Advocates, providers on new Nursing Home mandates

Published in RINewsToday on April 29, 2024

In the shadow of Rhode Island’s ongoing staffing shortage, the Center for Medicare and Medicaid Services (CMS) issued its 329-page final rule on Nursing Home Minimum Staffing Standards (CMS 3442-F) on April 22 in the Federal Rule. 

CMS affirmed its commitment to hold nursing homes accountable for providing safe and high-quality care for the nearly 1.2 million residents living in Medicare-and Medicaid-certified long-term care facilities.  

According to CMS, over 46,000 public comments submitted in response to the proposed rule. Central to this final rule are new comprehensive minimum nurse staffing requirements, which aim to significantly reduce the risk of residents receiving unsafe and low-quality care within nursing homes.

Just the Nuts and Bolts

CMS say that central to its final rule are new comprehensive minimum nurse staffing requirements that would significantly reduce the risk of residents receiving unsafe and low-quality care within nursing homes.  The agency is finalizing a total nurse staffing standard of 3.48 hours per resident day (HPRD), which must include at least 0.55 HPRD of direct registered nurse (RN) care and 2.45 HPRD of direct nurse aide care. Facilities are given the flexibility to use any combination of nurse staff (RN, licensed practical nurse [LPN] and licensed vocational nurse [LVN], or nurse aide) to account for the additional 0.48 HPRD needed to comply with the total nurse staffing standard.

CMS is also finalizing enhanced facility assessment requirements and a requirement to have an RN onsite 24 hours a day, seven days a week, to provide skilled nursing care. 

This final rule provides a staggered implementation timeframe for facilities to meet the minimum nurse staffing standards and 24/7 RN requirement based on geographic location as well as possible exemptions for qualifying facilities for some parts of these requirements based on workforce unavailability and other factors. The requirements of this final rule prioritize safety and health care quality while taking into consideration the unique workforce challenges some nursing homes are facing, especially those operating in rural areas. 

CMS will closely monitor and evaluate the provisions of this final rule, including but not limited to, the minimum staffing standards, the 24/7 RN requirement, the exemption process, and the definition of rural, as they are implemented over the next several years to determine whether any updates or changes are necessary in the future. 

Additionally, to increase transparency related to compensation for workers, CMS will also require states to collect and report on the percent of Medicaid payments that are spent on compensation for direct care workers, and support staff, delivering care in nursing facilities and intermediate care facilities, for individuals with intellectual disabilities. 

Provider, advocate positions on new CMS final rule

At press time, the RI Department of Health (RIDOH) had no comments about CMS’s new final rule released last week, say Joseph Wendelken, RIDOH’s public information officer.  The state agency is reviewing the rule and assessing its impact and applicability in Rhode Island,” he says.

With the final rules release, senior advocates and providers are expressing their opinion about its impact.

Former President Donald Trump, who is challenging President Joe Biden for the presidency, has not addressed quality of care in nursing homes with a formal position.  Kathleen HerenRhode Island’s Ombudsman, speculates that by releasing the CMS mandate before the upcoming presidential election, President Biden is just trying “to establish a record” of enhancing quality of care in nursing homes.

“Nursing homes cannot find  Registered nurses (RN), and Nursing Assistances to hire,” notes Heren.  The CMS mandate will force nursing homes to downsize, like we have just seen happen at the Scandinavian Home,” she predicts.

According to Heren, the final CMS rules do not include the minimum staffing of LPNs. More important, “it’s an unfunded mandate,” she says.

Gerontologist Deb Burton, MS, executive director of RI Elder Info, is pleased to see a Federal minimum staffing mandate of 3.48 hours of daily nursing care. “It’s important to understand mandates don’t make workers appear and a minimum staffing mandate is only an average amount of time allotted for care across all residents in the facility,” she says, noting that this rule doesn’t mean each resident will receive 3.48 hours of care each day.

According to Burton, the CMS Nursing Home Compare website, as of April 2024, notes there are 6 Rhode Island facilities that would not meet the lower federal minimum staffing mandate if it were enacted today. “The workforce shortage and the dire need to increase Medicaid reimbursements to attract and retain adequate staff with a proper wage are common topics of meetings,” says Burton. 

“When workers say ‘It’s only me on the floor – do I help the resident eat their supper or take the other resident to the bathroom? I can’t do both,’ – we need to listen,” says Burton. “The new federal minimum staffing mandate is a good step forward, but we need more. One day it will likely be us waiting for that workers’ help,” she warns. 

Like other RI senior advocates, Maureen Maigret, policy director for the Senior Agenda Coalition of RI, sees the importance of CMS releasing its final rules.  “It is important that these regulations have been finalized as providing for minimum nurse staffing levels in nursing homes helps  ensure residents across the country will receive quality and resident-centered care,”  she says. 

According to Maigret, Rhode Island has had a provision for 24/7 RN coverage even before the state’s minimum staffing law was passed so that is not a new requirement here. She pointed out the regulations will also promote transparency and accountability by requiring public reporting on how much of the Medicaid payments are spent on direct care staff and that the federal government has committed to invest over $75 Million in an initiative to increase the number of nurses working in nursing homes through such things as financial incentives for tuition reimbursement.   

“We are dismayed that the Biden Administration is moving forward with this one-size-fits-all staffing mandate,” says John E. Gage, President and CEO of the Rhode Island Health Care Association. “In the midst of a historic and deepening caregiver shortage, this unrealistic policy will put access to care at risk for countless seniors in Rhode Island and across the country,” he warns, noting that when nursing homes can’t find nurses and/or certified nursing assistants (CNAs), they will be forced to downsize or, even worse, close their doors altogether, leaving seniors with fewer options to receive the care they need.

New final rule just another unfunded mandate

Like the 2021 RI staffing law, the Federal rule is an unfunded mandate, charges Gage. “Every nursing home wants more workers, but rather than blanket mandates from Washington, we need supportive policies and investments that will help us recruit and retain caregivers, he states.

According to Gage, nationally, the nursing home workforce has declined by 124,200 individuals (-7.8%) since the start of the pandemic. Rhode Island’s numbers are even worse, down 1,495 individuals (-15.3%). Gage calls on Congress to step up and support the bipartisan Protecting America’s Seniors’ Access to Care Act, which would prevent CMS from enforcing this unfunded and flawed mandate.

“Together with our national association, the American Health Care Association (AHCA), we will continue to fight for more common-sense solutions and do everything we can to preserve access to care for Rhode Island seniors,” says Gage.

“The good news about the Biden Administration’s final rule, there are phase-ins over multiple years that will provide an opportunity to challenge the mandates through legislation and/or possible AHCA litigation on the national level,” adds Gage. “The federal mandate highlights how much of an outlier RI’s staffing mandate is.  The RI statute has the highest staffing metrics and the highest fines in the country – 10% above the federal standards.  Without the Executive Actions of Governor McKee, RI nursing homes would be fined $90 million in the first full year of enforcement – devastating facilities and forcing further closures.  RI excludes hours worked by administrative nurses from counting toward the RN metric, yet they are included in the federal standards.  RI also excludes med techs’ and nurse aides in training’s hours from the CNA metric, while CMS includes them,” noted Gage.

Gage adds that the CMS final rules consider Rhode Island to be “urban.” As a result, the state has 2 years to phase-in the 24×7 RN requirement.

Rhode Island regulations and law have required 24×7 RN coverage in nursing homes for many decades, says Gage. “While challenging to maintain compliance given the shortage of registered nurses, this should not be a major concern for RI facilities,” he adds, noting that there will be 3 years to comply with the required 0.55 HPRD for RNs and 2.45 HPRD for CNAs. 

Additionally, Gage says that there are also waiver opportunities in certain circumstances.  “During the implementation phase, facilities and all stakeholders must be laser-focused on building a sufficient pipeline of qualified nurses and CNAs to the nursing home workforce,” he says.  

Like Gage, James Nyberg, executive director LeadingAgeRI, sees the CMS mandate as less onerous than the RI staffing mandate that “fortunately” remains suspended. “We remain concerned about the impact of this national mandate on providers in Rhode Island, and its broader impact on consumers and the health care industry,” he says.

According to Nyberg, the state’s current workforce shortages are already preventing nursing homes from filling open positions, limiting new admissions, and forcing organization closures (six nursing homes have already closed since the COVID pandemic began and two more have embarked on significant downsizing). 

“These challenges are also resulting in backlogs at hospitals, which are unable to discharge patients due to reduced capacity in nursing homes,” says Nyberg, noting that LeadingAgeRI is working with numerous stakeholders on various initiatives to develop a pipeline of workers. “But the simple fact is that it will take time and an infusion of resources,” he adds.

“CMS proposes to spend $75 million on a nursing home staffing campaign.  That amount might help a state like Rhode Island, but that money is national, so it is a drop in the bucket in terms of the support the industry needs, states Nyberg.  “On the home front, we have been working with the Administration and the General Assembly to provide an infusion of funding to try and rescue the homes from their dire financial straits and try to stabilize the industry.  But the federal mandate, and all the related details and requirements embedded in the rule, do nothing to further that cause,” he says.

For the Minimum Nursing Standard final rules, go to https://public-inspection.federalregister.gov/2024-08273.pdf

For the CMS Fact Sheet  on Minimum Nursing Standard final rules, go to https://www.cms.gov/newsroom/fact-sheets/medicare-and-medicaid-programs-minimum-staffing-standards-long-term-care-facilities-and-medicaid-0

Regulatory approval can make a belated Christmas miracle happen

Published in RINewsToday on April 8, 2024

A belated Christmas miracle may truly happen, if state and federal agencies allow the Linn Health & Rehabilitation to convert one of its floors into affordable assisted living specializing in memory and dementia care. If this happens, says the facility’s management and its Board of Trustees it will keep the East Providence-based nonprofit facility from closing, preventing the displacement of residents and staff. 

Faced with rampant inflation, rising food and utility costs, high temporary staffing agency fees, and very low state Medicaid reimbursement rates that haven’t kept pace with increasing costs in over a decade, Linn Health, established over 52 years ago, publicized its financial troubles over four months ago.   

The Best of the Best 

When the news broke about Linn Health & Rehabilitation’s financial crisis over four months ago, the facility had just been named a 2024 ‘Best Nursing Home’ and ‘High-Performing’ short-term rehabilitation home in the nation by U.S. News & World Report, states Jamie L. Sanford, LNHA, LCSW, administrator of Linn Health & Rehabilitation.

“Here we are, one of the elite nursing homes in the United States, and we are finding it difficult to stay afloat like six other homes in our local market who have gone out of business, and three others who have declared bankruptcy, and one other who recently had to downsize by 50 beds,” says Sanford.

“It’s sad that Rhode Island families who deserve an affordable 5-star nursing home like ours don’t have the option because of inadequate Medicaid reimbursement. The struggle is real,” says Sanford.

Together with Aldersbridge Communities and its volunteer Board of Trustees, Linn leaders launched a savvy PR move, calling it a “Hail Mary” effort, to find its Christmas miracle donors and funding to prevent it from closing or forcing the displacement of 71 residents and the laying off of 150 staff members. A clever twist on the message resulted in a story on Rhode Island television stations, talk radio, and pick up by other media outlets.

“Our tireless pleas for funds to keep us afloat until a slight Medicaid reimbursement rate increase is expected to take place later this year were heard, but didn’t result in us receiving any emergency gap funding. We did receive charitable contributions from generous donors in earnest, but the amount was nowhere near enough to cover our losses of $100,000 per month,” states Richard Gamache, MS, FACHCA, chief executive officer of Aldersbridge Communities. With revenues dwindling, Linn leadership came up with a solution: convert one floor of the nursing home into affordable assisted living, specializing in memory and dementia care”, he notes. 

Submitting the Application

According to Gamache, its application for recertification was submitted last month and he expects the license to be approved by the RI Department of Health soon. “Obtaining our certification so that we can bill the Centers for Medicare & Medicaid Services is a bigger obstacle, because the federal government is involved,” he says. But, it could take “one or two months to get the facility’s licensing and certification approved by the RI Department of Health and Human Services (RIDHS) and CMS.  

If approved and certified, Linn Health & Rehabilitation will operate “The Loft at Linn” – a new assisted living memory care unit featuring 22 private studio apartments on the second floor of the building. The third floor will remain a licensed nursing home, albeit smaller now with 33 beds.

According to Gamache, the RIDHS has recertified Linn residents currently receiving long-term care to qualify for assisted living-level memory care, enabling them to continue to live at Linn and have the same caregivers they are used to and know. 

Meanwhile, grant funding from the Rhode Island Foundation, the Ruby Linn Foundation, and other sources are being used to pay for the apartment renovations; and to re-educate and train certified nursing assistants to become certified medical technicians so they can remain on staff working at the assisted living memory care program.

Shifting operations to assisted living and repurposing existing nursing home rooms will keep the facility’s doors open. “It’s not enough to solve our financial woes completely, as we expect the nursing home to continue to lose money – just not as much as we have been losing,” notes Gamache. “The irony is that we will save Rhode Island over $780,000 in a year because of the difference between what they will reimburse us for assisted living, versus a skilled level of care per Medicaid resident,” Gamache calculates. 

As a whole, because we’re going from a 42-bed skilled nursing floor to a 22-bed assisted living floor, the state is going to save $2.8 million per year in Medicaid dollars,” notes Gamache.

It is not surprising that Rick Gamache, who has years of experience managing nursing facilities, might have just found a way to keep his facility open,” says Kathleen Heren, Rhode Island’s Ombudsman. If the request of recertification is approved by state and federal regulators to offer assisted living with memory care, residents won’t be displaced and workers won’t lose their jobs, says Heren.

“It was never a viable option to sell Linn Health to an out-of-state nursing facility chain,” says Heren, noting that there is a need for assisted living facilities offering memory care. “There are high functioning people affected with dementia, with no medical conditions, who do not need to be placed in a nursing facility,” she adds.

Comments from the Sideline 

Like Heren, Maureen Maigret, policy advisor for the Senior Agenda Coalition and member of the RI Advisory Council on Alzheimer’s Disease Research and Treatment, holds Gamache in high regard. By converting a floor to needed assisted living with a memory care, staff will not be displaced, so residents with memory issues will not be losing staff who know them and who they are comfortable with.

According to Maigret, many assisted living residences strictly limit residents on Medicaid. A few years back, the state changed the Medicaid reimbursement for assisted living to one with three levels of reimbursement with a higher level of reimbursement to encourage more residences to accept persons with higher needs who are on Medicaid. ”We know that RI has many persons with diagnoses of Alzheimer’s and related dementias so such memory care programs are critical for those who cannot pay privately with monthly rates often over $6,000,” says Maigret.

Maigret notes that the state’s Health Department reports that 34 assisted living residences are licensed as Special Care/Alzheimer’s residences, but it is does not show which ones accept Medicaid. “And even those that do often limit the number of residents on Medicaid as they can get higher reimbursements from private paying persons,” she says.

According to Gage, in 2024, RI’s nursing homes are being paid rates by Medicaid that are based on their 2011 actual costs under the price-based reimbursement system that was implemented in 2013. Core principles of this reimbursement methodology are the statutory annual inflation adjustments and a Medicaid rate analysis every three years to determine whether rates are reasonable and adequate. “In the vast majority of years in the past decade, RI Medicaid has slashed or eliminated inflation adjustments, and they have never conducted a rate analysis/adjustment.  As a direct result, RI nursing homes are losing $50-75/day on each resident receiving care under Medicaid,” he says.

Gage predicts that Linn and Scandinavian Home will not be the last to make the difficult choice to downsize or close. “Just since the start of the pandemic, six RI nursing homes have closed and three were in receivership. Now, two nonprofit homes are forced to downsize their facilities,” he noted. “RI nursing homes must be adequately reimbursed by Medicaid under a stable and sustainable reimbursement system, and there needs to be bold action to recruit and retain frontline healthcare workers at competitive rates,” he warns, calling for the state to preserve nursing facilities. 

Demographics show a silver tsunami on the horizon. We need to ensure that there will be capacity for those who will need short-term or long-term care and services in the coming years,” states Gage.

As far as any potential Medicaid savings resulting from the planned conversion, Gage says that Linn would only be able to accommodate 33 nursing facility residents down from its former capacity of 87. By downsizing the nursing home by 54 beds and transitioning that floor into low-income memory care assisted living for just 22 residents, there will be a savings to the state, he says. due to the combined capacity of the facility decreasing by 32 residents, and those who remain in the memory care unit will be receiving a lower level of care and assistance than that provided in a skilled nursing home.

At press time, Gamache waits for the license from RIDOH and certification from the Centers for Medicare & Medicaid Services to be approved that enables the opening of the new assisted living memory care program. 

“There is no reason while this approval shouldn’t happen,” says Gamache. “We can comply with all the regulations, we’ve identified an overwhelming community need, and we are saving the state a lot of money,” he quipped. 

“After all, this is a win/win for the state, for residents, their families and staff to enable Aldersbridge Communities continue operating a full continuum of care,” states Gamache. 

Hail Mary PR Effort Puts Spotlight on Inadequate RI Nursing Home Medicaid Plan

Published in RINewsToday on December 4, 2023

Last week, a campaign by Linn Health & Rehabilitation told of its efforts to keep its doors open.  With no immediate state reimbursement fix in sight, the nonprofit nursing home, established 52 years ago, launched a savvy PR move, calling it a “Hail Mary” effort to find its Christmas miracle donors and funding to prevent it from closing or forcing the displacement of 71 residents and the laying off of 150 staff members. A clever twist on the message resulted in a story on Rhode Island television stations, talk radio, and pick up by other media outlets.

For over 10 years, Linn Health, which had only recently been named a 2024 “Best Nursing Home” and “High-Performing” short-term rehabilitation home in the nation by U.S. News & World Report, has been fighting rampant inflation, rising food and utility costs, high temporary staffing agency rates, and low state Medicaid reimbursement rates that haven’t kept pace with increasing expenses – as most nursing homes have been as well. 

Linn Health & Rehabilitation is currently losing $100,000 a month, notes Richard Gamache, MS, FACHCA, chief executive officer of Aldersbridge Communities which is the nonprofit that operates the nursing facility, senior housing, affordable assisted living, and outpatient rehab for older Rhode Islanders.

“For years, we’ve operated with a slight loss, but the other Aldersbridge entities were able to subsidize that loss.  As a mission-driven provider for low-income people and those on Medicaid, we aren’t here to make money, we’re here to serve our community’s needs,” he says, noting that the gap between the facility’s costs and its daily Medicaid rate is now just too great.

“Bleeding Cash” drastically impacts facility’s bottom line

Gamache noted that Aldersbridge Communities had been able to support its nursing home but it has now reached a “tipping point.”  During COVID the federal and state governments were very generous with grants. “That’s no longer an option, and the money is running out quickly,” he says.

“We’re in dire straits, financially,” admits the seasoned CEO, who has been in the long-term care field for over 43 years.  “We’re struggling.  We have some vendors who understand and are being patient with us, and others who tack on charges if we don’t pay on  time,” he says.

“Eighty-two percent of our residents are on Medicaid and don’t have families who can take care of them. We are their family and support system, and some have been discharged from other assisted living communities because they ran out of money,” he says. 

In recent months, Gamache reports he has meet with peers, East Providence lawmakers, state officials, and even nursing facility trade groups seeking a viable solution to the state’s Medicaid reimbursement issues. “I have proposed options such as bridge funding and higher Medicaid reimbursement rates, as many other states have done, to address this nationwide problem. It seems only nursing home residents, their families, employees, leaders of surviving homes that are hanging by their fingernails, and some advocacy groups care about the financial predicament we are in. We’ve made everyone aware and we will not stop fighting for funding that we need,” he says.  

According to Jamie L. Sanford, LNHA, LCSW, administrator of Linn Health & Rehabilitation, since 2022, six nursing homes in Rhode Island have shut their doors permanently, not counting the four that closed prior to the COVID-19 pandemic. Three more have filed for bankruptcy, she says, noting that many nursing homes throughout the nation are in the same financial predicament. 

“Linn’s Medicaid reimbursement rate averages $255 per patient per day, and it costs $411 to care for each patient per day,” states Sanford. “The general population thinks that nursing homes make a lot of money. Perhaps that’s true in some for-profit organizations where they are owned by large corporations, but nonprofit homes are robbing Peter to pay Paul. These are the homes – like us – that are on life support, operationally speaking,” she notes.

Joseph Wendelken of the RI Department of Health says that the state is attempting to ease the financial burden of facilities providing care to Rhode Island nursing facility residents. “Nursing homes in Rhode Island received an increase in Medicaid reimbursement rates on October 1, 2023. The increase varied by facility, but it was approximately 6.9%. Per Rhode Island legislation, there is a mandatory review of nursing home expenses every three years called the ‘re-array.’ The current re-array is in progress and any potential increase in the nursing home rates would begin as of October 1, 2024,” he noted.  

But facilities can’t wait a year for the state’s Medicaid adjustment to kick-in and immediate action must be taken. “Essentially, the state is breaking its own law by not conducting the re-array every three years, which was put in place to keep up with the national nursing home inflation index. The last re-array was in October of 2012. Even with an increase next fall, it won’t be enough to help close the funding gap now,” charges Michael Cole, vice president of the Board of Trustees for Aldersbridge Communities.

It’s time for a savvy PR campaign   

With no immediate financial solutions in sight, Gamache and his management team staff have been working on their own grassroots PR campaign, calling it a “Hail Mary” effort, to save Linn Health from having to displace its staff and residents.  

Linn Health’s PR campaign was seen as the next logical step to quickly tackle its financial problems, after months of alerting staff officials of the need for action. 

“Everyone with the authority to do something to help has all the information they need. Now we need action. I often hear, ‘there’s not enough money in the budget’ but the fact is, these are policy decisions. It’s about priorities,” says Gamache. 

“Do we value our older adults enough to provide for their basic needs? What kind of values do we have as a state and as a society?” asks Gamache. 

“Now it’s time to get the story into the public domain. Many people feel that nursing homes are making money hand over fist and that we’re all diverting funds to pay for yachts,” says Gamache. “Although it’s true that there are some bad apples in this profession, I believe most of us want to do what’s right, and for Linn Health and Aldersbridge Communities, a mission-driven non-profit, we’ve always cared more about better outcomes for our people than more income. We just can’t afford to operate much longer,” he warns.

The residents and staff at Linn are doing everything they can, including holding baked goods sales to raise funds. “No one wants to leave Linn, and no one wants us to be sold to another organization,” Sanford comments. “During this season of holiday miracles, we’re working to find donors who believe in what we’re doing now, and for our future. There must be a donor out there who can help us fight the proverbial ‘grinch’ that is causing nursing homes to disappear throughout the country and in our state. All we want for Christmas is to keep caring for our residents who depend on us,” she says.

“This situation exemplifies the dire straits that RI nursing homes are in, especially the community-based ones like non-profit providers.  We have been working with state officials, including the Governor’s office, EOHHS, the Health Department, and other stakeholders to highlight the crisis and the need for immediate action,” says James Nyberg, president and CEO of LeadingAge Rhode Island.  LeadingAge, founded in 1989, is a not-for-profit membership organization of not-for-profit providers of aging services, including not-for-profit nursing homes, assisted living residences, and senior housing providers, and adult day health services. 

“They have recognized our concerns and we are hopeful that some action will be taken ASAP to provide an infusion of funding.  Any nursing home closure has profound and disruptive consequences for residents, staff, families, and the broader community.  With six nursing homes closing and three in receivership, how many more proverbial canaries in the coal mine do we need?” adds Nyberg.

“Unfortunately, Linn Health’s story is emblematic of a wider crisis facing Rhode Island nursing facilities.  Nursing facilities are facing unprecedented increases in nearly all aspects of providing care – staffing costs, energy prices, inflation on food, medical supplies, etc. At the same time, Medicaid rates have not kept pace,” says John Gage, president and CEO of the Rhode Island Health Care Association.  In 2023, RI’s nursing homes are being paid by Medicaid based on the actual allowable cost of care from 2011 with an average of approximately 1% increase annually,” he said.  RIHCA was founded in 1972, and has 63 skilled nursing facilities who are members.

Finally, Maureen Maigret, former Director of the RI Department of Elderly Affairs who serves as a member of the Long-Term Care Coordinating Council and chair of its Aging in Community Subcommittee, weighs in. “The financial challenges faced by Linn Health are worrisome and point to a need for the State to take a very close look at the financial status of Rhode Island nursing homes in general,” she said, noting that few persons can afford privately paid nursing home care at an average cost of $113,000 per year. 

“So unless skilled care is paid by Medicare, Medicaid becomes the payer for a large percent of nursing home care in Rhode Island and rates must be adequate to provide the quality care we expect our loved ones to receive if they need the round the clock care provided in nursing homes,” Maigret adds. 

Linn is asking that interested charitable organization and donors willing to help Linn Health & Rehabilitation’s financial situation to contact Aldersbridge Communities Director of Development, Elise Strom at estrom@aldersbridge.org, 401-438-4456 ext. 136.