Backup Documents 09/27/2011 Item #16D5ORIGINAL DOCUMENTS CHECKLIST & ROUTING SLIP
TO ACCOMPANY ALL ORIGINAL DOCUMENTS SENT TO
,w
THE BOARD OF COUNTY COMMISSIONERS OFFICE FOR SIGNATURE
ROUTING SLIP
Complete routing lines #I through #4 as appropriate for additional signatures, dates, and/or information needed. If the document is already complete with the
exception of the Chairman's signature, draw a line through routine lines #1 through #4. comnlete the checklist and forward to Ian Mitchell !line #51
Route to Addressee(s)
(List in routing order
Office
Initials
Date
1. Ashlee Franco, Accounting
Supervisor
HHVS
(A
9/27/11
2. Ian Mitchell, Executive Manager
Board of County Commissioners
AF
9/27/11
3.
Contract Agreement
Number of
3 Agreements, 2
4.
an original signature from the
Documents Attached
copies of each
Chairman needed on each copy
agreement, 1
contracts, agreements, etc. that have been fully executed by all parties except the BCC
signature per doc.
PRIMARY CONTACT INFORMATION
(The primary contact is the holder of the original document pending BCC approval. Normally the primary contact is the person who created/prepared the executive
summary. Primary contact information is needed in the event one of the addressees above, including Ian Mitchell needs to contact staff for additional or missing
information. All original documents needing the BCC Chairman's signature are to be delivered to the BCC office only after the BCC has acted to approve the
item.
Name of Primary Staff
Contact
Ashlee Franco / Housing, Human and
Veteran Services
Phone Number
252 -2689
Please call or e-mail
for pick u
Agenda Date Item was
September 27, 2011
Agenda Item Number
16D 5 (Item #3007)
Approved by the BCC
Original document has been signed/ initialed for legal sufficiency. (All documents to be
AF
Type of Document
Contract Agreement
Number of
3 Agreements, 2
Attached
an original signature from the
Documents Attached
copies of each
Chairman needed on each copy
agreement, 1
contracts, agreements, etc. that have been fully executed by all parties except the BCC
signature per doc.
Chairman and Clerk to the Board and possibly State Officials.)
(total of 6
2.
All handwritten strike - through and revisions have been initialed by the County Attorney's
AF
signatures)
INSTRUCTIONS & CHECKLIST
I: Forms/ County Forms/ BCC Forms/ Original Documents Routing Slip WWS Original 9.03.04, Revised 1.26.05, Revised 2.24.05
Initial the Yes column or mark "N /A" in the Not Applicable column, whichever is
Yes
N/A (Not
aivrotoriat e.
(Initial)
Applicable)
1.
Original document has been signed/ initialed for legal sufficiency. (All documents to be
AF
signed by the Chairman, with the exception of most letters, must be reviewed and signed
by the Office of the County Attorney. This includes signature pages from ordinances,
resolutions, etc. signed by the County Attorney's Office and signature pages from
contracts, agreements, etc. that have been fully executed by all parties except the BCC
Chairman and Clerk to the Board and possibly State Officials.)
2.
All handwritten strike - through and revisions have been initialed by the County Attorney's
AF
N/A
Office and all other parties except the BCC Chairman and the Clerk to the Board
3.
The Chairman's signature line date has been entered as the date of BCC approval of the
AF
document or the final negotiated contract date whichever is applicable.
4.
"Sign here" tabs are placed on the appropriate pages indicating where the Chairman's
AF
signature and initials are required.
5.
In most cases (some contracts are an exception), the original document and this routing slip
AF
should be provided to Ian Mitchell in the BCC office within 24 hours of BCC approval.
Some documents are time sensitive and require forwarding to Tallahassee within a certain
time frame or the BCC's actions are nullified. Be aware of your deadlines!
6.
The document was approved by the BCC on 9/27/2011 (enter date) and all changes
AF
N/A
made during the meeting have been incorporated in the attached document. The
County Attorney's Office has reviewed the changes, if applicable.
I: Forms/ County Forms/ BCC Forms/ Original Documents Routing Slip WWS Original 9.03.04, Revised 1.26.05, Revised 2.24.05
16D5
MEMORANDUM
Date: September 28, 2011
To: Ashley Franco
Housing, Human and Veteran Services
From: Teresa Polaski, Deputy Clerk
Minutes & Records Department
Re: Contract Agreement and Letter of Agreement with Naples HMA,
LLC
Attached for your records are three (3) originals of the document referenced above
(Item #16D5) approved by the Collier County Board of County Commissioners on
Tuesday, September 27, 2011.
Please forward on for additional signatures and return a Fully Executed
Original to the Minutes & Records Department to be kept in the Board's
Official Records.
If you have any questions, please feel free to contact me at 252 -8411.
Thank you.
16D5
AGREEMENT
THIS AGREEMENT is made and entered into this 27'h of September 2011 by and between Collier County,
Florida, a political subdivision of the State of Florida, hereinafter referred to as "the County" and Naples
HMA, LLC. d /b /a Physicians Regional Healthcare System, a Florida limited liability company, hereinafter
referred to as "the Hospital ".
RECITALS:
WHEREAS, Section 125.01(1)(e), Florida Statutes, authorizes the County to provide health
welfare programs for the residents of Collier County to the extent not inconsistent with general or
special law; and
WHEREAS, the establishment and maintenance of such programs are in the common interest of
the people of Collier County; and
WHEREAS, the County desires the Hospital to become a community health partner to assist in
providing payments for health prevention programs, and mental health services to residents of the
County, where no existing state or federal resources are available; and
WHEREAS, the Hospital desires to be a Community Health partner and is willing to voluntarily
provide payments for such services, subject to the terms and conditions hereinafter set forth.
NOW THEREFORE, in consideration of the covenants herein contained, the parties hereby agree as
follows:
ARTICLE I
SERVICES TO BE PERFORMED
1. The Hospital shall provide documentation and quarterly reports to the County that support
Hospital's expenditures for the delivery of hospital services, designated primary health care
services, specialty health care services and other health care services including, but not limited
to, the following services:
a. Immunization program provided by the Collier County Health Department
b. AIDS Prevention Program provided by the Collier County Health Department
c. Tuberculosis Program provided by the Collier County Health Department
d. Communicable Disease Program provided by the Collier County Health Department
e. Child Health Program provided by the Collier County Health Department
f. Healthy Start Prenatal Program provided by the Foundation for Women's Health
g. School Health Program provided by the Collier County Health Department
h. Adult Health Program provided by the Collier County Health Department
i. Dental Program provided by the Collier County Health Department
j. Community Mental Health Services provided by the David Lawrence Center, Inc.
k. Other health related programs and services -
ARTICLE II
PAYMENTS
The County shall make intergovernmental transfers, on behalf of the Hospital, in connection
with the State's Medicaid Programs — specifically the buyback of the Medicaid inpatient and
outpatient trend adjustment and self funding of exemptions - to the State of Florida in
accordance with the Letter(s) of Agreement between the County and the Agency for Health Care
Administration.
2. There are no pre- arranged agreements (contractual or otherwise) between the County and the
Hospital to re- direct any portion of Medicaid supplemental payments in order to satisfy non -
Medicaid activities.
3. The following documents are hereby incorporated by reference as Attachments to this
Agreement
a. Buy -Back Letter of Agreement with State of Florida AHCA (Attachment A)
b. Self Funding Exemptions Letter of Agreement with State of Florida AHCA (Attachment B)
ARTICLE III
CLAIMS VALUATION AND CLAIMS PROCESSING
1. As the claims processing entity, the Hospital will provide quarterly financial reports to the
County in such detail as required by the County.
ARTICLE IV
TERMS OF AGREEMENT AND TERMINATION
1. The term of this Agreement shall be October 1, 2011 through September 30, 2012.
2. Either party may terminate this Agreement thirty (30) calendar days after receipt by the other
party of written notice of intent to terminate. In the "event of termination, the County shall pay
for services rendered, prorated to the date of termination. The County shall continue to pay for
any inpatient receiving services on the date of termination until the discharge of such patient.
3. Upon breach of this Agreement, the aggrieved party may, by written notice of breach to the
breaching party, terminate the whole or any part of this Agreement. Termination shall be upon
no less than twenty -four (24) hours notice, in writing, delivered by certified mail, telegram or in
person. Waiver by either party of breach of any provisions of this Agreement shall not be
deemed to be a waiver of any other or subsequent breach and shall not be construed to be a
modification of the terms of this Agreement.
ARTICLE V
ASSIGNMENT
The Hospital and /or its sub - contractor shall not assign or transfer this Agreement, or any interest, right
or duty herein, without the prior written consent of the County, which consent shall not be
unreasonably withheld by the County. Without obtaining prior consent by the County, the Hospital shall
be allowed to assign or transfer this Agreement or any of the Hospital's obligations hereunder to
affiliates or wholly owned subsidiaries of the Hospital. This Agreement shall run to the County and its
successors.
ARTICLE VI
SUBCONTRACTING
16D5
The parties agree that the Hospital shall be permitted to execute subcontracts for the purchase by the
Hospital of such services, articles, supplies, and equipment, which is both necessary and incidental to
the performance of the work, required under this Agreement. However, the Hospital expressly
understands that it shall assume the primary responsibility for performing the services outlined in Article
I of this Agreement.
ARTICLE VII
INSURANCE, SAFETY AND INDEMNIFICATION
1. Indemnity. The Hospital and /or its sub - contractor shall indemnify the County against any
claims, damages, losses, and expenses, including reasonable attorneys' fees and costs, arising
out of, resulting from the Hospital's failure to perform its obligations under this Agreement.
Subject to the limitations set forth in Section 768.28, Florida Statutes, the County shall
indemnify the Hospital against any claims, damages, losses, and expenses, including reasonable
attorneys' fees and costs, arising out of, resulting from or in any way connected with the
performance of the County's responsibilities under this Agreement including the County's
review of all invoices to insure that no violations of state of federal laws, rules or regulations
occurs in payments made pursuant to this Agreement.
2. Insurance Required. During the term of this agreement the Hospital shall procure and maintain
liability insurance coverage. The liability insurance coverage shall be in amounts not less than
$1,000,000 per person and $2,000,000 per incident or occurrence for personal injury, death, and
property damage or any other claims for damages caused by or resulting from the activities
under this Agreement. Such policies of insurance shall name the County as an additional
insured. The Hospital shall purchase all policies of insurance from a financially responsible
insurer duly authorized to do business in the State of Florida. The Hospital shall be financially
responsible for any loss due to failure to obtain adequate insurance coverage and the failure to
maintain such policies or certificate in the amounts set forth herein shall constitute a breach of
this agreement.
ARTICLE VIII
BILLING PROCEDURES
The Hospital has standard, acceptable billing procedures that the Hospital will utilize in the performance
of its obligations under this Agreement.
The County shall provide the Hospital with invoices pursuant to this Agreement once the County has
verified the validity of the invoices to be paid by the Hospital. The Hospital will not pay any invoices
prior to the County's approval.
The Hospital shall make payment, on a voluntary basis, to specific healthcare programs and services,
such as the mental health programs of the David Lawrence Center and the Collier County Health
Department that are pre- approved by the County for payment. The Hospital shall use reasonable efforts
to pay invoices approved by the County within thirty (30) days of County approval.
For the healthcare services provided by the Hospital, the Hospital shall be reimbursed at the federally
approved Medicare rates. The County shall be responsible for verifying invoices for such services prior
to reimbursement to the Hospital. The Hospital has the right to bill the balance to the patient for any
difference between the Medicare rate and the amount the hospital is paid pursuant to the County's
authorization.
ARTICLE IX
RECORDS
1. The Hospital and /or its sub - contractor shall keep orderly and complete records of its accounts
and operations related to the services provided under this Agreement for the entire term of the
Agreement plus three (3) years. The Hospital and /or its sub - contractor shall keep open these
records to inspection by County personnel at reasonable hours during the entire term of this
Agreement. If any litigation, claim or audit is commenced prior to the expiration of the three (3)
year period and extends beyond this period the records must remain available until any
litigation, claim or audits have been resolved. Any person duly authorized by the County shall
have full access to and the right to examine any of said records during said period. Access to PHI
shall be in compliance with federal laws and HIPAA.
ARTICLE X
CIVIL RIGHTS
1. There will be no discrimination against any employee or person served on account of race, color,
sex, age, religion, ancestry, national origin, handicap or marital status in the performance of the
Agreement.
2. It is expressly understood that, upon receipt of evidence of such discrimination, the County shall
have the right to terminate this Agreement for breach of agreement.
3. The Hospital and /or its sub - contractor shall comply with Title VI of the Civil Rights Act of 1964
(42 USC 2000d) in regard to persons served.
4. The Hospital and /or its sub - contractor shall comply with Title VII of the Civil Rights Act of 1964
(42 USC 2000c) in regard to employees or applicants for employment.
5. The Hospital and /or its sub - contractor shall comply with Section 504 of the Rehabilitation Act of
1973 in regard to employees or applicants for employment and clients served.
ARTICLE XI
OTHER CONDITIONS
1. Any alterations, variations, modifications or waivers of provision of this Agreement shall only be
valid when they have been reduced to writing, duly signed and attached to the original of this
Agreement. The parties agree to renegotiate the Agreement if revision of any applicable laws or
regulations makes changes in the Agreement necessary.
2. This Agreement contains all the terms and conditions agreed upon by the parties. All items
incorporated by reference are as though physically attached. No other agreements, oral or
otherwise, regarding the subject matter of this Agreement, shall be deemed to exist or to bind
any of the parties hereto.
1605
3. The Hospital and /or its sub - contractor shall obtain and possess throughout the term of this
Agreement all licenses and permits applicable to its operations under federal, state, and local
laws, and shall comply with all fire, health and other applicable regulatory codes.
4. The Hospital and /or its sub - contractor agrees to comply with all applicable requirements and
guidelines prescribed by the County for recipients of funds.
5. The Hospital and /or its sub - contractor agree to safeguard the privacy of information pursuant to
the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
IN WITHNESS WHEREOF, the parties have executed this Agreement on the dates indicated below.
ATTEST:
DWIGHT E. BROCK, CLERK
as Clad t 1, 4 iI
k #yfldt�r,1' ;CLERK
Approval as to form and legal Sufficiency:
Jennifer B. White
Assistant County Attorney
ATTEST:
By:
Date:
BOARD OF COUNTY COMMISSIONERS
OF COLLIER COUNTY, FLORIDA
By: ) ��' —
FRED W. COYLE, CHAIRMAN I
Naples HMA, LLC., d /b /a Physicians Regional Healthcare
System, a Florida limited liability company
By:
Title:
ORIGINAL DOCUMENTS CHECKLIST & ROUTING SLIP
TO ACCOMPANY ALL ORIGINAL DOCUMENTS SENT TO ,0 5
THE BOARD OF COUNTY COMMISSIONERS OFFICE FOR SIGNATURE
ROUTING SLIP
Complete routing lines #I through #4 as appropriate for additional signatures, dates, and/or information needed. If the document is already complete with the
exception of the Chairman's sienature. draw a line through routine lines # 1 throueh #4, complete the checklist, and forward to Ian Mitchell (line #5).
Route to Addressee(s)
List in routing order
Office
Initials
Date
1. Ashlee Franco, Accounting
Supervisor
HHVS
Ck
10 /1Q /11
cll(
2. Clerk of Courts
Minutes and Records Dept., 4h Fl.
AF
10/10/11
3.
September 27, 2011
Agenda Item Number
16D 5 (Item #3065)
4.
by the Office of the County Attorney. This includes signature pages from ordinances,
Type of Document
Contract Agreement
Number of
2 Agreements, 1
Attached
an original signature from the
Documents Attached
copies of each
PRIMARY CONTACT INFORMATION
(The primary contact is the holder of the original document pending BCC approval. Normally the primary contact is the person who created/prepared the executive
summary. Primary contact information is needed in the event one of the addressees above, including Ian Mitchell needs to contact staff for additional or missing
information. All original documents needing the BCC Chairman's signature are to be delivered to the BCC office only after the BCC has acted to approve the
item.)
Name of Primary Staff
Ashlee Franco / Housing, Human and
Phone Number
252 -2689
Contact
Veteran Services
(Initial)
Please call or e-mail
1.
Original document has been signed/ initialed for legal sufficiency. (All documents to be
AF
for vick u
Agenda Date Item was
September 27, 2011
Agenda Item Number
16D 5 (Item #3065)
Approved by the BCC
by the Office of the County Attorney. This includes signature pages from ordinances,
Type of Document
Contract Agreement
Number of
2 Agreements, 1
Attached
an original signature from the
Documents Attached
copies of each
Chairman needed on each copy
agreement
INSTRUCTIONS & CHECKLIST
I: Forms/ County Forms/ BCC Forms/ Original Documents Routing Slip WWS Original 9.03.04, Revised 1.26.05, Revised 2.24.05
Initial the Yes column or mark "N /A" in the Not Applicable column, whichever is
Yes
N/A (Not
ap ropriate.
(Initial)
Applicable)
1.
Original document has been signed/ initialed for legal sufficiency. (All documents to be
AF
signed by the Chairman, with the exception of most letters, must be reviewed and signed
by the Office of the County Attorney. This includes signature pages from ordinances,
resolutions, etc. signed by the County Attorney's Office and signature pages from
contracts, agreements, etc. that have been fully executed by all parties except the BCC
Chairman and Clerk to the Board and possibly State Officials.)
2.
All handwritten strike- through and revisions have been initialed by the County Attorney's
AF
N/A
Office and all other parties except the BCC Chairman and the Clerk to the Board
3.
The Chairman's signature line date has been entered as the date of BCC approval of the
AF
document or the final negotiated contract date whichever is applicable.
4.
"Sign here" tabs are placed on the appropriate pages indicating where the Chairman's
AF
signature and initials are required.
5.
In most cases (some contracts are an exception), the original document and this routing slip
AF
should be provided to Ian Mitchell in the BCC office within 24 hours of BCC approval.
Some documents are time sensitive and require forwarding to Tallahassee within a certain
time frame or the BCC's actions are nullified. Be aware of your deadlines!
6.
The document was approved by the BCC on 9/27/2011 (enter date) and all changes
AF
N/A
made during the meeting have been incorporated in the attached document. The
County Attorney's Office has reviewed the changes, if applicable.
I: Forms/ County Forms/ BCC Forms/ Original Documents Routing Slip WWS Original 9.03.04, Revised 1.26.05, Revised 2.24.05
� r
SEP 3 0 2011
Letter of Agreement
�pp��+�.+pMEDICAID
THIS LETTER OF AGREEMENT made and entered into in duplicate on the 27th u'�3'` MAM ANALYSIS
September, 2011, by and between Collier County, (the County) and the State of Florida, through
its Agency for Health Care Administration, (the Agency),
1. Per Senate Bill 2000, the General Appropriations Act of State Fiscal Year 2011 -2012,
passed by the 2011 Florida Legislature, the County and the Agency agree that the County
will remit to the State an amount not to exceed a grand total of $1,326,164.
a. The County and the Agency have agreed that these funds will only be used to
increase the provision of Medicaid funded health services to the people of the
County and the State of Florida at large.
b. The increased provision of Medicaid funded health services will be accomplished
through the buy back of the Medicaid inpatient and outpatient trend adjustments
up to the actual Medicaid inpatient and outpatient cost but not to exceed the
amount specified in the Appropriations Act for public hospitals, including any
leased public hospital found to have sovereign immunity, teaching hospitals as
defined in section 408.07 (45) or 395.805, Florida Statutes, which have seventy or
more full -time equivalent resident physicians, designated trauma hospitals and
hospitals not previously included in the GAA.
2. The County will pay the State an amount not to exceed the grand total amount of
$1,326,164. The County will transfer payments to the State in the following manner:
a. The first quarterly payment of $331,541, for the months of July, August, and
September, is due upon notification by the Agency.
b. Each successive payment of $331,541 is due as follows, November 30, 2011,
March 31, 2012 and June 15, 2012.
c. The State will bill the County each quarter payments are due.
3. Timelines: This agreement must be signed and submitted to the Agency no later than
September 30, 2011, to be effective for SFY 2011- 2012.
4. The County and the State agree that the State will maintain necessary records and
supporting documentation applicable to Medicaid health services covered by this Letter
of Agreement. Further, the County and State agree that the County shall have access to
these records and the supporting documentation by requesting the same from the State.
5. The County and the State agree that any modifications to this Letter of Agreement shall
be in the same form, namely the exchange of signed copies of a revised Letter of
Agreement.
SFY 2011 -12 Buyback LOA Page 1
1605
6. The County confirms that there are no pre - arranged agreements (contractual or
otherwise) between the respective counties, taxing districts, and/or the hospitals to re-
direct any portion of these aforementioned Medicaid supplemental payments in order to
satisfy non - Medicaid activities.
7. This Letter of Agreement is contingent upon the State Medicaid Hospital Reimbursement
Plan reflecting 2011 -12 legislative appropriations being approved by the federal Centers
for Medicare and Medicaid Services.
8. This Letter of Agreement covers the period of July 1, 2011 through June 30, 2012.
SFY 2011 -12 Buyback LOA Page 2
1
WITNESSETH:
IN WITNESS WHEREOF the parties have duly executed this Letter of Agreement on the day
and year above first written.
Collier County
Fred W. Coyle
Chairman
a Lie T
.E D Yy
i K, le�9
4s to ChalreAn s
ature on,
SFY 2011 -12 Buyback LOA
State of Florida
Phil E. Williams
Assistant Deputy Secretary for Medicaid Finance,
Agency for Health Care Administration
A 'ov" 88 to forrn 8, teal Sufflclane",
�� ^ ►cam+ ��2 . Wi,
RECEIVED
SEP 3 0 2011
ill hi M11 V, IF-1,
Page 3
1 m r°zrl
Letter of Agreement I,k4l b Q 1'i
THIS LETTER OF AGREEMENT made and entered into in duplicate on the 27th day of
September, 2011, by and between Collier County, (the County) and the State of Florida,
through its Agency for Health Care Administration, (the Agency),
1. Per Senate Bill 2000, the General Appropriations Act of State Fiscal Year 2011-
2012, passed by the 2011 Florida Legislature, the County and the Agency agree that
the County will remit to the State an amount not to exceed a grand total of
$873,836.
a. The County and the Agency have agreed that these funds will only be used
to increase the provision of Medicaid funded health services to the people of
the County and the State of Florida at large.
b. The increased provision of Medicaid funded health services will be
accomplished through the removal of inpatient and outpatient
reimbursement ceilings for public hospitals, or any leased public hospital
found to have sovereign immunity, hospitals with graduate medical
education positions that do not qualify for the elimination of the inpatient
and outpatient ceilings under any section of the General Appropriations Act
(GAA), that provide services to Medicaid recipients or hospitals not
previously included in the GAA.
2. The County will pay the State an amount not to exceed the grand total amount of
$873,836. The County will transfer payments to the State in the following manner:
a. The first quarterly payment of $218,459, for the months of July, August, and
September, is due upon notification by the Agency.
b. Each successive payment of $218,459 is due as follows, November 30,
2011, March 31, 2012 and June 15, 2012.
c. The State will bill the County each quarter payments are due.
3. Timelines: This agreement must be signed and submitted to the Agency no later
than September 30, 2011, to be effective for SFY 2011- 2012.
4. The County and the State agree that the State will maintain necessary records and
supporting documentation applicable to Medicaid health services covered by this
Letter of Agreement. Further, the County and State agree that the County shall
have access to these records and the supporting documentation by requesting the
same from the State.
5. The County and the State agree that any modifications to this Letter of Agreement
shall be in the same form, namely the exchange of signed copies of a revised Letter
of Agreement.
SFY 2011 -12 Public Exemptions LOA Page 1
1605
6. The County confirms that there are no pre - arranged agreements (contractual or
otherwise) between the respective counties, taxing districts, and/or the hospitals to
re- direct any portion of these aforementioned Medicaid supplemental payments in
order to satisfy non - Medicaid activities.
7. This Letter of Agreement is contingent upon the State Medicaid Hospital
Reimbursement Plan reflecting 2011 -12 legislative appropriations being approved
by the federal Centers for Medicare and Medicaid Services.
8. This Letter of Agreement covers the period of July 1, 2011 through June 30, 2012.
SFY 2011 -12 Public Exemptions LOA Page 2
loos
WITNESSETH:
IN WITNESS WHEREOF the parties have duly executed this Letter of Agreement on the day
and year above first written.
Collier County
7��A..J C"
Fred W. Coyle
Chairman F",
SFY 2011 -12 Public Exemptions LOA
State of Florida
/Y'
Phil E. Williams
Assistant Deputy Secretary for Medicaid Finance,
Agency for Health Care Administration
r
prOved as to forrr, ,� legal Suf IcIg ey
s �c\Jij=c-(Z (3 .czr%� \7' �C—
V �q
SEP 3 0 2011
MEDIU
PROGRAM ANALY
Page 3