafter, according to analysis by the nonpartisan Legislative Services Agency. Any savings to the state would be “minimal.”

Continue Reading...

Five things to know about Trump's sabotage budget

Matt Sinovic is the executive director of Progress Iowa. -promoted by Laura Belin

This week, the Trump administration released its proposed budget for fiscal year 2020, which revives a call to repeal the Affordable Care Act and lays out massive cuts to Medicaid, Medicare, and the Department of Health and Human Services. The administration’s budget reveals just how steadfast it remains in trying to take away Americans’ health care.

Here are five things you need to know about Trump’s Health Care Sabotage Budget:

Continue Reading...

Bill targeting Iowans on public assistance would cost $40 million by 2021

Matt Chapman has closely followed this year’s legislative proposals targeting Iowans on public assistance. -promoted by Laura Belin

A bill requiring more frequent reviews of Iowans’ eligibility for public assistance programs would cost the state an additional $40 million during the first two years alone, according to analysis by the nonpartisan Legislative Services Agency. The federal government would be on the hook for an additional $35 million during the same period.

Continue Reading...

Steve Bullock's testing these messages among Iowa Democrats

Although Montana Governor Steve Bullock has not yet declared plans to run for president, a group supporting his ambitions has been polling Iowa Democrats to test positive messages about Bullock and several other declared or likely contenders.

I’ve long encouraged readers to record or take notes on political surveys. This post draws on a recording an Iowan provided after receiving the call on the evening of March 7. (Bleeding Heartland never provides identifying information about respondents; I’m only interested in the questions asked.)

The latest Selzer poll for the Des Moines Register, CNN, and Mediacom found Joe Biden and Bernie Sanders well ahead of the rest of the Democratic field in Iowa, with 27 percent and 25 percent, respectively. Bullock was among several candidates at 1 percent. Later today, Bleeding Heartland will publish analysis by Dan Guild, taking a historical view of polling this far out from the Iowa caucuses.

Continue Reading...

Five Senate bills target Iowans on public assistance

Matt Chapman has attended Iowa House and Senate subcommittee meetings nearly every day. These bills were among the most significant he has tracked lately. -promoted by Laura Belin

Over the past week, Iowa Senate subcommittees considered five bills drafted to address fraud in Iowa public assistance programs. Each bill would direct revenue generated by Iowa taxpayers to private vendors, who are charged with finding fraudulent claims. If investigation supports the claims of fraud, those funds could be recovered, and criminal charges filed.

Continue Reading...

Democratic statewide candidates need sharper rhetoric

Joe Gorton: “Fred Hubbell’s campaign for governor is the most recent example of a candidacy that failed to couple a strong emotional tone to strong content.” -promoted by Laura Belin

For the third consecutive time, Iowa Democrats are licking our wounds after a gubernatorial campaign loss. Not surprisingly, there are many competing explanations for what went wrong. Within those explanations one factor is largely ignored: dull campaign rhetoric.

Continue Reading...

Iowa DHS withheld records on "fishy" Medicaid deal before election

For weeks this fall, the Iowa Department of Human Services stonewalled a journalist’s request for easily accessible public records that would have cast an unflattering light on management of the state’s Medicaid program.

Three days after Governor Kim Reynolds won the election, the department sent a copy of one key document to Ryan Foley of the Associated Press. DHS released other relevant files on December 6, allowing Foley to confirm Director Jerry Foxhoven had cut a deal in April allowing UnityPoint Health affiliates to keep nearly $2.4 million they had been overpaid for services provided to Medicaid patients.

The settlement agreement came shortly after UnityPoint agreed to remain part of the network for Amerigroup, one of the private companies DHS picked to manage care for Medicaid recipients.

Continue Reading...

IA-Gov post-mortem: One mistake and two missed opportunities

Nate Williams is a labor attorney and served in the Iowa House from 2009 through 2012. -promoted by desmoinesdem

I am not sure whether to think of this as “three mistakes Fred Hubbell’s campaign made” or “one mistake the Hubbell campaign made and two missed opportunities.”

Either way, there are three things I wish the Hubbell campaign would have done very differently.

Continue Reading...

Half-baked state audit doesn't settle questions about Medicaid savings

Privatizing Medicaid saved the state of Iowa about $126 million during the fiscal year that ended June 30, according to a report State Auditor Mary Mosiman released on November 26.

I put low odds on that estimate holding up after a more diligent auditor takes office.

Even if it did, this review of “savings” was too narrow to reveal whether turning Medicaid over to for-profit companies was a good deal for Iowans.

Continue Reading...

Grassley to chair Senate Finance Committee

U.S. Senator Chuck Grassley told reporters today that he will lead the Senate Finance Committee in the new Congress. The current chair, Senator Orrin Hatch, is retiring. Grassley’s official website notes,

Senator Grassley calls this committee the quality of life committee because of the committee’s jurisdiction, which includes all tax matters, health care, Social Security; Medicare, Medicaid, social services, unemployment compensation, tariffs and international trade. Legislation acted on by the Committee on Finance raises virtually all federal revenue, and expenditures authorized by this committee represent as much as two-thirds of the federal budget.

Continue Reading...

We need representatives who vote for us!

ReShonda Young of Waterloo has been an advocate for small business owners on a variety of issues. -promoted by desmoinesdem

My U.S. House Representative Rod Blum, along with his Iowa colleagues David Young and Steve King, has repeatedly voted to take away health care from me, my brother, my employees, and many other Iowans.

This is personal for me, as it is for most of us. I have a serious health condition and, as a business owner, have employed people with serious conditions of their own.

Continue Reading...

"Fight for the best of who we are": Kamala Harris rallies Iowa Democrats

Hundreds of Iowa Democrats got their first chance to hear U.S. Senator Kamala Harris on October 22. On her first major swing through the state, the senator from California had a packed schedule, including:

  • a morning gathering with the Asian and Latino Coalition;
  • an Ankeny rally organized by Des Moines Area Community College students, also featuring Iowa House district 38 candidate Heather Matson, Iowa Senate district 19 candidate Amber Gustafson, and third Congressional district nominee Cindy Axne;
  • a late afternoon event in Indianola;
  • a private fundraiser for Axne; and finally
  • a speech to a room full of Polk County Democrats in Des Moines.
  • Though Harris is widely viewed as a potential 2020 presidential candidate, she kept her focus on the election happening November 6. I enclose below the full audio and partial transcript of the evening speech, which was similar to remarks Harris delivered earlier in the day.

    Whereas some politicians tend to use convoluted, run-on sentences, Harris was striking in how she used simple sentence construction and repetition to great effect.

    Continue Reading...

    IA-Gov: Notes on the final Hubbell-Reynolds debate

    Governor Kim Reynolds and Democratic challenger Fred Hubbell debated for the third and last time today in Davenport. Too bad not many viewers are likely to tune in at 8:00 am on a Sunday morning, because the discussion was yet another study in contrasts. For those who prefer a written recap, I enclose below my detailed notes. Click here and here for Bleeding Heartland’s analysis of the first two Hubbell-Reynolds debates.

    As during the second debate, journalists kept the candidates on topic and within the time limit, so kudos to moderator David Nelson of KWQC-TV6 and panelists Erin Murphy of Lee Enterprises, Forrest Saunders of KCRG-TV9, and Jenna Jackson of KWQC-TV6.

    Both candidates recycled many talking points from their first two meetings. My impression was that Reynolds performed about equally well in all three debates, while Hubbell improved each time. For instance, after Reynolds noted that Iowa had moved up in mental health rankings three years in a row and was now rated sixth in the country for mental health, Hubbell pointed out that the study the governor cited covered the years 2013 through 2015. That was before the Branstad/Reynolds administration closed some mental health institutions and privatized Medicaid, which has led to worse care for thousands of Iowans.

    For those who prefer to watch the replay, KCRG-TV posted the video in a single file, which is the most user-friendly option. You can also find the debate on KWQC-TV (with closed captioning) and WOWT-TV’s websites, but you will have to watch a series of clips, with advertisements before each segment.

    Continue Reading...

    Former Iowa Medicaid carrier's financial sleight of hand

    John Morrissey investigates anomalies in financial reports filed by AmeriHealth Caritas, which left Iowa’s Medicaid program last year. -promoted by desmoinesdem

    A managed care company that left the Iowa Medicaid program last November financially engineered its first quarter report to state regulators this year, even as it dragged its feet in paying Iowa medical providers for claims that were then more than 90 days old.

    AmeriHealth Caritas Iowa, Inc. claimed in its calendar first quarter filing with the Iowa Insurance Division (IID) that general administrative costs to run its Iowa operation totaled $20 million. But at the end of June, the company reduced that expense to $6 million without explanation.

    Continue Reading...

    Think Iowa's economy is improving? One key federal measure says no

    Tax and budget policy expert Randy Bauer explains that although personal income has been rising across the country in recent years, Iowa is not doing as well in comparison to other states. -promoted by desmoinedem

    How is Iowa doing, economy-wise, in comparison to other states? There are a variety of statistics and competing claims. I would argue that one key measure, which the federal government uses to figure out Iowa’s federal share of a very important program, suggests that Iowa is not doing as well in comparison to other states.

    In fact, using this measure, Iowa has been falling behind for the last four years.

    Continue Reading...

    Rob Sand: If I'm elected, Medicaid MCOs will get subpoenas

    Iowa’s disastrous Medicaid privatization is becoming an important theme of Rob Sand’s campaign for state auditor. While Republican incumbent Mary Mosiman was slow to embark on a review of the program and won’t promise to release her office’s findings before the November election, Sand has pledged to thoroughly investigate the operations of managed-care organizations (MCOs), which now make health care decisions affecting more than 600,000 Iowans.

    Continue Reading...

    IA-Gov: New Register poll points to winning paths for Hubbell, Reynolds

    If Iowans were voting for governor today, 43 percent would support Democrat Fred Hubbell and 41 percent Governor Kim Reynolds, according to a new poll by Selzer & Co for the Des Moines Register and Mediacom. Another 9 percent of the 555 likely voters surveyed were undecided, and 7 percent backed Libertarian Jake Porter. The poll validates the view of leading election forecasters that the governor’s race is a toss-up. Selzer’s poll has a margin of error of plus or minus 4.2 points.

    If this snapshot of the race accurately reflects the views of Iowans likely to vote in November, I’d rather be Hubbell than Reynolds. An incumbent barely above 40 percent despite much higher name recognition than her opponent is not in a strong position. Nevertheless, the Register’s survey points to ways either Reynolds or Hubbell could improve their prospects during the final six weeks of the campaign.

    Continue Reading...

    Former Iowa Medicaid carrier owes millions in unpaid claims

    John Morrissey delved into a little-noticed financial report by AmeriHealth Caritas. -promoted by desmoinesdem

    Although it left the Iowa Medicaid program more than seven months ago, AmeriHealth Caritas Iowa, Inc. continues to string along claims payments due to Iowa providers.

    AmeriHealth – which is owned by Independence Blue Cross of Philadelphia – reported $14.6 million in unpaid liability for claims submitted last year by Iowa Medicaid providers, according to the company’s most recent quarterly financial filing with the Iowa Insurance Division. Meanwhile, the managed-care organization has racked up more than $6 million in administrative costs so far this year to manage the now-closed operation.

    Continue Reading...

    Democrats will get outspent in Iowa House races again. Here's why

    Democrats have opportunities to make big gains in the Iowa House this year. Thirteen of the 59 Republican-held seats in the lower chamber are open. A number of Democratic challengers have done well on fundraising, in some cases even out-raising the GOP incumbents in their districts. The past year’s special elections for Iowa House seats suggest that Democratic turnout may be much higher than the level seen in Iowa’s last two midterms, thanks to extreme laws enacted by statehouse Republicans and an unpopular president in Washington.

    But winning a state legislative race often requires more than a favorable political environment. Bleeding Heartland observed in February that “the latest set of campaign financial disclosures reveal little sense of urgency among Democratic incumbents who could do much more to help others win competitive districts this November.”

    Unfortunately, the latest fundraising numbers tell the same old story.

    Continue Reading...

    Reynolds dumped Medicaid adviser who asked tough questions

    “It’s not certain to me that [my son] Matthew is safe with a Republican governor and a Republican legislature,” David Hudson told the Des Moines Register’s Tony Leys after Governor Kim Reynolds declined to reappoint him as co-chair of Iowa’s Medical Assistance Advisory Council. “And I say that as a lifelong Republican! Because I just don’t see the governor asking the right questions and doing the right thing for my son.”

    By dumping Hudson and another council member who spoke out about problems related to Medicaid privatization, Reynolds has once again shown she is unwilling or unable to engage with facts on the ground related to Iowans’ health care.

    Continue Reading...

    Hope and pray for Democratic victories in Iowa

    Jeff Cox sees Democrats “campaigning only on issues that reliable Democratic voters care about.” He thinks a winning message will require addressing broader concerns among Iowans. -promoted by desmoinesdem

    In the past decade, the Democratic Party has lost control of both houses of the Iowa legislature as well as the governor’s office. It is difficult to overstate the damage that has been done to the people of Iowa by the Republicans. If they keep control of the governor’s office and legislature next November, they can add the judiciary to their list of conquests. When that happens, things will get even worse–much worse.

    Continue Reading...

    Iowa Senate district 49 preview: Patti Robinson vs. Chris Cournoyer

    When Fred Hubbell selected State Senator Rita Hart as his running mate, Democrats had to scramble to find a new candidate in Iowa Senate district 49. Patti Robinson announced her candidacy on July 3. She will face Republican Chris Cournoyer, who has been campaigning here since last November.

    Hart was favored for re-election, having won by nearly 900 votes in 2014 despite the statewide GOP landslide. However, an open seat should be highly competitive. Both parties may devote hundreds of thousands of dollars to this race, based on spending totals from the battleground Iowa Senate districts during the 2016 cycle.

    Democrats are looking at a difficult state Senate map this year and can’t afford to lose any ground to maintain a realistic chance of regaining the majority in 2020. Republicans currently hold 29 of the 50 Senate seats and will pick up Senate district 1, where Iowa’s only independent lawmaker David Johnson is retiring.

    Continue Reading...

    IA-Gov: First speeches by the Hubbell-Hart ticket (audio, transcripts)

    “Whether it’s her own story or distorting facts about my story, one thing is clear: Governor Reynolds is running a campaign about yesterday,” Fred Hubbell told Iowa Democratic Party state convention delegates on June 16. “We’re running a campaign about tomorrow. We are running to get Iowa growing the right way.”

    Hubbell’s first speech to a large crowd since his decisive victory in the high-turnout June 5 primary served several purposes:

    • Preview the main themes of his general election campaign;

    • Reassure Democratic activists (many of whom had been strongly committed to other candidates) that he shares their values and goals;

    • Address and reframe early attacks from Governor Kim Reynolds; and

    • Introduce his running mate State Senator Rita Hart, who’s not well-known outside Clinton and Scott counties.

    For those who weren’t able to attend the convention, I enclose below audio and full transcripts of the speeches by Hubbell and Hart.

    Continue Reading...

    Iowa court strikes down state ban on Medicaid coverage for transgender care

    A two-decade-old state administrative rule “clearly discriminates against transgender Medicaid recipients on the basis of gender identity by excluding coverage for medically necessary gender affirming surgery” while covering the same surgeries for non-transgender Iowans, a Polk County District Court ruled on June 7. Chief Judge Arthur Gamble found the rule violates both Article I, section 6 of the Iowa Constitution, which guarantees equal protection, and the Iowa Civil Rights Act, which has prohibited discrimination on the basis of gender identity since 2007.

    Continue Reading...

    Iowa DHS won't vouch for accuracy of Medicaid data

    The Iowa Department of Human Services “cannot ensure the accuracy, completeness, or reliability” of data released to the public about any programs administered by Iowa Medicaid Enterprise, including the managed-care system for some 600,000 Iowans on Medicaid.

    When responding to all requests for information about Medicaid or related programs, the DHS also warns users that “there may be errors, omissions, or inaccuracies in the data provided.” Leading Iowa Senate Democrats were unaware of the disclaimer, which they described as “odd,” “troubling,” and “unacceptable.”

    Continue Reading...

    New family planning program fails Iowans. Republicans don't want to know

    Republican lawmakers made big promises last year that Iowans would have “more access” to family planning services under a new state program that excluded Planned Parenthood.

    As anyone could have foreseen, the opposite was true. In the first nine months of the State Family Planning Program’s existence, the number of Iowans enrolled dropped by a third. The number who obtained at least one reproductive health care service fell by more than 40 percent from the first quarter to the second quarter the program was operating. The number of health care providers billing the program also declined by 40 percent during the same time frame.

    Republican lawmakers don’t want to hear how poorly the new system is serving their constituents. Even worse, GOP state senators voted unanimously last week to compound the mistake by blocking Planned Parenthood from participating in sex education programs.

    Continue Reading...

    Big changes, worrying signs at Des Moines Register

    High-profile departures from the Des Moines Register newsroom have happened too often over the last decade. A series of layoffs and buyouts left readers less informed about important topics. For instance, ever since the Register let its last Washington-based correspondent go, readers rarely hear about what our state’s members of Congress are doing, unless the story originated from a press release or comments during a conference call with journalists.

    The recent turnover at Iowa’s most important agenda-setting news organization is worrying for heavy consumers of political coverage.

    Continue Reading...

    Report highlights Iowa Medicaid horror stories; oversight bill languishes

    Complaints to the Iowa Office of Ombudsman regarding privatized Medicaid increased by 157 percent last year, reflecting “systemic frustration” over cuts to health services for patients and unpaid bills for providers. Ombudsman Kristie Hirschman has “yet to be convinced” that the Department of Human Services is providing “adequate oversight” of the private insurance companies that control access to care and reimbursements, she wrote in a report released on April 2. The three outrageous examples she recounted resemble too many other tragic cases since Iowa shifted to a managed-care model for more than half a million Medicaid recipients.

    Hirschman has assigned a full-time staffer to handle Medicaid-related complaints. The same issues come up again and again, more than a year after she, the state’s Long Term Care Ombudsman, and the advocacy group Disability Rights Iowa informed the DHS director about recurring problems with Medicaid managed-care organizations.

    Although the ombudsman praised the legislature for “taking steps to correct some of the problems we and others have identified,” Senate Republican leaders haven’t brought up a Medicaid oversight bill that passed the Iowa House unanimously last month.

    Continue Reading...
    Page 1 Page 2 Page 3 Page 4 Page 5 Page 31