Intro Introduction to NM Medicaid Medicaid

Intro
Introduction to NM Medicaid
Medicaid
Presented by:
Xerox State Healthcare, LLC
Provider Relations
Resources
When online use: Ask Service Representative
[email protected]
[email protected]
Call Center 505-246-0710 or 800-299-7304
New Mexico Web Portal
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•
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Provider Information section
Links and FAQ section
Provider Login section
Important State Websites
STATE WEBSITE:
PROGRAM POLICY MANUAL
http://www.hsd.state.nm.us/mad/policymanual.html
BILLING INSTRUCTIONS
http://www.hsd.state.nm.us/mad/billinginstructions.html
REGISTERS AND SUPPLEMENTS:
http://www.hsd.state.nm.us/mad/registers/2012.html
3
IMPORTANT!
Electronic Funds Transfers (EFT)
Step One: Click on
Email EFT
Administration
Step Two: Enter EIN
(Federal Tax ID) or
SSN
and click on submit
4
11/20/2013
IMPORTANT!
Electronic Funds Transfers (EFT)
Step Three: You will
need to fill out your
account type, account
number and bank
routing transit number,
you will also need to
enter your email
address then click on
submit
This e-mail address will also provide a security purpose for EFT
because a provider will be notified whenever a change is made to the
banking information associated with EFT.
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November 20, 2013
IMPORTANT!
Electronic Funds Transfers (EFT)
Step Four:
You receive
confirmation
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11/20/2013
Glossary of Terms
Glossary of Terms
Visit the link below for a list of frequently used abbreviations.
http://www.hsd.state.nm.us/mad/Glossary.html
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History of Medicaid
As he campaigned in 1964 Lyndon B. Johnson declared a
“The War on Poverty.” He challenged Americans to build a
“Great Society” that eliminated the troubles of the poor.
Medicaid was created by the Social Security Amendment of
1965 which added Title XIX to the Social Security Act.
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What is Medicaid?
• U.S. health coverage program for individuals and families
with low incomes/resources.
• Medicaid is jointly funded by the federal and state
governments and administered by the States.
• Largest funding source for health related services for low
income people.
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It All Fits Together
ISD
Medical
Assistance
Division
Molina\TPA
DentaQuest
PROVIDER
Managed Care Providers
Xerox
FEE-FOR-SERVICE
SCI
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New Mexico Medicaid
Program
New Mexico Medicaid Program
• The Medical Assistance Division (MAD) of the Human Services
Department (HSD) administers the Medicaid program for the State
of New Mexico and establishes policies around benefits and claims
processing.
• Medical Assistance Division (MAD) is comprised of the Director’s
Office and several bureaus or units. To find out more about each
office, bureau, or unit go to the following link
http://www.hsd.state.nm.us/mad/HBureauListing.html
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Medicaid Policy Manual
• Medicaid Policy Manuals are available for reference.
• Each manual contains basic Medicaid policy as well as
specific provider type policy and billing instructions.
• Billing providers should become familiar with their manual and
refer to it.
http://www.hsd.state.nm.us/mad/RPolicyManual.html
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What Is HIPAA?:
HIPAA is?:
The Administrative Simplification provisions of the Health
Insurance Portability and Accountability Act of 1996
(HIPAA, Title II) required the Department of Health and Human
Services (HHS) to establish national standards for electronic
health care transactions and national identifiers for providers,
health plans, and employers.
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HIPAA is?:
The security and privacy of health data was also addressed. As the
industry adopts these standards for the efficiency and effectiveness of the
nation's health care system, the use of electronic data interchange will
improve.
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•
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NPI (National Provider Identifier)
Electronic Billing (Payer Path, Clearing Houses)
NM Medicaid Web Portal
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New Mexico Medicaid
Program
Eligibility: Who qualifies?
• Client eligibility is determined by the Income Support Division
(ISD) of HSD or Social Security Office
• Eligibility is based upon family size, income, assets and other
criteria (Often in association with the disability or age of an
individual)
• Clients qualify for Medicaid under a specific category of
eligibility (COE). The COE can also indicate a benefit
package (full benefits, limited benefits, full benefits but may
owe co-pays, etc.)
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How to Apply for Medicaid
Benefits
In order to apply, clients must provide information about family,
income, and assets to the ISD office in their local county, or if their
eligibility is determined by the Social Security Department, the
information is reported to the Social Security Department.
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How to Apply for Medicaid Benefits
Continued
Once approved clients receive a blue plastic Medicaid ID card upon their
eligibility being sent to Xerox.
*The card itself is not proof of eligibility. Rather the card contains information that enables a provider to
check on eligibility. In addition, a provider should always ask to see other recipient identification in order to
assure that the patient is who he or she claims to be.
• Remember to verify that eligibility is current.
• Clients must inform their caseworker of any status changes.
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NM Medicaid Blue Card
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Ways to Check Eligibility
•On-Line Eligibility Inquiry—Web Portal
https://nmmedicaid.acs-inc.com
•Automatic Voice Response System (AVRS) (800) 820-6901
•Xerox Eligibility Help Desk: (800)-705-4452
Monday, Tuesday, Wednesday and Friday 8:00 a.m. - 5:00 p.m.
Thursday (Mountain Time) 8:00 a.m. - 4:00 p.m.
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Medicaid Recipient
COE examples
072:
035:
029:
074:
041:
044:
Medicaid full benefits
Pregnancy-related services only
Family Planning Benefits
Working Disabled Individuals
QMB - Age 65 and Over
QMB - Under 65
For a COE & description listing, go to:
http://www.hsd.state.nm.us/mad/pdf_files/GeneralInfo/Eligpamphlet.pdf
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New Mexico Medicaid Program Structure
New Mexico Human Services Department/Medical Assistance Division
Medicaid Program
Physical Health Program
Managed Care
SALUD!
Lovelace
Presbyterian
Molina
Blue SALUD!
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CoLTS
Behavioral Health
Program
Fee-for Service
Fiscal Agent
Xerox
Amerigroup
UnitedHealthcare
Community plan
Utilization Review
Third Party Assessor
Contractor Molina
DentaQuest
Contracted by
Molina
Statewide Entity for
Behavioral Health –
OptumHealth
NM Medicaid Managed
Care Organizations
SALUD!
The managed care contracts provide for the delivery of medically
necessary physical and behavioral health services to approximately
300,000 children and adults in New Mexico.
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SALUD!
Native Americans are not automatically enrolled in SALUD!,
however, they can choose to be in SALUD!.
Visit the link below for additional details regarding the Native
American opt-in policy.
http://www.hsd.state.nm.us/mad/PNaoptin.html
Medicaid clients who are dual eligible (covered by Medicare and
Medicaid) are enrolled in CoLTS and not SALUD!.
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SALUD!
Medicaid clients qualified under COE 029 – Family Planning
Services Only are not in SALUD!.
Medicaid clients in nursing homes or intermediate care facilities for
the developmentally disabled are enrolled in CoLTS.
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SALUD!
• Clients not excluded from SALUD! are enrolled in SALUD!
about 4-6 weeks after they’ve qualified for Medicaid. During
that 4 - 6 week interval, most recipients are in the Medicaid
Fee-For-Service Program with claims processed by Xerox.
• The client receives a notice that they will be enrolled in
SALUD! and have an opportunity to select their MCO.
• If they do not select a MCO by a certain date, they are
automatically assigned to a MCO. The client has 90 days after
assignment to change their SALUD!.
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SALUD!
• Clients in SALUD! become members of a SALUD! Managed
Care Organization (MCO) and receive their physical health
care services from doctors, hospitals, pharmacies, and others
who work with that MCO.
• Once enrolled in an MCO, the client is issued a member card
by that MCO.
• This card is NOT their Medicaid eligibility card. It indicates
they are a member of that MCO and has their MCO member
ID on it.
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SALUD!
• A newborn baby is enrolled in the same MCO as the
mother, if the mother was enrolled in SALUD! on the baby’s
date of birth.
• The baby’s birth must be reported to the ISD office for the
enrollment to take place.
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SALUD! Managed Care
Organizations (MCO)
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•
•
•
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Lovelace Healthcare: 800-808-7363
Molina Healthcare: 800-580-2811
Presbyterian Healthcare: 888-977-2333
Blue Cross Blue Shield of NM: 866-689-1523
Coordination of Long Term Services
(CoLTS)
CoLTS covers primary, acute, and long-term services in one
coordinated and integrated program that incorporates Medicare and
Medicaid services.
Clients who are also eligible for Medicare and are in nursing
facilities, or receive certain services such as Personal Care Option
services in their home, are enrolled in a CoLTS MCO, not in Salud!
CoLTS MCO:
• United Healthcare: 800-851-1878
• Amerigroup: 800-600-4441
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Important Reminder
• In all cases, providers must be enrolled in the MCO in
order to be paid by the MCO.
• Providers must follow MCO requirements and submit
claims to the MCO for clients who are enrolled in
SALUD! or CoLTS on the date(s) of service (DOS).
• Xerox cannot pay physical health claims for clients
enrolled in SALUD! or CoLTS on the claim’s DOS.
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NM Medicaid Structure:
Fee-for-Service (FFS)
NM Medicaid Structure:
Fee-for-Service (FFS)
Xerox is the Fiscal Agent for the New Mexico Medicaid Fee for
Service program.
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NM Medicaid Structure:
Fee-for-Service (FFS)
Clients who are not enrolled in SALUD! or CoLTS may obtain
health care services from any provider who accepts Medicaid.
This part of the Medicaid program is referred to as Medicaid
“fee-for-service”.
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NM Medicaid Structure:
Fee-for-Service (FFS)
Terms you may hear describing clients in the Medicaid fee-forservice program:
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•
•
•
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“exempt”
“Medicaid fee-for-service”
“In regular Medicaid”
“Medicaid traditional”
As the Fiscal Agent:
• Enrolls providers into the FFS Medicaid program.
• Processes health care claims for New Mexico’s Medicaid FFS
program.
• Claims are processed according to the policies of the New Mexico
Medicaid program.
• Issues payment to Medicaid providers.
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As the Fiscal Agent
Does Not:
• Make Medicaid Policy.
• Make exceptions to Medicaid Policy.
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Full Medicaid Covered Services
through Fee for Service (FFS)
Medicaid.
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Inpatient Hospitalization
Outpatient Hospital Services
Physician Services
Lab & Radiology Services
Home Health
Nursing Facilities
Early and Periodic Screening,
Diagnostic and Treatment
(EPSDT) Services for Children
**Some procedure codes
within these services may
not be covered and some
may require prior
authorization**.
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•
•
•
•
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•
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•
•
•
•
•
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Prescription Drugs
Vision and Hearing Services
Organ Transplants
Behavioral Health Services
Podiatrist Services
Dental Services
Physical, Occupational and Speech
Therapies
Rehabilitative Services
ICF/MR
Case Management
Emergency Hospital Services
Hospice
Transportation Services
Prosthetic Devices
Personal Care
Insure New Mexico
Programs
2012 Federal Poverty Level Guidelines
Household size
100%
133%
150%
200%
300%
400%
1
$11,170
$14,856
$16,755
$22,340
$33,510
$44,680
2
$15,130
$20,123
$22,695
$30,260
$45,390
$60,520
3
$19,090
$25,390
$28,635
$38,180
$57,270
$76,360
4
$23,050
$30,657
$34,575
$46,100
$69,150
$92,200
5
$27,010
$35,923
$40,515
$54,020
$81,030
$108,040
6
$30,970
$41,190
$46,455
$61,940
$92,910
$123,880
7
$34,930
$46,457
$52,395
$69,860
$104,790
$139,720
8
$38,890
$51,724
$58,335
$77,780
$116,670
$155,560
$3,960
$5,267
$5,940
$7,920
$11,880
$15,840
for each additiaonal person add
Insure New Mexico! Health Care Coverage Guidelines
185%: New MexiKids, New Mexiteens, Family Planning & Pregnancy
200%: State Coverage Insurance (SCI)
235%: Children's Health Insurance Program (CHIP)
250%: Working Disabled Individuals Program (WDI)
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Behavioral Health Services
Behavioral Health Services
Services provided by a Behavior Health Provider are
administered by Optumhealth.
Prescription drugs prescribed by a Behavioral Health Provider
are also administered by OptumHealth.
It is the provider type, not the service or the diagnosis that is
used to determine if it is Behavioral Health Service.
For clients enrolled in CoLTS, Medicare crossovers are paid by
the CoLTS MCOs (Amerigroup, UnitedHealthcare).
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Behavioral Health Services
Behavioral Health Providers should access Optumhealth’s
website for information.
https://www.optumhealthnewmexico.com
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NM Medicaid Utilization
Review
Utilization Review (UR)
Prior Authorization (PA)
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•
Some services in the Fee For Service program require prior
authorization in order for the claim to be eligible for payment.
•
The PA is issued based upon medical necessity, but does not
guarantee the client’s Medicaid eligibility. (Eligibility must still
be verified).
Utilization Review (UR)
The UR contractor for New Mexico is Molina TPA (Third Party
Assessor)
All claims for Waiver and PCO providers require an authorization.
•
Waiver providers – Contact the Case Manager to obtain or follow
up on a Prior Authorization.
•
PCO providers – Contact Molina TPA (Third Party Assessor).
(505) 348-0311 ( in Albuquerque)
(866) 916-3250 (Toll free)
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Utilization Review (UR)
How do you determine if/when a Prior Authorization (PA) is required?
Call Molina. They can tell you if a PA is required and the procedures for getting
a Prior Authorization.
Molina TPA (Third Party Assessor)
• (505) 348-0311 ( in Albuquerque)
• (866) 916-3250 (Toll free)
Also, consult the Medicaid program and policy manuals and billing manuals for
prior authorization requirements.
Authorizations for EMSA Emergency Medical Service for Aliens (review contact
Molina TPA.).
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Utilization Review (UR) cont…
Out of State Providers - When submitting a claim on the CMS-1500 claim form for a New Mexico
Medicaid client, please attach the Prior Authorization to the claim. If the claim is submitted with the Prior
Authorization number located in form locator 23, the claim will deny. Reminder: all out of state providers
require a prior authorization for services rendered to a New Mexico Medicaid client.
Dental Providers need to submit requests for prior approval to:
DentaQuest USA, LLC
12121 North Corporate Parkway
Mequon, WI 53092
If you have questions or concerns, regarding your prior approval requests that
have been submitted to DentaQuest for review, please contact DentaQuest
Customer Service at:
1-800-417-7140 (toll free)
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Medicaid Management
Information System (MMIS)
Medicaid Management
Information System (MMIS)
Medicaid Management Information System (MMIS). Omnicaid is the
name of New Mexico's MMIS.
Xerox maintains Omnicaid to process claims and issue payments to
Medicaid providers for their services to Medicaid clients.
Some data that MMIS contains includes provider information, client
information, claims history, and payment history.
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NM Medicaid Web
Portal
The Xerox New Mexico Medicaid Web Portal
Billing Instructions
Trainings
FAQ’s
HSD Link
RA Newsletter
https://nmmedicaid.acs-inc.com
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Categories of Eligibility with
Limited Benefits
029 - Family Planning
Which services are covered?
Medical Claims and Institutional Claims:
The system examines the revenue code, procedure code, and any
related diagnosis codes on the line. The service is covered by the
Family Planning Medicaid (FPM) if a combination of the approved code
sets are used to identify the service:
•
Procedure Code and the diagnosis codes must be contraceptive
management or screening and treatment for sexually transmitted
diseases.
Institutional Claims only:
• The revenue code and diagnosis are on the approved code lists.
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029 - Family Planning Waiver
Which services are NOT covered by this COE?
•
Treatment of conditions not related to contraception, sterilization, or
sexually transmitted diseases. Hysterectomies for the sole purpose of
sterilization and pregnancy terminations are not covered.
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0029 – Service not Family Planning
Related
Why does this denial occur when the service was actually for Family
Planning?
•
Procedure code, diagnosis code, or revenue code not recognized as
family planning related. If rendered service is family planning related,
resubmit claim using alternate codes. You can verify if a code is
covered by contacting the Provider Relations Help Desk. Do not bill
Medicaid client for services that can be billed using an alternate
approved codes.
•
If you are not able to locate a suitable alternative code for your service
but feel the service should be paid under this benefit package, please
contact the FPM Program Manager at MAD.
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035 – Pregnancy Related
(presumptive) Covered Services
Presumptive: Presumptive Eligibility (PE) is short-term (60 days or
less) Medicaid coverage for children up to age 19 or for pregnant
women.
Medical Claims and Institutional Claims:
The system examines the revenue code, procedure code, and any
related diagnosis codes on the line. The service is covered by
Pregnancy Related Services Only (PRSO) if a combination of the code
sets are used to identify the service:
• Procedure Code and the diagnosis code are relating to a pregnancy
or complications of pregnancy.
Note: Inpatient stay not covered under presumptive eligibility, the
individual must first complete the eligibility process.
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035 – Pregnancy Related (nonpresumptive) Covered Services
Medical Claims and Institutional Claims:
The system examines the revenue code, procedure code, and any
related diagnosis codes on the line. The service is covered by
Pregnancy Related Services Only (PRSO) if a combination of the code
sets are used to identify the service:
•
Procedure Code and the diagnosis code are relating to a pregnancy or
complications of pregnancy and conditions that may complicate the
pregnancy.
Institutional Claims only:
• The revenue code and diagnosis are relating to a pregnancy or
complications of pregnancy and conditions that may complicate the
pregnancy.
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041, 044 – Qualified Medicare
Beneficiary (QMB)
MEDICAID covers the co-insurance and deductible on
MEDICARE covered services only after MEDICARE has paid.
If service is not covered by MEDICARE,
MEDICAID WILL NOT PAY.
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Categories of Eligibility with
Co-pays
• 071 FM 1 – CHIP (Children’s Health Insurance Program)
• 074 – WDI (Working Disabled Individuals)
Clients with these COEs may owe co-pays for some services;
Native American Exempt (NAX) clients are excluded from all copayments.
Copayment Schedules are available on the Eligibility Inquiry on
the Web Portal.
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Other Categories of Eligibility
CMS (Children’s Medical Services)
Children’s Medical Services is part of the Family Health Bureau in the
Public Health Division of the Department of Health, and is federally
funded through Title V and State General Funds to serve as a safety net
for medical management, payment for medical services, diagnostic
studies and service coordination for Children and Youth with Special
Health Care Needs (CYSHCN).
CMS is billed similar to regular Medicaid (FFS) with the following differences:
•
•
Always use the 14 digit CMS client ID number that begins with 07 off of
the MAD 309 form
Always enter the PA number in box 23 of the CMS-1500 form (If the
PA number is 8 digits, add 2 zeroes in front of it.)
All claims for Children’s Medical Services (CMS) clients must have the
CMS prior authorization number entered on the claim.
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CMS (Children’s Medical Services)
CMS claims can be submitted electronically. However, if the claims denies
for eligibility, submit the claim on paper and attach the paper authorization
issued by CMS, which is either the CMS 309 form, CMS Card letter or
CMS Registration.
If a CMS PA for a pharmacy service is not on file, the provider needs to
first contact the Point of Sale Helpdesk and then fax the CMS PA to them:
•
Point of Sale Helpdesk
800-365-4944
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Prior Authorization
Prior Authorizations for
Pharmacy Claims
•
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Point of Sale Helpdesk
800-365-4944
What do I do if I get a denial pertaining to a Prior
Authorization?
Access the Web Portal’s Prior Authorization inquiry.
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•
Verify the PA/Claim discrepancy the denial pertains to.
•
Make claim corrections or follow up with your respective
authorizing agency to have PA information changed/corrected.
Timely Filing
Timely Filing Limits
90 days from the date of service for all providers.
Exceptions to the 90 day timely filing limit:
• Schools, the filing limits are 120 days for the initial filing period and
120 days for the grace period (rather than 90 days).
• IHS and Tribal 638 compact facilities, the filing limit is 2 years from the
date of service with no additional grace period.
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Timely Filing Limits
• For a claim which met the initial filing period, but was denied,
partially denied, or requires an adjustment, there is an
additional one-time 90 day grace period counted from the date
of payment or denial, during which the claim can be re-filed or
an adjustment submitted to Xerox.
• It is to the provider’s advantage to resubmit a claim, if
necessary, within the initial 90 day filing period in order to have
the greatest amount of time in which to re-file or submit an
adjustment during the 90 day grace period if another re-filing or
adjustment is necessary.
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Timely Filing Limits
• The claim may be re-filed during the 90-day grace period as many
times as necessary, but claims filed after the 90 day grace period will
be denied.
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Timely Filing Limits
Exceptions to the filing limit:
When other primary payers have denied or made payment on a
claim, the filing limit of 90-days is counted from the date of payment
or denial by the other party, but not to exceed 210 days from the
date of service. A provider should file claims in sufficient time with
other payers to allow submission in time to meet the Medicaid 210
day limit.
When the recipient has retroactive eligibility, the initial filing limit is
120 days from the date the eligibility was added to the eligibility file
and was therefore available to providers.
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Timely Filing Denials
Exceptions to the filing limit:
When the provider was not originally enrolled as a MAD provider on the
date of service, the filing limit of 90 days is counted from the date the
provider was notified of their enrollment, but must not exceed 210 days
from the date of service.
A provider should submit a provider
participation agreement in sufficient time to allow processing and still
meet the Medicaid 210 day limit for submitting the claim.
When a claim previously paid by a Medicaid managed care organization
is recouped from a provider due to retroactive disenrollment of the client
from the managed care organization, the filing limit of 90 days is counted
from the date of the managed care organization’s notice or recoupment
from the provider.
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Timely Filing Denials
Re-filing Claims and Submitting Adjustments
When resubmitting a claim or requesting an adjustment on a claim that is
past the 90 day filing limit but originally met the filing limit, the “TCN”
number which appears on the remittance advice (RA) will be used by
Xerox to evaluate the claim. The provider must supply that TCN number
in order for Xerox to be able to evaluate the claim.
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Timely Filing Denials
Re-filing Claims and Submitting Adjustments
CMS 1500 form: Put the TCN in block 22 on the paper form. Leave the
“Code” blank, and put the TCN in the “Original Reference No.” field.
UB Form: Put the TCN in Form Locator 64 “Document Control Number”
(DCN) matching the appropriate payer line, using a paper form.
Dental Claim Form: Enter the TCN number in Box 35 beginning on the
left side.
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Timely Filing Helpful Hints
There are two filing limits to meet - the initial filing limit and the grace period limit.
Continuing to re-file a claim does not continue to extend the filing limit. It is to the
provider’s advantage to file or request an adjustment on the most recently filed
claim that met the original filing limit.
• When requesting an adjustment on an adjusted claim, use the TCN of the final
payment or denial, not the credit record which has a negative amount on the
RA.
• The filing limit does not apply when the provider is returning an overpayment to
the Medicaid program.
• When submitting a paper claim each claim needs a cover letter and any
necessary attachments explaining what the claim.
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Electronic Claim Submissions
Electronic Claim Submission
All Fee For Service claims within 90 days from the initial date of service
that do not require an attachment for payment must be submitted
electronically.
For any assistance regarding Electronic Claims Submissions,
contact the HIPAA Helpdesk.
[email protected]
or call 800-299-7304
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Three Ways to Submit Claims Electronically
•PayerPath – Free HIPAA Compliant web-based claims entry
system.
The URL to the registration form for PayerPath submissions is:
http://www.hsd.state.nm.us/mad/hipaa.html
*Pay attention to the RA Newsletter, for upcoming updates to PayerPath.
•Through a Clearinghouse
•EDI Gateway
The URL for additional information regarding EDI Gateway electronic
submissions is:
http://www.hsd.state.nm.us/mad//pdf_files/Converting%20from%20TIE%2
0to%20ACS%20EDI.pdf
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Claim Form Instructions
Where to get a copy of claim form instructions
Click Forms ,
Publications, and
Instructions under
Provider Information
Where to get a copy of claim form instructions
Scroll down
Open
Claim Reference Tools
What is a Transaction Control
Number (TCN)?
The TCN is a unique number assigned to each and every claim.This
number contains information about the claim and can be used to identify
the claim when calling provider services.
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What is a Transaction Control Number (TCN)?
91308700085000001
The first digit indicates
what the claim “media” is:
Batch number
The twelfth digit
in an adjustment/
void TCN will
either be:
1= Debit
2= Credit
2 = electronic crossover
3 = other electronic claim
4 = system generated
claim or adjustment
8 = paper claim
The last two
digits of the
year the
claim was
received
The numeric
day of the
year.
The claim number within
the batch.
9 = Web portal claim entry
This is the Julian Date - this represents the date the claim
was received by Xerox: this claim was received the 87th
day of 2013, or March 28, 2013
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Claim follow up
Check for claim status on the Web Portal.
•
Claim specific search capability is available using the web
portal to locate specific claims quickly.
https://nmmedicaid.acs-inc.com
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Claim follow up Reading the Remittance Advice
(RA)
The Remittance Advice, also known as an Explanation of
Benefits (EOB), is produced weekly.
The RA lists Claims Xerox has processed for a particular
provider, explaining which claims are pending, paid, or denied,
and the reason for any denials.
A financial summary is also included in the RA.
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