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Kara Newbury – Acting on CMS' 2025 Final Payment Rule
44 Plays3 days ago
We had the chance to sit down with Kara Newbury, ASCA’s Chief Advocacy Officer, to discuss what ASCs can expect in 2025. CMS officially published its 2025 Final Payment Rule, so we covered Medicare reimbursement rates, changes to the ASC Covered Procedure List, updates to the ASC Quality Reporting Program, and some other topics that every ASC should be aware of.
After my conversation with Kara, we’ll switch to our Data & Insights segment. In September, HST released our annual State of the Industry report, which analyzed client data from 590 surgery centers. Today, I’ll share with you the numbers we were able to put together regarding OR efficiency and patient throughput. We’ll look at OR Start Time, OR Duration, OR Turnover, and Recovery times.
Also, this week’s episode will be our last one in 2024. There will not be any new episodes on December 24th or December 31st, but we will hit the ground running on Tuesday, January 7th, with a brand new series on payor contracts. If you need content to hold you over, please see the list of educational resources below.
So, with that, we hope you all enjoy the holiday season with your loved ones, and we will see you after the New Year.
Resources:
- Connect with Maia Kunkel from ASCA for help scheduling a facility tour
- HST’s State of the Industry Report
- ASC Data & Benchmarking Video Playlist
- Content Bundles by Topic (board meetings, OR utilization, EMRs, etc.)
Brought to you by HST Pathways.
Recommended
Transcript
Introduction and Guest Introduction
00:00:01
Speaker
Welcome to This Week in Surgery Centers. If you're in the ASC industry, then you're in the right place. Every week, we'll start the episode off by sharing an interesting conversation we had with our featured guests, and then we'll close the episode by recapping the latest news impacting surgery centers. We're excited to share with you what we have, so let's get started and see what the industry's been up to.
00:00:28
Speaker
Hi, everyone. Here's what you can expect on today's episode. I had the chance to sit down with Cara Newberry, ask his chief advocacy officer to talk about what ASCs can expect in 2025. CMS officially published their 2025 final payment rule, so we covered Medicare reimbursement rates, changes to the ASC covered procedures list, updates to the ASC quality reporting program, and some other topics that ah every ASC should be aware of. After my conversation with Kara, we'll switch to our data and insight segment.
HST's Industry Report Preview
00:01:01
Speaker
HST released our annual City of the Industry report this past September, which analyzed client data from 590 surgery centers. So today I'll share with you the numbers we were able to put together regarding OR efficiency and patient throughput. So we'll look at OR start time, OR duration, OR turnover times, and recovery times.
00:01:21
Speaker
Also this week's episode will be our last one in 2024. So there will be no new episodes on December 24th or December 31st, but we will hit the ground running on Tuesday, January 7th with a brand new series on payer contracts.
00:01:37
Speaker
If you need content to hold you over in the meantime, the state of the industry report I mentioned has over 50 chapters. We have a ton of data and insights videos on our YouTube channel. And we've recently released new content bundles on our website, which cover tips for preparing for quarterly board meetings, improving OR utilization, convincing physicians to switch to an EMR, how to expand your surgery center, and a lot more.
00:02:02
Speaker
And as always, I'll link to everything in the episode notes so you can easily find all those resources I just mentioned. So with that, a huge thank you to all of you who have tuned in this year, been guests, been listeners, everything in between. I really appreciate it. I hope you all get to enjoy the holiday season with your loved ones and I will see you after the new year. Hope everyone enjoys the episode and for the final time in 2024, here's what's going on this week in Surgery Centers.
Medicare Reimbursement Rates Discussion
00:02:33
Speaker
Hi, Kara. Welcome back to the podcast. Thanks for having me, Erica. So I'm sure all of our listeners are very familiar with you, especially this time of year, but can you please share a little bit more about yourself and your role at ASCA? Sure. So Kara Newberry, I've been with ASCA now for 13 years and I currently serve as the chief advocacy officer for the associations. I spearhead a lot of our regulatory affairs though.
00:03:02
Speaker
specifically and help develop strategy moving forward for our advocacy efforts. Awesome. And that's exactly why we wanted to have you on again. I think this is our third year recapping the final payment rule, but I just want to make sure our listeners as always understood exactly what it contains and what their next steps are. So to start, could you please give us a quick overview of the Medicare reimbursement rates for 2025?
00:03:30
Speaker
Absolutely. And we are specifically talking about the ASC payment system. So we're not diving into the physician fee schedule. I think you've had Alex Tyra on our team on to discuss that in the past. He's he's really our in-house expert on that, but this is for the facility fee portion because that's what our ASCs are most concerned about. So for 2025, ambulatory surgery centers are set to get a 2.9% effective update.
00:04:00
Speaker
Across all codes, of course, that varies significantly sometimes even by specialty or different codes, but 2.9% overall, that is the same update that hospital outpatient departments are set to receive. So for the last, now it'll be seven years. ah We have received the same update as hospital outpatient departments prior to 2019.
00:04:24
Speaker
We were updated based on the consumer price index for all urban consumers, which is historically a lower and increase. And we were on this trial period and we were actually hoping to extend this past 2025. But for 2025, 2.9% effective update. um It's not, we know, keeping pace with the ah increased costs that all of our facilities are facing due to anesthesia costs, other staffing.
00:04:51
Speaker
devices, implants, overhead, et cetera. But we're looking ahead to already to 2026, how we might be able to help improve the Medicare payment system. um But for right now, I guess i guess the the positive is that it's a positive update as opposed to other fee schedules, like the physician fee schedule, which saw a negative update for 2025. Wow.
00:05:13
Speaker
Okay. We'll take it. Yeah. And I know, so one thing I always look
New ASC Quality Reporting Measures
00:05:17
Speaker
for every year as does everybody else is that is the ASC covered procedures list because it can just have such an impact on a surgery center strategy and growth strategy. I do feel like we were a bit spoiled last year and then this year was a let down. So would love to hear your thoughts and what and what was finalized on the ASC CPL.
00:05:39
Speaker
And it's interesting Erica, because this was the first year that we had a more transparent, allegedly transparent open process through which ah you any interested stakeholder really could submit codes.
00:05:52
Speaker
that they wanted to see added to the ASC CPL through a CMS portal. And we were extremely disappointed that the procedures that we had submitted weren't even mentioned in the proposed rule. And then in the final rule, they were grouped by category. CMS did not choose to add any of the procedures that we wanted to see added. So our primary focus for 2025 was some cardiac codes.
00:06:18
Speaker
specifically some cardiac ablation procedures. Those were not added. And then a couple of lumbar fusion codes that we've been asking for years were not added. So that was disappointing. CMS did very generally state that they were worried about the cardiovascular codes, some of which they said had significant inpatient admissions. And then they also said some of them were non-surgical.
00:06:41
Speaker
in nature. So I guess at least we have a couple of hints of where to direct our advocacy and how to try to convince CMS to add the codes moving forward. I will say that we've been gaining momentum working closely with the Heart Rhythm Society and ACC. And so I do i am optimistic that we will see some of those procedures added in the future with the lumbar fusion codes. Honestly, CMS said that the studies that they were shown included selection bias and an absence of age group representation, which I thought was odd considering the data that we shared was specific to the Medicare populations. A lot of work to be done, but we do think that we are well equipped and we have the right messaging the right information, including outcomes data to really push for some of these procedures to be added in 2026. As you said, we were disappointed in 2020 in part because of the success we had seen in recent years. But I think that there is a lot of momentum and that there will be a big push for 2026. As you may recall, under the first Trump administration in the last year, the 2021 rulemaking, there were like 200 and some
00:07:55
Speaker
procedures added that then were taken off. So I think that there's a lot of opportunity there to try to push for some of those procedures to be added back to the ASC cover procedure list that we that are some of our members ah wanted to do. I think specifically some urology codes were on that list. Disappointing for this year, but hopefully we'll make some headway in 2026. Yeah. And okay. And it was, what is it called? the Pre proposed rule recommendation process. or rule Yeah. It was originally called the nomination process. And apparently that was too few of words. CMS had to make it much longer. Yeah. And like I said, so we'll submit through that portal again.
00:08:39
Speaker
But I think we're also ask us also planning on sending a letter to the incoming administration outlining our priorities and outlining, especially since, as I was saying, the, like the hospital market basket update is set to expire in 2025.
00:08:56
Speaker
We're set to go back on the CPIU unless the secretary of health and human services directs us to stay on the hospital market basket. So there's a lot of work that needs to be done early in the year. So we will be sending a letter in advance of that, but yeah, the March 1st deadline for what I refer to as the nomination process, but it's much wordier than that now. Yeah. And did they explain to you, it sounds like you got a little bit of feedback, but was that through that process where they're like, Hey, you guys submitted all of this. Do you know?
00:09:25
Speaker
how they chose? there no Yeah, there was no feedback in there. were the What I was citing in terms of the feedback from CMS, that was all in the final rule. And that was really all they said. They said the codes that were submitted finally in the final rule, some of them, and they gave a little bit of feedback. I will say that we had a meeting with Dr. Doug Jacobs, who's the chief transformation officer at CMS.
00:09:50
Speaker
a few months ago and he raised concerns on that call more specifically about the spine codes that we were wanting to see added and questioning maybe the efficacy of spine procedures, which I thought was interesting. He gave us a little glimpse of what we might be able to look ahead to and work with our clinicians to provide data to combat some of the concerns that were raised. But he didn't raise any concerns about the cardiovascular codes on that call. So we were flying a little blind. Cardiovascular codes in general are really tough because they fall outside of the typical surgical range. And so you really have to do a good job of putting them to the forefront, bringing them in front of CMS and also
00:10:33
Speaker
then convincing them that they're, cm convincing CMS that they're surgery like at the very least. So surgery like was this interesting term that we got added, I think back in 2019, which helped us get those PCI codes added. And so we're going to need to be able to convince CMS that these cardiac ablation codes also fall within that surgical like designation. Gotcha.
00:10:57
Speaker
All right.
Concerns About Untested Quality Measures
00:10:58
Speaker
So the next big thing that we're all looking at is the quality of reporting program. And I know there was some changes there. So what what are we expecting next year? Absolutely. Of course, as you are well aware, the OSCAPS survey goes into effect January 1. That was not in the really in the role. I think that there were some folks who thought maybe we would get a delay again or an extension. We've been talking about OSCAPS for over a decade now.
00:11:26
Speaker
It's been in various rules for a long time. And it's just come to the point where it's now finally being implemented and goes into effect on a mandatory basis starting January 1. It's already in effect in hospital outpatient apartments. So even though that wasn't in the rule, I feel like I always have to plug the fact that that does go live January 1. But we were thinking,
00:11:47
Speaker
that because of that, maybe CMS would not add any other measures to our quality reporting program. We were mistaken. So there were three cross program measures that will also be in the hospital operation department program as well for upcoming years, the first one is set to go into effect next year. So I think it's the most important, the most time sensitive measure. That's the facility commitment to health equity measure. And so when CMS says calendar year 2025 reporting period, what they really mean is data collection and then reporting in 2026. I don't know why they don't just say that for 2027 payment determination. So the thought is that you're collecting
00:12:31
Speaker
the data or the information that you need to report on for this and reporting it by May 15th of 2026. So the facility commitment to health equity, i although it's nothing like the safe surgery checklist, I compare it to that because a lot of our members who are around back when for as long as I have been or longer know that we used to have to attest to the fact that we were using a cell a safe surgery checklist in our facilities. And this is similarly an attestation.
00:12:59
Speaker
So we're going to provide a lot more information on our website. We're looking into education offerings as well, but really it's just, there are five domains that CMS has laid out and you're attesting that your facility is committed to health equity and that you've checked these different boxes. Although ASCA is of course supportive of health equity and sees the benefit from a public health perspective, we do question this and the other health equity measures that are being added.
00:13:27
Speaker
primarily because they've never been tested in the ASC setting. And we're just unclear how ASC is the role that we play to collect and really report out some of this data. So the attestation one though, like I said, goes into effect January 1 right away and set to start reporting on that in 2026. The other two new measures are looking at social drivers of health.
00:13:54
Speaker
And so CMS is requiring the ASCs in the future. So it would start with 2026 data collection, 2027 reporting. We would collect data on our does the patient have housing insecurity? Do they have transportation issues, food insecurity? Do they feel safe at home or not? And I don't know about you, but some of these questions are ones I'm already asked at a primary care setting, but it's data that CMS feels is valuable to collect, we'll continue, like I said, to raise concerns and questions about whether ASCs are the truly appropriate site of service for collecting this data, especially since we don't we're not really equipped with social workers or some of the resources that hospitals have to provide assistance if our patients raise concerns or say that they have some of these food or housing or really safety insecurities. More to come on that, I do think
00:14:50
Speaker
that there's a chance under a new administration that these measures get delayed or potentially even removed. But we are encouraging, of course, our membership to continue as they are in place because they are currently and they're currently mandatory. So, like I said, more to come on our website and through education on these measures. I also feel like I need to add that MASCA, since its inception, has been really advocating against the COVID vaccination measure. Once again, not because obviously obviously we don't think that it's valuable information to collect for some organizations, but and we just didn't don't think that it's appropriate for ASCs. And so I do think that there is a good possibility that in the future, ASC20, that COVID vaccination measure does get removed.
00:15:41
Speaker
But for right now, as long as it's in place, we do want to make sure that everybody is collecting that data, reporting it, and making sure that they have it uploaded every quarter ah so that they're complying and that they will be able to get that 2% update annually. Sure. Yeah, I think the conversation around the social determinants of health is interesting because you probably remember this, but I think it wasn't 2022 or 2023, Maura Cash spoke at ASCA about the ASC's role more so about disparity of care, like at a higher level. And just some questions you could be asking during the pre-assessment process. But to your point, and this is more on the technical side, but if the physician office is already collecting that information to some degree, can that just be passed through? And would that be considered the ASC collecting it as well?
00:16:35
Speaker
and i i do't want i
Addressing Social Determinants of Health
00:16:37
Speaker
I saw that Maura posted something on Ask a Connect this week and I thought it was a really great and thoughtful posts, and actually we were talking, intern we need to reach out to Maura and see if maybe she could potentially help with some of our education. But yeah I think she raises, she raises good points and it is valuable information to collect. I think it's just the fact that these measures have not been tested in the ASC setting. And so there's a lot of uncertainty. And so if the data can be just taken from the physician office and put into the record, or we can just check that box that we know that it's there.
00:17:10
Speaker
and that counts, then I think that it's not a huge lift. I think our biggest concern, and this is a long standing concern of ASCAs, is that it seems like CMS has added, has created dupless duplicative measures. And we've seen this with some of the colonoscopy measures, the currently voluntary ophthalmic measure, and Why are we collecting and reporting on the same data if we're already getting it to your point from the physician office? So I think that there needs to be better coordination there, not just by us. It's often said ASCs need to be better partners in coordination of care. And I agree. And I understand that, but I think CMS also needs to facilitate that coordination better. Yeah, definitely. And at total, how many measures are there now?
00:18:01
Speaker
So right now there are 12 measures on which our update is based for submission for 2025. five So there are eight measures that see that um our facilities actually have to proactively go online and submit, seven through QualityNet, and one the COVID vaccination measure through the NHSN portal, which is the CDC's portal. And then there are four other measures that CMS gets the data from the hospital claims, so those are the seven-day follow-up measures. it's there are There's what? We're on number 21 or whatever total. we've removed some We've removed some. Some haven't gone into effect yet, but really from an ASC's burden perspective, right now there's only eight that they are responsible for proactively reporting, of course.
00:18:50
Speaker
the data collection for ASC 15, which is the OSCAPS measure starts next year. There are 13 measures that are there for next year that they're going to have to worry about, but I think it's time for a more holistic and a renewed look at our quality reporting program. One of the things that we put in our comment letter was from our perspective, the the quality reporting program should benefit patients and the public.
00:19:17
Speaker
looking at the data and then the facility being able to improve their facility and the outcomes of that facility based on that data. And if neither of those exist, what are we doing here? And so I think we need to be looking at things through that lens, making sure that the patients and the facility have the opportunity to see what's happening and improve based on what's in the Quality Reporting Program.
00:19:39
Speaker
Yeah, because that's what I was just thinking too. it's Of course, no one's going to roll their eyes at wanting to make sure their their patients are properly cared for. But when you think about the work and all the other data points they're already collecting, it's like they're bursting at the seams. They're just continuing to add more and more measures. I think that's something too. Can we somehow get credit for or be looking at some of the information that's already being collected by our facilities?
00:20:09
Speaker
And so I know that ASCQC, which I believe Maura is a part of, is working on some of that. And they've just actually created and released a tool that'll be coming out for prime time. It's been tested, but a tool where facilities can go in and check that they're doing all the things that they need to be doing to operate a safe ASC. And so I think that'll be good to show CMS moving forward. We are interested in working with CMS to see about like the culture of safety survey, which is something I know a lot of our facilities are ah already using, which the ah staff and physicians are interviewed to see basically if everybody's on the same page for how comfortable people within the facility would feel speaking up, speaking out about things they see that they think need to be improved upon within the facility. So I think there are other opportunities for growth within the AIC Quality Reporting Program. We're just questioning whether some of what's been added, especially because it has not been tested in our setting, are the appropriate measures. Sure.
00:21:08
Speaker
With the final payment rule, is there anything else that you think our listeners should be aware of or keep a close eye on? I think as you and I were talking about before we jumped on, besides really the quality reporting measures, there wasn't a lot in this rule. I don't know if it's the quiet before the storm or what have you. I think there will be an increased push to add procedures to the ASCPL in the future. We have hopes of overhauling are really our our entire Medicare payment system. We were in talks four years ago, four and a half years ago with CMS about removing the ASE weight scaler, which is a significant cut to our payment weights when they come over from the HOPD setting every year. So there's a lot that we're working on to try to ensure you know that the reimbursement is not only increasing, but that it's adequate
00:22:02
Speaker
to meet the needs of our facilities. But I think that that really the reimbursement rates and the ASC quality reporting program and the ACCPL are consistently top of mind. And I think that will remain. So I will just plug really quickly that we are separating out next year. ASCA is going to separate out our copay cap legislation from the rest.
00:22:27
Speaker
of our ASC Quality and Access Act and really putting an emphasis and focus on that. So for those of you who are not aware, there's a cap on what a beneficiary would pay in the hospital outpatient department setting. It's currently $1,632. So if somebody is having a surgery done in an ASC and they're paying more than $1,632, they're paying more to have their surgery done in the ASC, which we think is ridiculous. And so we are asking for the same cap in the ASC setting and because we're so You know, focused on that we've decided to do a standalone piece of legislation. We've got a lot of interest um on the Hill for that. But unfortunately, that is something that has to be done through legislation. It was, it's not a change that CMS can make on its own. And so that's something that we're pushing kind of outside of the regulatory arena. But I think it's important because it will help.
00:23:19
Speaker
our members better serve their patients because a lot of physicians, they're not going to want to take their patient to an ASC if they know that patient, that beneficiary is going to pay more and often significantly more to have their surgery done in the ASC. It just doesn't make sense. More to come on that. Maybe you can have somebody come back on and talk about some of our legislative advocacy in the coming year. But I think that's the other kind of big thing that's on the horizon for us. Yeah, that's great to know.
00:23:47
Speaker
And if people want more info from ASCA, what resources can they look for? Absolutely. www.ascassociation.org is our website. We did just do a pretty big overhaul of the website, I think like a year ago. So there's a ton of information on their Medicare payment resources, quality reporting resources.
00:24:08
Speaker
more information specifically on OSCAPs for those who still haven't signed up with a vendor. And then obviously for ASCA members, we have a much more robust group of resources on our website, as well as access to myself and all of the staff to help people through a lot of the changing environment in healthcare. care Really happy to speak with folks and if they have questions, but yeah, I think starting at our website is always a good, is always a good place to begin.
Advocacy and Engagement Strategies for ASCs
00:24:38
Speaker
All right, Kara, we do this every week with our guests. What is one thing our listeners can do this week to improve their surgery centers? I would actually recommend that you contact Maya Kunkel on our staff. I'm sure she's going to be happy if she gets bombarded with people, but and try to schedule a facility tour. With the start of a new session of Congress, there's a lot of new members, and really just making sure that the elected officials that we have elected know who we are because if they don't know who we are then they could potentially act against our best interests. It can be an in-person tour, it can be a virtual tour we have, you can come to our fly in the fall, but please I do encourage everybody in whatever way that you can to get involved and really that's a great way to help your ASE succeed.
00:25:30
Speaker
Perfect. And as always, I'll include all the links and emails you just mentioned in the episode notes too. So it'll be super easy for people to find. Thank you so much for coming back again and for all your advocacy for the industry. It does not go unnoticed. Thank you so much, Erica.
Industry Best Practices and KPIs
00:25:51
Speaker
HST Pathways released an updated version of our State of the Industry report in September, highlighting best practices, key process steps, and KPIs for every step of the patient journey and for nearly every recurring administrative duty. Most importantly, using our own unique data set from our clients, we were able to extract data points so that anyone in the industry could benchmark themselves against their peers. Two quick disclaimers, we only pulled data from clients who gave us permission and we omitted any extreme outliers.
00:26:19
Speaker
So today, we're going to take a look at four key metrics that shed light on OR efficiency and patient throughput.
OR Efficiency Metrics in Orthopedic Procedures
00:26:26
Speaker
And those are OR start time, OR duration, OR turnover times, and recovery times. And to keep things consistent, I'm going to look at it all through the lens of orthopedics. But if you want to do the same using a different specialty, our state of the industry report has all these same metrics for 11 other specialties as well.
00:26:45
Speaker
Okay, so let's start from the top with start times, which really set the tone for the day. On average, an ortho procedure is going to be delayed by 13 minutes. While it's not ideal it may and may not seem significant, a procedure being delayed at all will continue to compound throughout the day, so every minute really does count.
00:27:06
Speaker
And delayed procedures can also lead to decreased OR utilization, have a negative impact on patient and family satisfaction, and could start to accumulate overtime costs for staff. A lot of ASCs will have first case on time start policies, meaning if the first case of the day starts late, they actually will cancel or postpone it to avoid that ripple effect of delays for the entire schedule. Just something to keep in mind.
00:27:32
Speaker
All right, so the procedure gets started. Let's look at OR duration. Now this is where specialty specific benchmarking is incredibly important because we wouldn't expect an ortho procedure to take the same amount of time as let's say a cataract procedure. Looking at year over year trends can provide really helpful context.
00:27:50
Speaker
But in 2024, the average ortho procedure took 66.5 minutes, and that is a one-minute increase from 2023. Now, again, that may seem insignificant, right? It's just a minute. But if you're looking at the average net revenue per minute, which for ortho cases in 2024 is $96.52, and if you're doing, let's say, 150 cases per month, that's over $14,000. So, again, every minute counts.
00:28:20
Speaker
Another way to look at OR duration is expected versus actual. So ortho is actually the only specialty in 2024 that comes in under the expected duration and does so by three minutes. So maybe that one minute increase in the average OR duration is not cause for alarm, but that is why we track these things.
00:28:40
Speaker
Okay, moving right along, the procedure is completed, so let's look at OR turnover time. Orthopedics has the second highest turnover time, averaging roughly 21 minutes. Turnover times could be improved by implementing checklists, clearly documenting staff protocol and cross-trading staff.
00:28:57
Speaker
I've also seen ASCs implement a pit crew approach, much like at a NASCAR race. And with this approach, you basically assign each team member a specific role during turnover. So that could be equipment setup, sterilization, patient prep, and that really minimizes downtime. And for those who have done it, it has been incredibly effective.
00:29:17
Speaker
And lastly, let's look at recovery times. So from 2023 to 2024, ortho recovery times did increase from 68.8 minutes to 71.8 minutes. Recovery time is a critical metric for surgery centers as it directly impacts both the patient experience and operational efficiency.
00:29:37
Speaker
However, reducing recovery time does not mean we're compromising care. It's just about optimizing the process to ensure that patients recover safely and everything is operating efficiently.
00:29:49
Speaker
So if you take a step back and think about it from the patient's perspective, on average, their procedure might start 13 minutes late, but their procedure is going to be three minutes shorter than expected. So you will make up a little time there. And then when it comes to recovery times, they will spend a little longer in recovery than the patient and your team expected them to. But by tracking these metrics, surgery centers can really enhance both operational efficiency and the patient experience.
00:30:15
Speaker
And if this is a metric that you track, please head over to HSC's LinkedIn page and leave a comment. I'd love to hear how you compare and any tips you have for others to help them improve as well. And if you're interested in more data points and use cases, subscribe to our podcast so that you don't miss any upcoming segments, or head to our website to check out the full State of the Industry report to get your hands on even more data.
00:30:38
Speaker
And that officially wraps up this week's podcast. Thank you as always for spending a few minutes of your week with us. Make sure to subscribe or leave a review on whichever platform you're listening from. I hope you have a great day and we will see you again next week.