HSAD 7301PBHL 5123

1
HSAD 7301/PBHL 5123

• MEDICARE, MEDICAID AND STATE CHILDRENS HEALTH
  INSURANCE

2
MEDICARE

• TITLE 18 SOCIAL SECURITY ACT (1964)
• IMPLEMENTED 1966
• ELIGIBILITY
• 65
• DISABLED
• END STAGE RENAL DISEASE
• QUALIFY BY HAVING 40 QUARTERS OF MEDICARE
  EMPLOYMENT (PAID PAYROLL TAX) OR MEET ONE OF THE
  OTHER ELIGIBILITY CRITERIA

3
MEDICARE ENROLLMENT, TOTAL, AGED AND DISABLED
1966-2003
41.0
START OF DISABILITY
35.0
6.0
CMS MEDICARE ENROLLMENT TRENDS, 2004
4
Table 3.7 Medicare Beneficiaries as a Share of
the U.S. Population, 1970-2030 The U.S.
population will age rapidly through 2030, when 22
percent of the populationwill be eligible for
Medicare.
22.0
2.4
18.5
19.5
2.7
15.0
13.9
13.1
2.4
15.8
12.1
1.9
1.2
1.3
12.6
9.5
12.0
11.9
10.8
9.5
Source Social Security Administration, Office of
the Actuary.
5
Table 3.6 Number of Medicare Beneficiaries,
1970-2030
The number of people Medicare serves will nearly
double by 2030.
76.8
61.0
45.9
Medicare Enrollment (millions)
39.6
34.3
28.4
20.4
Numbers may not sum due to rounding. Source
CMS, Office of the Actuary.
6
MEDICARE PART A - HOSPITAL INSURANCE

• HOSPITAL INSURANCE TRUST FUND
• 75 PREMIUM
• 25 GENERAL REVENUE
• PREMIUM PAYROLL TAX (99 OF ENROLLEES)
• EMPLOYER 1.45 (ALL
  WAGES)
• EMPLOYEE 1.45 (ALL
  WAGES)
• SELF-EMPLOYED 2.90
• PREMIUM FOR NON-QUALIFIED
• IN 2005)
• 31-39 QUARTERS 189 (209 IN
  2005)

7
MEDICARE PART A MAJOR BENEFIT COVERAGE

• INPATIENT HOSPITAL CARE (90 DAYS)
• SKILLED NURSING FACILITY (100 DAYS)
• HOME HEALTH (100 VISITS)
• HOSPICE
• INPATIENT PSYCHIATRIC (UP TO 190 DAYS)
• NOT COVERED
• LONG-TERM CARE
• CUSTODIAL SERVICES
• PERSONAL SERVICES
• HEARING AIDES, GLASSES
• DENTAL
• OUTPATIENT DRUGS (PRIOR TO 2006)

8
MAJOR PART A COST SHARING 2005

• INPATIENT HOSPITALIZATION
• DEDUCTIBLE 912 BENEFIT PERIOD
• 1-60 DAYS NO COPAYMENT
• 61-90 DAYS - 228
• 91-150 (LIFETIME RESERVE) 456
• SKILLED NURSING FACILITY
• 1-20 DAYS NO COPAYMENT
• 21-100 DAYS 114 DAY COPAYMENT
• NO PAYMENT AFTER 100 DAYS

9
MEDICARE PART B-SUPPLEMENTAL MEDICAL INSURANCE

• SUPPLEMENTAL MEDICAL INSURANCE TRUST FUND
• 25 PREMIUM
• 75 GENERAL REVENUE
• PREMIUM (VOLUNTARY PARTICIPATION 94 OF PART
  A-HI)
• 2000 45.50
• 2003 58.70
• 2004 66.60
• 2005 78.20

10
MAJOR MEDICARE PART B BENEFITS

• PHYSICIAN SERVICES
• MEDICAL EQUIPMENT
• OUTPATIENT HOSPITAL SERVICES
• RENAL DIALYSIS
• PT/ST
• OUTPATIENT MENTAL HEALTH
• HOME HEALTH (LIMITED)
• AMBULANCE
• TRANSPLANTS
• OUTPATIENT REHAB
• SOME PREVENTIVE SERVICES (SCREENINGS AND FLU
  SHOTS)

11
MEDICARE PART B COST SHARING

• PREMIUM
• 2004 66.60 PER MONTH
• 2005 78.20 PER MONTH
• 2007 INCOME LEVEL ADJUSTMENTS
• DEDUCTIBLE
• 2004 100 PER CALENDAR YEAR
• 2005 110 PER CALENDAR YEAR
• COINSURANCE
• 20 OF ALLOWED CHARGE
• 50 OF OUTPATIENT MENTAL HEALTH

12
Table 3.20 Medicare Beneficiaries With Drug
Coverage, 1992-1999
The proportion of the Medicare population with
some drug coverage during at least partof the
year increased from 1992 to 1999.
Note Data are based on the non-institutionalized
population and those who were enrolled in
Medicare at any point during the year. Source
CMS/Office of Research, Development and
Information. Data are from the Medicare Current
Beneficiary Survey.
13
MEDICARE PART D DRUG BENEFIT

• PART OF SMI TRUST FUND
• IMPLEMENTATION IN JANUARY 2006
• TRANSITION DRUG DISCOUNT CARD (JUNE 2004-DECEMBER
  2005) ESTIMATED SAVING OF 10-15
• COST (30-35) FOR TRANSITION CARD
• LOW INCOME (
• ENROLLMENT IN PRESCRIPTION DRUG PLANS (PDPS) OR
  MEDICARE ADVANTAGE PLANS (MA) FORMERLY MEDICARE
  CHOICE
• PLANS CAN DEVELOP PREFERRED DRUG LIST
• PREMIUM OF 35 PER MONTH STARTING IN JANUARY 2006

14
MEDICARE PART D BENEFITS

• DEDUCTIBLE FIRST 250
• COINSURANCE -25 OF 250-2,250 OR NEXT 2000
• NO PAYMENT BETWEEN 2,250-5,100 A GAP OF
  2,850
• CATASTROPIC COVERAGE AFTER 5,100 (3,600 OUT OF
  POCKET 25025 OF 200O NO COVERAGE GAP OF
  2,850) 2 FOR GENERICS, 5 FOR BRAND OR 5
  COINSURANCE AFTER 3,600

15
PART D- LOW INCOME ASSISTANCE

• MEDICAID DUAL ELIGIBLES WILL MOVE TO MEDICARE
  DRUG PROGRAM
• DRUG COST ABOVE THE OUT OF POCKET THRESHOLD.
• SUBSIDY
• 50 DEDUCTIBLE, 15 COINSURANCE UP TO OUT OF
  POCKET THRESHOLD AND 2 TO 5 COPAYS ABOVE
  THRESHOLD.

16
MEDICARE PART D ISSUES

• IMPACT ON EMPLOYER SPONSORED PLANS THAT PAY DRUGS
  FOR RETIREES- MEDICARE WILL PROVIDE SUBSIDIES TO
  EMPLOYERS
• MEDIGAP PLANS-WILL NOT BE ALLOWED TO INCLUDE DRUG
  COVERAGE TO SUPPLEMENT PART D
• MEDICAID STATES WILL PAY MEDICARE FOR AMOUNT
  THEY WOULD HAVE SPENT ON DUAL ELIGIBLES (CLAWBACK
  PROVISION)

17
OTHER MEDICARE BENEFITS TO BE ADDED IN 2005

• INITIAL COMPREHENSIVE EXAM WITHIN SIX MONTHS OF
  ENROLLMENT (SCREENING TESTS, PAP, PROSTATE,
  COLON, OSTEOPOROSIS, ADL ASSESSMENT, ETC.)
• DIABETES SCREENING TWICE A YEAR
• 5 YEAR CHOLESTEROL TEST

18
Medicare Spending
Overall Medicare spending grew from 3.3 billion
in 1967 to nearly 241 billion in 2001.
Dollars in Billions
Note Overall spending includes benefit dollars,
administrative costs, and program integrity
costs. Represents Federal spending only.
Source CMS, Office of the Actuary.
Section III.C. Page 2
19
Growth in Aggregate Medicare Personal Health Care
Spending
Following rapid growth in expenditures in the
early 1990s, the Balanced Budget Act reduced the
rate of spending growth between 1997 and 1999.
The Balanced Budget Refinement Act contributed to
a resurgence of spending in 2000.
Percent
Source CMS, Office of the Actuary, National
Health Statistics Group.
20
Table 3.4Where the Medicare Dollar Went 1980
and 2001
Medicare spending has moved from inpatient
hospital services to outpatient settings.
2001
1980
Outpatient Hospital and Other Outpatient
Facility1 5.3
DME, Supplies, Independent Labs and Other
Services2 7
HHA 2.2
Outpatient Hospital and Other Outpatient
Facility1 8
Hospice 1
Physician 24.1
Managed Care 18
SNF 1.1
HHA 4
Inpatient Hospital 39
Physician 17
Inpatient Hospital 67.4
SNF 5
Total 236 Billion
Total 37 Billion
1 Other outpatient facilities include ESRD
freestanding dialysis facilities, RHCs,
outpatient rehabilitation facilities, and
federally qualified health centers. 2 Other
services include ambulatory surgical center
facility costs and ambulance services. Note Data
do not sum due to rounding. Spending includes
benefit dollars only. Source CMS, Office of the
Actuary.
21
Table 3.14 Types of Supplemental Health Insurance
Held by Medicare Beneficiaries, 2000 Most
beneficiaries have private, supplemental health
plans.
Medicare Emp. Spon. PHI 34.6
Medicare Medigap 21.1
Medicare Other 4.4
Medicare Risk HMO 16.9
Medicare Medicaid 15.3
Medicare FFS Only 7.8
Source CMS, Office of Research, Development,
and Information Data from the Medicare Current
Beneficiary Survey Cost and Use Survey (MCBS)
2000 Access to Care File.
22
Table 3.15 Medicare Beneficiary Out-of-Pocket
Spending, 1999
The majority of beneficiary out-of-pocket
spending is for Medicare cost-sharing and
payment for non-covered services.
Medicare Cost- Sharing 27
Outside Medicare Benefit Package 73
Total Out-of-Pocket Expenses Direct
Out-of-Pocket 115 billion 74 billion
These are for home health services not covered
by Medicare. Note 1) Data are for all
beneficiaries, both fee-for-service and
MedicareChoice enrollees. 2) Total per capita
direct out-of-pocket spending is 1,825. Source
CMS, Office of Research, Development, and
Information Medicare Current Beneficiary Survey
(MCBS) 1999 Cost and Use File.
23
PERFORMANCE OF PART A- HOSPITAL INSURANCE TRUST
FUNDASSETS AS A OF ANNUAL EXPENDITURES
2004 Annual Report of Medicare Trustees
24
MEDICARE ISSUES

• HOW TO FUND/FINANCE CARE FOR INCREASING NUMBER OF
  ELDERLY
• HOW TO CONTROL THE GROWTH IN EXPENDITURE (Federal
  Participation )
• HOW TO KEEP THE HI TRUST FUND SOLVENT
• HOW TO CONTROL THE DEMAND FOR ADDITIONAL
  SERVICES

25
MEDICAID
26
MEDICAID

• TITLE 19, SOCIAL SECURITY ACT
• COMBINED FEDERAL AND STATE PROGRAM
• FEDERAL GUIDELINES AND MATCH BASED ON STATE
  INCOME LEVELS
• ARKANSAS RECEIVES APPROXIMATELY 73 CENTS OF EVERY
  MEDICAID DOLLAR FROM THE FEDERAL MATCH
• FOCUS IS ON LOW INCOME, CHILDREN, AGED AND
  DISABLED POPULATIONS
• 50 STATE PROGRAMS WITH VARIATIONS BASE ON STATE
  PLANS

27
ARKANAS MEDICAID ELIGIBILITY CATEGORY

• ELIGIBILITY IS CATEGORICAL BASED ON INCOME OR
  SOME DISEASE OR FAMILY STATE (MEANS TEST)
• MAJOR ELIGIBILITY CATEGORIES
• SUPPLEMENTAL SECURITY INCOME (FEDERAL ASSISTANCE
  CATEGORY)
• AID TO FAMILIES WITH DEPENDENT CHILDREN(AFDC)/TEMP
  ORARY ASSISTANCE NEEDY FAMILIES(TANF)
• PREGNANT WOMEN (LOW INCOME)
• AID AGED, BLIND, DISABLED
• ARKids
• FAMILY PLANNING
• UNDER AGE 18
• FOSTER CARE
• QUALIFIED MEDICARE BENEFICIARY (DUAL ELIGIBLES)
• MEDICALLY NEEDY

28
Table 3.25 Medicaid Beneficiaries and Payments by
Eligibility Group, 1999 Payments for the
elderly, blind and disabled account for 71
percent of total payments.
Unknown
3
10
21
Adults
15
51
Children
72
Aged, Blind Disabled
28
FY 99
Note (1) Totals may not equal 100 due to
rounding (2) Payments describe direct Medicaid
vendor payments and Medicaid program expenditures
for premium payments to third parties for managed
care (but exclude DSH payments, Medicare premiums
and cost sharing on behalf of beneficiaries
dually enrolled in Medicaid and Medicare) (3)
disabled children are included in the aged, blind
disabled category shown above. Source CMS,
CMSO, Medicaid Statistical Information System.
29
ARKANSAS MEDICAID SERVICES COVERED

• MANDATORY FEDERAL SERVICES
• Child Health (EPSDT)
• Family Planning
• Federally Qualified Health Centers (FQHC)
• Home Health
• Hospital, Inpatient and Outpatient
• Laboratory and X-Ray
• Nursing Facility ( Over age 21)
• Nurse midwife
• Nurse Practitioner (Family and Pediatric)
• Physician
• Rural Health Clinics

30
ARKANSAS MEDICAID COVERED SERVICES

• OPTIONAL SERVICES
• Ambulatory Surgical Center Services
• Audiological Services (EPSDT, under age 21)
• Targeted case management for pregnant women
• Targeted case management for recipients age 21
  and older
• Targeted case management for recipients (EPSDT
  under 21 with DD)
• Targeted case management for recipients (EPSDT
  under 21)
• Targeted case management for recipients age 60
• Certified Registered Nurse Anesthetist (CRNA)
• Child Health Management Services (EPSDT under 21)
• Chiropractic Services
• Dental Services (EPSDT under 21)
• Developmental Day Treatment Clinical Services
  (DDTCS)
• Domiciliary Care Services
• Durable Medical Equipment
• End-Stage Renal Disease (ESRD)

31
ARKANSAS MEDICAID COVERED SERVICES

• ADDITIONAL OPTIONAL SERVICES
• Facility Services
• Hearing Services
• Hyperalimentation services
• Hospice services
• Inpatient psychiatric services under age 21
• Inpatient rehabilitation hospital services
• ICF/Mentally Retarded
• Medical supplies
• Nursing facility services (under age 21)
• OT, PT, ST services
• Orthotic appliances (under 21)
• Personal Care services
• Podiatrist services
• Portable x-ray
• Private duty nursing (Ventilator dependent)
• Prescription drugs
• Prosthetic devices

32
Table 3.30 Births Financed by Medicaid as a
Percent of Total Births by State, 1998
Medicaid pays for about 1 in 3 of the nations
births.
WA
ME
NH
VT
MT
ND
MN
OR
WI
NY
MA
ID
SD
MI
RI
WY
CT
PA
NJ
IA
OH
NE
DE
NV
IN
IL
MD
WV
UT
VA
DC
CO
CA
KS
MO
KY
NC
TN
OK
AR
SC
NM
AZ
AL
GA
MS
TX
LA
FL
AK
Less than 28.8
28.8 to 33.9
34.0 to 41.3
HI
More than 41.3
No data
Note CO, GA 1997 data KY, NJ, VT 1996
data. Source Maternal and Child Health (MCH)
Update States Have Expanded Eligibility and
Increased Access to Health Care for Pregnant
Women and Children, National Governors
Association, February, 2001, Table 23, at
http//www.nga.org.
33
U.S. MEDICAID ENROLLMENT1990-2004
CMS MEDICAID ENROLLMMENT
34
PERCENT CHANGE IN U.S. MEDICAID ENROLLMENT
FY1998-2005
KAISER COMMISSION ON MEDICAID AND UNINSURED
35
ARKANSAS MEDICAID ENROLLMENT
ARKANSAS MEDICAID REPORT2001
36
Table 3.31 Medicaid Beneficiaries by Eligibility
Group, 1975-2001
Children historically represent the largest
eligibility group of Medicaid beneficiaries.
2001 Total 46.1 million Adults 10.4
million Children Under 21 23.1
million Blind Disabled 7.9 million Age 65
Older 4.8 million
Note (1) In 1998, a large increase occurred in
the number of persons served which is mainly the
result of a new reporting methodology of
classifying payments to managed care
organizations FY 1998 was the first year
capitation payments were counted as a service for
purposes of the HCFA 2082 reporting, and thus all
managed care enrollees were counted as
individuals receiving services this new
methodology probably has the greatest effect on
the reported number of children (2) the term
adults as used above refers to non-elderly,
non-disabled adults (3) disabled children are
included in the blind disabled category shown
above. The Other category was dropped in
1999. Source CMS, CMSO, Medicaid Statistical
Information System.
37
Table 3.32 Medicaid Beneficiaries by Age, Sex,
and Race, 1998
Medicaid beneficiaries are disproportionately
female and non-white.
Sex
Age
Race
Asian 2.5
Unknown 7.4
Unknown 8.7
65 and Over 11.5
Black 24.2
White 43.1
21-64 29.9
Female 55.1
Male 36.2
Unknown 15.5
Native American .8
Under 21 51.2
Hispanic 15.6
FY 1998
Note Percentages may not sum to 100 because of
rounding. Source CMS, Office of Research,
Development and Information Data development by
Planning and Policy Analysis Group.
38
TOTAL FEDERAL AND STATE MEDICAID SPENDING
1992-2002
39
Table 3.28 Total State Spending and Federal Funds
Provided to States, 2000
Over nineteen percent of state total spending and
over forty-two percent of federalfunds provided
to states were spent on Medicaid.
Total State Spending
Federal Funds Provided to States
Higher Education 10.9
Higher Education 5.2
Elementary Secondary Education 10.5
Public Assistance 4.0
Public Assistance 2.4
Elementary Secondary Education 22.5
Transportation 9.3
Medicaid 19.5
Corrections 0.4
Transportation 8.8
Medicaid 42.6
Corrections 3.8
All Other 28.0
All Other 32.1
Note When only general funds are examined, the
proportions change somewhat. Medicaid is the
second largest state program in either total or
general funds. Source National Association of
State Budget Officers, 2000 State Expenditure
Report.
40
GROWTH IN STATE TAX REVENUE COMPARED WITH AVERAGE
MEDICAID SPENDING GROWTH 1997-2004
Kaiser Commission on Medicaid and the Uninsured
41
Growth in Medicaid Spending
Changing Medicaid eligibility rules and a
spillover effect from outreach efforts under
SCHIP led to increasing Medicaid spending in 1998
and 1999 followed by stabilization in 2000.
Peak in DSH
Welfare to Work policies
SCHIP outreach and upper payment limit effects
boosts spending
Note DSH is disproportionate share hospital.
SCHIP is the State Childrens Health Insurance
Program. For a discussion of changing eligibility
policies, see K. Levit et al., Health Spending
in 1998 Signals of Change, Health Affairs
(Jan/Feb 2000) 124-132. Source CMS, Office of
the Actuary , National Health Statistics Group.
42
ARKANSAS MEDICAID EXPENDITURES (BILLIONS)
ARKANSAS MEDICAID REPORT 2001
43
Table 3.27 Total Medicaid Expenditures by Type of
Service, 1999
The majority of Medicaid spending is for hospital
and nursing home services.
Capited Payments and PCCM Services 14
Prescription Drugs 11
Inpatient Outpatient Hospital 19
Home Health Other Community-Based Services 17

Physicians Other Practitioners 5
Institutional Long Term Care 29
Clinic, Lab X-ray 5
Total 152 Billion in FY 99
Note PCCM is Primary Care Case Management
Services. Home Health Other Community-Based
Services includes home health, personal support
services and other care services. Source HCFA
Form 64, total computable expenditures.
44
DISTRIBUTION OF ARKANSAS MEDICAID EXPENDITURES
SFY 2001
ARKANSAS MEDICAID REPORT 2001
45
FACTORS BEHIND MEDICAID EXPENDITURE
GROWTH2003-2004
Kaiser Commission on Medicaid and the Uninsured
46
Table 3.33 Medicaid Managed Care Enrollment,
1996-2001
Medicaid managed care enrollment grew rapidly
over the last decade.
Managed Care 40
48 54 56 56 57
Note The unduplicated managed care enrollment
figures include enrollees receiving comprehensive
benefits and limited benefits. This table also
provides unduplicated national figures for the
Total Medicaid population and Other population.
The statistics also include individuals enrolled
in State health care reform programs that expand
eligibility beyond traditional Medicaid
eligibility standards. Source CMS, Center for
Medicaid and State Operations National Summary
of Medicaid Managed Care Programs and Enrollment
June 30, 2001.
47
MEDICAID ISSUES

• HOW WILL STATES CONTINUE TO FUND THEIR PORTION OF
  THE PROGRAM, ESPECIALLY WITH TIGHT STATE BUDGETS
• WHAT LIMITS MIGHT THE FEDERAL GOVERNMENT PLACE ON
  EXPENDITURES
• HOW TO HANDLE THE GROWTH/DEMAND FROM AGING
  POPULATION FOR NURSING HOME ACCESS
• HOW TO FUND ACCESS FOR CHILDREN

48
MEDICAID COST CONTAINMENT STRATEGIES2002-2005

• DRUG COSTS FORMULARY
• REDUCE-FREEZE PROVIDER PAYMENT
• REDUCE/RESTRICTING ELIGIBILITY
• REDUCE BENEFITS
• INCREASING COPAYMENTS
• DISEASE MANAGEMENT PROGRAMS
• LONG TERM CARE REDUCTIONS

49
STATE CHILDRENS HEALTH INSURANCE PROGRAM
50
STATE CHILD HEALTH INSURANCE PROGRAMS

• TITLE 21 SOCIAL SECURITY ACT
• BALANCE BUDGET ACT 1997
• 40 BILLION OVER 10 YEARS
• TARGET APPROXIMATELY 10 MILLION UNINSURED
  CHILDREN
• (SCHIP) STATE CHILD HEALTH INSURANCE PROGRAM
• EXPAND MEDICAID OR STATE CAN DEVELOP A SPECIAL
  PROGRAM OR BOTH
• FOR CHILDREN
• FOR INCOME UP TO 200 OF FPL
• ARKANSAS DEVELOPED ARKids PROGRAM

51
Table 3.37 State Childrens Health Insurance
Program Enrollment by Plan Type, 2001
Most SCHIP beneficiaries received services in
states that combined aState Childrens Health
Insurance Program with a Medicaid Expansion.
Separate State Childrens Health Program 18
828,000
Medicaid Expansion 13
Combined SCHIP Medicaid Expansion 69
3,174,000
598,000
4.6 Million Total Children in FY 2001
Source CMS The State Childrens Health
Insurance Program Annual Enrollment Report FY
2001.
52
Table 3.36 State Childrens Health Insurance
Program Plan Type by State, 2002 Plan activity
as of October 2002
NH
ME
WA
VT
MT
ND
MN
OR
WI
NY
MA
ID
SD
MI
RI
WY
CT
NJ
PA
IA
NE
OH
DE
IN
NV
IL
MD
UT
WV
VA
CO
DC
CA
KS
MO
KY
NC
TN
OK
SC
AZ
AR
NM
AL
GA
MS
TX
LA
FL
AK
Separate State Child Health Plan
Medicaid Expansion
HI
Combination

State Plan Amendment
Number of Approved Separate State Child Health
Plans 16 (AZ, CO, DE, GA, KS, MT, NC, NV, OR,
PA, UT, VT, VA, WA, VW, WY) Number of Approved
Medicaid Expansions 21 (AK, AS, AR, CNMI, DC,
GU, HI, ID, LA, MN, MO, NE, MN, OH, OK, PR, RI,
SC, TN, VI, WI) Number of Approved Combination
Plans 19 (AL, CA, CT, FL, IA, IL, IN, KY, MA,
MD, ME, MI, MS, ND, NH, NJ, NY, SC, TX) Source
CMS Center for Medicaid and State Operations.
53
NATIONAL SCHIP ENROLLMENT
CMS STATE CHILDRENS HEALTH INSURANCE ANNUAL
REPORTS
54
ARKANSAS SCHIP ENROLLMENTARKids B
CMS STATE CHILDRENS HEALTH INSURANCE REPORTS
55
STATE CHILDRENS HEALTH INSURANCE ISSUES

• CONTINUED FEDERAL SUPPORT BEYOND 2007
• STATE MATCHING FUNDS TO SUPPORT THE PROGRAM
• OF FPL COVERED, LIMIT OF 200 OF FPL