Re-examining the delivery of high-value care through COVID-19

Re-examining the delivery of high-value care through COVID-19 ...

Over the past months, the country and the economy have radically shifted to unchartered territory. Now more than ever, we must reexamine how we spend health care dollars. 

While the COVID-19 pandemic has exposed challenges with health care in America, we see two overarching opportunities for change:

1) the under-delivery of evidence-based care that materially improves the lives and well-being of Americans and

2) the over-delivery of unnecessary and, sometimes, harmful care.

The implications of reallocating our health care spending to high-value services are far-ranging, from improving health to economic recovery. 

To prepare for coronavirus patients and preserve protective equipment, clinicians and hospitals across the country halted non-urgent visits and procedures. This has led to a substantial reduction in high-value care: emergency care for strokes or heart attacks, childhood vaccinations, and routine chronic disease management. However, one silver lining to this near shutdown is that a similarly dramatic reduction in the use of low-value services has also ensued.

As offices and hospitals re-open, we have a once in a century opportunity to align incentives for providers and consumers, so patients get more high-value services in high-value settings, while minimizing the resurgence of low-value care. For example, the use of pre-operative testing in low-risk patients should not accompany the return of elective procedures such as cataract removal. Conversely, benefit designs should permanently remove barriers to high-value settings and services, like patients receiving dialysis at home or phone calls with mental health providers.   

People with low incomes and multiple chronic conditions are of particular concern as unemployment rises and more Americans lose their health care coverage. Suboptimal access and affordability to high-value chronic disease care prior to the COVID-19 pandemic was well documented  As financially distressed providers re-open to a new normal, hopeful to regain their financial footing, highly profitable services are likely to be prioritized.

Unfortunately, clinical impact and profitability are frequently not linked. The post-COVID reopening should build on existing quality-driven payment models and increase reimbursement for high-value care to ensure that compensation better aligns with patient-centered outcomes.

At the same time, the dramatic fall in “non-essential care” included a significant reduction in services that we know to be harmful or useless. Billions are spent annually in the US on routinely delivered care that does not improve health; a recent study from 4 states reports that patients pay a substantial proportion (>10 percent) of this tab out-of-pocket. This type of low-value care can lead to direct harm to patients — physically or financially or both — as well as cascading iatrogenic harm, which can amplify the total cost of just one low-value service by up to 10 fold. Health care leaders, through the Smarter Health Care Coalition, have hence called on the Department of Health and Human Services Secretary Azar to halt Medicare payments for services deemed low-value or harmful by the USPSTF. 

As offices and hospitals reopen with unprecedented clinical unmet needs, we have a unique opportunity to rebuild a flawed system. Payment policies should drive incentives to improve individual and population health, not the volume of services delivered. We emphasize that no given service is inherently high- or low-value, but that it depends heavily on the individual context. Thus, the implementation of new financial incentives for providers and patients needs to be nuanced and flexible to allow for patient-level variability. The added expenditures required for higher reimbursement rates for highly valuable services can be fully paid for by reducing the use of and reimbursement for low-value services.  

The delivery of evidence-based care should be the foundation of the new normal. We all agree that there is more than enough money in U.S. health care; it’s time that we start spending it on services that will make us a healthier nation.




Navigating a Post-Covid Path to the New Normal with Gist Healthcare CEO, Chas Roades

Covid-19, Regulatory Changes and Election Implications: An Inside ...Chas Roades (@ChasRoades) | Twitter

Healthcare is Hard: A Podcast for Insiders; June 11, 2020

Over the course of nearly 20 years as Chief Research Officer at The Advisory Board Company, Chas Roades became a trusted advisor for CEOs, leadership teams and boards of directors at health systems across the country. When The Advisory Board was acquired by Optum in 2017, Chas left the company with Chief Medical Officer, Lisa Bielamowicz. Together they founded Gist Healthcare, where they play a similar role, but take an even deeper and more focused look at the issues health systems are facing.

As Chas explains, Gist Healthcare has members from Allentown, Pennsylvania to Beverly Hills, California and everywhere in between. Most of the organizations Gist works with are regional health systems in the $2 to $5 billion range, where Chas and his colleagues become adjunct members of the executive team and board. In this role, Chas is typically hopscotching the country for in-person meetings and strategy sessions, but Covid-19 has brought many changes.

“Almost overnight, Chas went from in-depth sessions about long-term five-year strategy, to discussions about how health systems will make it through the next six weeks and after that, adapt to the new normal. He spoke to Keith Figlioli about many of the issues impacting these discussions including:

  • Corporate Governance. The decisions health systems will be forced to make over the next two to five years are staggeringly big, according to Chas. As a result, Gist is spending a lot of time thinking about governance right now and how to help health systems supercharge governance processes to lay a foundation for the making these difficult choices.
  • Health Systems Acting Like Systems. As health systems struggle to maintain revenue and margins, they’ll be forced to streamline operations in a way that finally takes advantage of system value. As providers consolidated in recent years, they successfully met the goal of gaining size and negotiating leverage, but paid much less attention to the harder part – controlling cost and creating value. That’s about to change. It will be a lasting impact of Covid-19, and an opportunity for innovators.
  • The Telehealth Land Grab. Providers have quickly ramped-up telehealth services as a necessity to survive during lockdowns. But as telehealth plays a larger role in the new standard of care, payers will not sit idly by and are preparing to double-down on their own virtual care capabilities. They’re looking to take over the virtual space and own the digital front door in an effort to gain coveted customer loyalty. Chas talks about how it would be foolish for providers to expect that payers will continue reimburse at high rates or at parity for physical visits.
  • The Battleground Over Physicians. This is the other area to watch as payers and providers clash over the hearts and minds of consumers. The years-long trend of physician practices being acquired and rolled-up into larger organizations will significantly accelerate due to Covid-19. The financial pain the pandemic has caused will force some practices out of business and many others looking for an exit. And as health systems deal with their own financial hardships, payers with deep pockets are the more likely suitor.”





Rich vs. poor hospitals

Rich vs. poor hospitals | News Break

The inequalities in American health care extend right into the hospital: Cash-strapped safety-net hospitals treat more people of color, while wealthier facilities treat more white patients.

Why it matters: Safety-net hospitals lack the money, equipment and other resources of their more affluent counterparts, which makes providing critical care more difficult and exacerbates disparities in health outcomes.

The big picture: A majority of patients who go to safety-net hospitals are black or Hispanic; 40% are either on Medicaid or uninsured.

The other side: Wealthy hospitals, including many prominent academic medical centers, are “far less likely to serve or treat black and low-income patients even though those patients may live in their backyards,” said Arrianna Planey, an incoming health policy professor at the University of North Carolina.

  • An investigation by the Boston Globe in 2017 found black people in Boston “are less likely to get care at several of the city’s elite hospitals than if you are white.”
  • The Cleveland Clinic has expanded into a global icon for health care, but rarely cares for those in the black neighborhoods that surround its campus, Dan Diamond of Politico reported in 2017.

Between the lines: The way the federal government is bailing out hospitals for the revenues they’ve lost during coronavirus is exacerbating this inequality. More money is flowing to richer hospitals.

  • For example, the main hospital within University of Colorado Health has gotten $79.3 million from the government’s main “provider relief” fund — about the same amount as Cook County Health, Chicago’s public hospital system, which predominantly treats low-income black and Hispanic people. It has gotten $77.6 million from that pot.
  • The Colorado system, however, is sitting on billions of dollars in cash and investments that Chicago’s safety-net hospitals don’t have. Chicago has also seen a worse coronavirus outbreak.

The bottom line: Poor hospitals that treat minorities have had to rely on GoFundMe pages and beg for ventilators during the pandemic, while richer systems move ahead with new hospital construction plans.





HCA nurses say they face layoffs if they don’t give up negotiated pay increases

HCA nurses say they face layoffs if they don’t give up negotiated pay increases

HCA nurses say they face layoffs if they don't give up negotiated ...

Nurses at 15 HCA hospitals represented by National Nurses United protested last week, saying the for-profit hospital chain threatened layoffs.  Nurses took to the sidewalks outside of their hospitals with signs, after they said they were told to expect cuts to benefits and staff if they didn’t give up negotiated wage increases.

In an emailed statement, HCA said it had no plans for layoffs.

letter obtained by MedCity News threatened the possibility of reductions if the nurses did not accept HCA’s proposal.

The letter stated:

“The facts are that non-represented colleagues across the HCA Healthcare enterprise are taking pay reductions and non-represented colleagues are giving up wage increases this year. HCA Healthcare has made these tough decisions in order to preserve jobs. To be equitable to all of our colleagues across the enterprise, we recently reached out to unions, with the hope that during this time of crisis, they would support the same measures for our unionized employees to minimize the impact on your compensation and employment status. …  If the (National Nurses Organizing Committee) and/or (Service Employees International Union) reject our proposal, colleagues represented by these unions will no longer be eligible for continued pandemic pay, may be subject to layoffs and may face other benefit changes.”

Nurses interviewed by MedCity News said they were asked to give up other benefits.

Zoe Schmidt, a registered nurse who works at Research Medical Center in Kansas City, said they were also asked to forego their 401(k) matching for the year and shift differential pay, or increased compensation for nurses that work night and weekend shifts.




Charting the rebound of physician office visits

MultiBrief: Telehealth is keeping doctors, patients connected in ...

As patients begin to return to doctors’ offices, we were intrigued to read an analysis out this week from the Commonwealth Fund that provides a first glimpse into the pace of the recovery. Researchers from Harvard University and healthcare technology company Phreesia analyzed data from 12M visits at over 50,000 physician practices, finding that in-person visits had declined nearly 70 percent by mid-April, compared to pre-pandemic levels.

Behavioral health providers, medical specialists and primary care practices maintained the most volume, and procedural specialists were the hardest hit. Many practices deployed telemedicine quickly, but even with those added encounters, total visits were still down by nearly 60 percent. While visits are starting to return, it’s likely that physician practices are in for a long, slow rebound. Telemedicine as a percentage of all visits peaked in late April, and by mid-May, in-person visits had reached 55 percent of pre-pandemic levels.

Even if virtual volumes pull back from their COVID high, we’re likely to see telemedicine play a much more expansive role moving forward. Dr. Rushika Fernandopulle, CEO of Iora Health, shared his company’s learnings from their COVID-19 response, predicting that ultimately 70-80 percent of physician encounters could be virtual, necessitating a need to reorganize care delivery around populations, instead of practices.

Expect the next year to be a reckoning as changes in payment and regulations, combined with a heated marketplace for virtual care, continue to shift the balance between in-person and virtual care.



Is it time for hospital at home?

JAMA - The John A. Hartford Foundation

We’ve long been intrigued by “hospital at home” care models, which deliver hospital-level care for acute conditions, supported by caregivers and technology, in a patient’s home. Stymied by the lack of payment, however, few health systems have pursued the approach. But as COVID-19 has made patients fearful of entering hospitals, we’ve had a flurry of health system leaders ask us whether they should consider launching a program now.

We think the answer is yes—with some caveats. A growing body of evidence supports its use. Cost of care is lower compared to a traditional inpatient stay. Patient satisfaction with care is high. And from a clinical perspective, hospital at home is well-established, capable of managing a number of mild- and moderate-acuity medical conditions, including exacerbations of chronic diseases like heart failure and diabetes, as well as infections like pneumonia and cellulitis, often better than a traditional hospital stay. Some programs are now using hospital at home for management of COVID-19 patients as well. Physician leaders we’ve spoken with are also interested in using the approach to manage post-operative recovery.

“Over half of our joint replacement patients spend time in skilled nursing or inpatient rehab,” one doctor told us. “People think those places are death traps now, and those cases aren’t coming back until we can find another way for them to recover.”

For patients averse to facility-based care, and systems wanting to offer an alternative, hospital at home sounds like a panacea. But experts recommend approaching it with a clear eye to the economics and ramp-up time, which can easily take 12 to 18 months. With emergency regulations released last month, Medicare will now provide payment for hospital care provided in an alternate setting, including the patient’s home—although it’s unclear whether that will continue once the COVID emergency ends. Commercial payer coverage usually requires a separate negotiation.

According to one leader, “Grass roots support of doctors is not enough. The CEO and CFO have to be on board with changing the care and payment model if it’s ever going to be more than a pilot.” But with patients and doctors becoming more comfortable with virtual care and open to new options, there is a a window of opportunity for expanding home-based care—and the longer the COVID-19 crisis lasts, the more hospital at home could provide a competitive advantage over being admitted to a busy, crowded inpatient hospital.




Majority of hospitals not meeting minimum volumes for high-risk surgeries, Leapfrog says

medical surgery

The majority of hospitals are electively performing high-risk surgical procedures without sufficient ongoing experience to safely do so, according to a new report.

The report from The Leapfrog Group, an independent hospital safety watchdog group, looked specifically at surgical volumes. The report, which relied on final hospital data from the 2019 Leapfrog Hospital Survey that had responses from more than 2,100 hospitals, also looked at the minimum standards those hospitals require surgeons to meet in order to gain privileges.

They were looking specifically at the safety of eight high-risk procedures identified by an expert panel as having a “strong volume-outcome relationship.” The report also looks at whether hospitals are working to make sure every surgery is necessary. 

According to the report, an increasing number of hospitals are meeting minimum volume standards if they perform high-risk hospitals. The majority of rural hospitals opt out of performing the high-risk surgeries because they can’t meet the volume standards. Further, more hospitals are implementing protocols to monitor for appropriateness of surgeries.

“The good news is we are seeing progress on surgical safety. The bad news is the vast majority of hospitals performing these high-risk procedures are not meeting clear volume standards for safety,” said Leah Binder, president and CEO of The Leapfrog Group, in a statement. “This is very disturbing, as a mountain of studies show us that patient risk of complications or death is dramatically higher in low-volume operating rooms.”

For instance, the report suggested hospitals should be performing a minimum of 20 esophageal resections for cancer and a minimum of 20 pancreatic resections for cancer to improve the odds of a safer surgery for their patients. Surgeons should perform at least seven and 10 of those procedures a year, respectively, to gain privileges.

But for those two procedures, only 3% and 8% of hospitals met the volume standards for patient safety, the report found.

Hospitals were most likely to meet the safety standard of a minimum of 50 procedures a year for the hospital and 20 procedures a year for bariatric surgery for weight loss. More than 48% reported meeting that standard in 2019, up from 38% in 2018.

The survey found more than 70% of reporting hospitals have protocols to ensure appropriateness for cancer procedures.

But for other high-risk procedures evaluated such as open-heart surgeries or mitral valve repair and replacement, hospital compliance with ensuring appropriateness dropped to a range of 32% to 60%, depending on the procedure.




110 hospital benchmarks | 2020

Image result for hospital benchmarks

Hospitals across the nation compete in a number of ways, including on quality of care and price, and many use benchmarking to determine the top priorities for improvement. The continuous benchmarking process allows hospital executives to see how their organizations stack up against regional competitors as well as national leaders.

Becker’s Hospital Review has collected benchmarks related to some of the most important day-to-day areas hospital executives oversee: quality, finance, staffing and utilization.


Key ratios

Source: Moody’s Investors Service, “Not-for-profit and public healthcare – US: Medians” report, September 2019. 

The medians are based on an analysis of audited fiscal 2018 financial statements for 284 freestanding hospitals, single-state health systems and multistate health systems, representing 79 percent of all Moody’s-rated healthcare entities. Children’s hospitals, hospitals for which five years of data are not available and certain specialty hospitals were not eligible for inclusion in the medians.

1. Maintained bed occupancy: 66.6 percent

2. Operating margin: 1.8 percent

3. Excess margin: 4.3 percent

4. Operating cash flow margin: 7.9 percent

5. Return on assets: 3.6 percent

6. Three-year operating revenue CAGR: 5.6 percent

7. Three-year operating expense CAGR: 6.4 percent

8. Cash on hand: 200.9 days

9. Annual operating revenue growth rate: 5.5 percent

10. Annual operating expense growth rate: 5.4 percent

11. Total debt-to-capitalization: 33.7 percent

12. Total debt-to-operating revenue: 33.3 percent

13. Current ratio: 1.9x

14. Cushion ratio: 21.6x

15. Annual debt service coverage: 4.7x

16. Maximum annual debt service coverage: 4.4x

17. Debt-to-cash flow: 3.1x

18. Capital spending ratio: 1.2x

19. Accounts receivable: 45.9 days

20. Average payment period: 61.4 days

21. Average age of plant: 11.7 years

Hospital margins by credit rating group

Source: S&P Global Ratings “U.S. Not-For-Profit Health Care System Median Financial Ratios — 2018 vs. 2017” report, September 2019.

AA+ rating

22. Operating margin: 5.5 percent

23. Operating EBIDA margin: 12 percent

24. Excess margin: 9.2 percent

25. EBIDA margin: 14.8 percent

AA rating

26. Operating margin: 4.4 percent

27. Operating EBIDA margin: 10.1 percent

28. Excess margin: 6.7 percent

29. EBIDA margin: 12.4 percent

AA- rating

30. Operating margin: 3.4 percent

31. Operating EBIDA margin: 9.5 percent

32. Excess margin: 4.0 percent

33. EBIDA margin: 10.4 percent 

A+ rating

34. Operating margin: 1.6 percent

35. Operating EBIDA margin: 7.4 percent

36. Excess margin: 3.3 percent

37. EBIDA margin: 10.1 percent 

A rating

38. Operating margin: 2.1 percent

39. Operating EBIDA margin: 7.6 percent

40. Excess margin: 3.3 percent

41. EBIDA margin: 8.6 percent

 A- rating

42. Operating margin: 1 percent

43. Operating EBIDA margin: 7.8 percent

44. Excess margin: 2.5 percent

45. EBIDA margin: 8.3 percent

Average adjusted expenses per inpatient day

Source: Kaiser State Health Facts, accessed in 2020 and based on 2018 data. 

Adjusted expenses per inpatient day include all operating and nonoperating expenses for registered U.S. community hospitals, defined as public, nonfederal, short-term general and other hospitals. The figures are an estimate of the expenses incurred in a day of inpatient care and have been adjusted higher to reflect an estimate of the volume of outpatient services.

46. Nonprofit hospitals: $2,653

47. For-profit hospitals: $2,093

48. State/local government hospitals: $2,260

Prescription drug spending

Source: NORC at the University of Chicago’s “Recent Trends in Hospital Drug Spending and Manufacturer Shortages” report, January 2019. Figures below are based on 2017 data.

49. Average prescription drug spending per adjusted admission at U.S. community hospitals: $555 

50. Average outpatient prescription drug spending per adjusted admission at U.S. community hospitals: $523

51. Average inpatient prescription drug spending per admission at U.S. community hospitals: $756

52. GPO hospital spending on Activase:  $210 million

53. GPO hospital spending on Remicade: $138 million

54. GPO hospital spending on Humira: $122 million

55. GPO hospital spending on Rituxan: $92 million

56. GPO hospital spending on Neulasta: $92 million

57. GPO hospital spending on Prolia: $85 million

58. GPO hospital spending on Harvoni: $83 million

59. GPO hospital spending on Procrit: $80 million

60: GPO hospital spending on Lexiscan: $64 million

61. GPO hospital spending on Enbrel: $60 million

Quality and process of care 

Source: Hospital Compare, HHS, Complications and Deaths-National Averages, May 2018, and Timely and Effective Care-National Averages, May 2018, the latest available data for these measures.

Hospital-acquired conditions

The following represent the average percentage of patients in the U.S. who experienced the conditions.

62. Collapsed lung due to medical treatment: 0.27 percent

63. A wound that splits open on the abdomen or pelvis after surgery: 0.95 percent

64. Accidental cuts and tears from medical treatment: 1.29 percent

65. Serious blood clots after surgery: 3.85 percent

66. Serious complications: 1 percent

67. Bloodstream infection after surgery: 5.09 percent

68. Postoperative respiratory failure rate: 7.35 percent

69. Pressure sores: 0.52 percent

70. Broken hip from a fall after surgery: 0.11 percent

71. Perioperative hemorrhage or hematoma rate: 2.53 percent

Death rates

72. Death rate for CABG surgery patients: 3.1 percent

73. Death rate for COPD patients: 8.5 percent

74. Death rate for pneumonia patients: 15.6 percent

75. Death rate for stroke patients: 13.8 percent

76. Death rate for heart attack patients: 12.9 percent

77. Death rate for heart failure patients: 11.5 percent

Outpatients with chest pain or possible heart attack

78. Median time to transfer to another facility for acute coronary intervention: 58 minutes

79. Median time before patient received an ECG: 7 minutes

Lower extremity joint replacement patients

80. Rate of complications for hip/knee replacement patients: 2.5 percent

Flu vaccination

81. Healthcare workers who received flu vaccination: 90 percent

Pregnancy and delivery care

82. Mothers whose deliveries were scheduled one to two weeks early when a scheduled delivery was not medically necessary: 2 percent

Emergency department care

83. Average time patient spent in ED after the physician decided to admit as an inpatient but before leaving the ED for the inpatient room: 103 minutes

84. Average time patient spent in the ED before being sent home: 141 minutes

85. Average time patient spent in the ED before being seen by a healthcare professional: 20 minutes

86. Percentage of patients who left the ED before being seen: 2 percent


Source: American Hospital Association “Hospital Statistics” report, 2019 Edition.

Average full-time staff

87. Hospitals with six to 24 beds: 101

88. Hospitals with 25 to 49 beds: 176

89. Hospitals with 50 to 99 beds: 302

90. Hospitals with 100 to 199 beds: 683

91. Hospitals with 200 to 299 beds: 1,264

92. Hospitals with 300 to 399 beds: 1,789

93. Hospitals with 400 to 499 beds: 2,670

94. Hospitals with 500 or more beds: 5,341

Average part-time staff

95. Hospitals with six to 24 beds: 52

96. Hospitals with 25 to 49 beds: 84

97. Hospitals with 50 to 99 beds: 141

98. Hospitals with 100 to 199 beds: 286

99. Hospitals with 200 to 299 beds: 472

100. Hospitals with 300 to 399 beds: 604

101. Hospitals with 400 to 499 beds: 1,009

102. Hospitals with 500 or more beds: 1,468


Source: American Hospital Association “Hospital Statistics” report, 2019 Edition.

Average admissions per year

103. Hospitals with six to 24 beds: 408

104. Hospitals with 25 to 49 beds: 901

105. Hospitals with 50 to 99 beds: 2,097

106. Hospitals with 100 to 199 beds: 5,809

107. Hospitals with 200 to 299 beds: 11,241

108. Hospitals with 300 to 399 beds: 16,635

109. Hospitals with 400 to 499 beds: 20,801

110. Hospitals with 500 or more beds: 34,593


Half of insured adults are skipping primary care visits. Cost a major reason why

Image result for Half of insured adults are skipping primary care visits. Cost a major reason why.

In a given year by 2016, almost 50 percent of adults with commercial insurance hadn’t visited a primary care physician, according to a study published in the Annals of Internal Medicine.

For the study, researchers from Harvard Medical School in Boston, the Icahn School of Medicine at Mount Sinai in New York City and the University of Pittsburgh School of Medicine wanted to better characterize primary care declines among adults. To do so, the study authors analyzed deidentified claims data from a national private insurer that covers roughly 20 million members each year, according to NPR.

They found from 2008-16, adult visits to primary care physicians fell by nearly 25 percent. The decline was largest among younger adults. The proportion of adults with no visits to primary care physicians in a given year climbed from 38.1 percent to 46.4 percent within the same period.

While the number of preventive checkups rose — likely because the ACA made the appointments cost-free — problem-based visits, such as going to a primary care physician for sickness or injury, declined more than 30 percent, according to NPR.

Problem-based visits saw out-of-pocket costs increase 31.5 percent during the study period, which could have affected the decline, according to researchers. Additionally, visits to alternative sites like urgent care clinics grew by 46.9 percent in the study period.

“Our results suggest that this decline may be explained by decreased real or perceived visit needs, financial deterrents, and use of alternative sources of care,” the study authors concluded. 




Seattle Children’s sues to block release of health records; top official resigns

Image result for seattle children's hospital

Seattle Children’s Hospital has filed a lawsuit to block the release of health department records regarding mold at its facility, according to court documents cited by King 5. 

The hospital’s legal team filed an amended complaint in an attempt to block the release of state and county health records.

Documents previously released to the media through a public records request revealed a nearly 20-year history of Aspergillus mold in the air handling system of the hospital’s operating rooms.

Most recently, an infant at Seattle Children’s Hospital died Feb. 12 after she developed a mold-related infection acquired at the facility, the seventh mold-related death since 2001.

The health records sought by the media are “confidential and sensitive,” Adrian Urquhart Winder, attorney for Seattle Children’s, said, according to King 5. The attorney cited a state law that says records produced for quality improvement purposes cannot be publicly disclosed.

On Jan. 10, Mark Del Beccaro, MD, former CMO and senior vice president of Seattle Children’s Hospital, resigned, according to a hospital spokesperson. King 5 could not reach Dr. Del Beccaro for comment.