SPARK Senior Health · Proprietary & Confidential · All Rights Reserved
Operations & Business Processes
People, process, and technology integration for day-one readiness
§5.1 HR & Hiring Plan §5.2 Transport & Logistics §5.3 Clinical Operations §5.4 Systems & Technology §5.5 Community Partnerships
Opening Team
NP · LPN/MA · driver per clinic
Visits / Day
10–14 target
Anchor Partners
Faith + NGHS + SNF
EHR Decision
Athelas AIR or Athenahealth
↓Begin
Stage 5 · Operations & Business Processes · Section 5.1
HR Management — Hiring Plan & Team Structure
Who to hire first, in what order, and what each role is accountable for. Each clinic opens with an NP/PA, an LPN/MA and a driver; care coordinators and front desk are added when workload justifies them. Compliance is owned at the MSO by the Chief Compliance Officer / Chief Legal Officer.
§ 5.1GA market comp 2025–2026
SPARK Senior Health staffing model
At opening: NP · LPN/MA · driver
Hiring Sequence — Opening Team (per clinic)
NP/PA, LPN/MA and driver at opening · every other role added when workload justifies it · follows the financial model's org design
1
Physician Owner + Collaborating Physician (contracted)
Georgia requires the PC to be owned by a Georgia-licensed physician: ownership, clinical authority, protocols and Medicare enrollment attestations. One collaborating physician covers up to 8 NPs/PAs (Georgia limit) and signs the NP protocol agreement filed with the GA Composite Medical Board. Contracted through Permit Health — cost pending the bid.
Pre-launch · before the NP protocol agreement and PECOS filing
2
NP / PA — Primary Clinician
Named pre-launch: NPI, GA licensure and the protocol agreement need a named clinician, and PECOS enrollment takes 60–90 days. On-site at the fixed clinic every clinical day — telehealth is an adjunct, not the care model. $147K base salary.
At clinic opening (M1 for Habersham) · named ~3 months earlier to start the PECOS clock
3
LPN / MA — Clinic Clinical Support
GA-licensed. Phlebotomy training documented before first blood draw (GA permits LPN blood draw — not automatic). ADA clinic orientation, OSHA bloodborne pathogen training. Works under NP supervision. $60K base salary (MA $50K once a 2nd full-time NP is added).
At clinic opening
4
Community Transport Driver
One van and driver per clinic from opening day. Reports to the CGO; the COO chain sets up vehicles, dispatch and Samsara monitoring (mileage log, maintenance alerts). Background check, clean driving record and HIPAA training before the first ride. Rides are not advertised and drivers do not market during rides. $45K base salary.
At clinic opening
5
Care Coordinator — workload-justified
Manages CCM time documentation (Chronic Care IQ), RPM alert monitoring (Tenovi dashboard), member scheduling (Klara), TOC outreach (Bamboo PatientPing) and referral tracking. Until hired, the NP and LPN/MA cover this work. Added when care-management workload passes 85% of a full-time load. $55K base salary.
Workload-justified · ~month 8 at Habersham (model)
6
Patient Services Representative (front desk) — workload-justified
Scheduling, check-in, insurance verification and member calls. Added when front-desk workload passes 85% of a full-time load; a second at clinics above ~750 patients. $45K base salary.
Workload-justified · ~month 10 at Habersham (model)
Compliance is an MSO function, not a clinic hire. FWA training, HIPAA BAAs, OSHA setup and OIG exclusion screening are owned by the Chief Compliance Officer / Chief Legal Officer, with a contracted Medicare enrollment consultant and HR consultant supporting launch.
Performance KPIs by Role
Monthly targets · reviewed quarterly · compliance KPIs non-negotiable
NP: CCM/APCM care plan accuracy rate≥95%
NP: Documentation turnaround (same-day)≥90% of encounters
LPN: Visits completed per day10–14 target
LPN: Member no-show rate<15%
Care Coord: CCM time log completion100% by month-end
Care Coord: RPM alert response (<24 hr)≥95% of alerts
Billing: Clean claim rate (first pass)≥92%
Billing: Days in A/R<35 days
All staff: FWA + HIPAA training100% before go-live
All staff: OIG exclusion screeningMonthly (Compliancy Group)
Compensation — Clinic Team
GA market rates 2025–2026 · model base salaries (no benefits load modeled) · driver included per clinic
NP/APRN (W-2, in-clinic)$147K/yr (model salary)
Physician Owner + Collaborating Physician (contracted)Pending Permit Health bid
LPN (W-2, clinic)$60K/yr (model salary; MA $50K once a 2nd FT NP is added)
Care Coordinator (W-2, workload-justified)$55K/yr (model salary)
Patient Services Rep (W-2, workload-justified)$45K/yr (model salary)
Driver (W-2, logistics)$45K/yr (model salary)
RCM/Billing (Commure RCM outsourced)4% of net collections
Per-clinic clinical team (approx.)~$307K–$489K/yr at ramp completion (incl. driver)
Backup staffing: Per-diem LPN pool from a healthcare staffing agency on standby. Cross-train Care Coordinator on basic scheduling and member outreach. No single point of clinical failure.
Stage 5 · Operations & Business Processes · Section 5.2
Transport & Logistics — Member Transport, Routes & Daily Operations
The van is a logistics asset — it brings members to the fixed clinic. Care is delivered at the permanent location. One driver per active clinic, AM pickup → clinic hours → PM return.
§ 5.21 driver / clinic · $45K/yr
Van = logistics only
Samsara fleet tracking
Transport Model — Fixed Clinic with Member Pickup
Van delivers members to clinic · all care at fixed ADA-compliant location · 1 van per active clinic
Core Principle
The van brings members to the clinic. The clinic delivers the care.
All clinical services, examinations, lab testing, and documentation happen at the fixed clinic. The transport van picks up members who cannot self-drive — returns them after the visit. Van contains: driver, basic first aid kit, tablet for scheduling. No clinical equipment. This distinction matters for CMS billing compliance.
AM Route — Member Pickup
7:30–9:00 AM · Route planned prior afternoon
Samsara or OptimoRoute clusters pickups by geography. Driver picks up scheduled members from home or community site. Typical: 4–8 pickups per route. All pickups logged in EHR scheduling system.
Clinic Hours — Driver Standby
9:00 AM – 3:30 PM · Driver at clinic or nearby
Driver assists with clinic logistics (supply delivery, member check-in support). Vehicle parked at clinic — visible to community, reinforces brand presence. Available for urgent needs.
PM Route — Member Return
3:30–5:00 PM · All transported members returned
All members returned to home or community site. Driver logs mileage (IRS required). Vehicle fueled, restocked if needed. Samsara records route completion automatically.
Daily Clinic Operations Flow
Monday–Friday · 7:30 AM huddle → 5:00 PM clean claim close
1
7:30 AM — Morning Huddle
LPN + NP teleconference (Doxy.me, 10 min). Day's schedule, overnight RPM threshold breaches, care gap alerts, driver confirms pickup route. Non-negotiable.
2
8:00 AM — Clinic Opens · Driver Departs
LPN prepares exam room, Vital Signs Station, i-STAT POC lab supplies. Driver departs on AM pickup route. EHR loaded with day's schedule and AI pre-visit notes.
3
9:00 AM – 3:30 PM — Encounters
10–14 visits/day. Each: AI-assisted intake (10 min) → NP exam via Doxy.me or in-clinic (15–20 min) → checkout, care plan update, next visit scheduled. Commure Ambient scribes in real time.
4
4:00 PM — Documentation Window
NP closes all visit notes (Commure AI drafts, NP validates). LPN restocks, disposes sharps per OSHA. Care coordinator reviews RPM alerts and updates Chronic Care IQ time logs.
5
5:00 PM — Claims Submission
NP-validated notes → Commure RCM charge capture → Palmetto GBA J-J submission. QMB flag verified before submission. Target: $0 next-day unbilled encounters.
Vehicle Maintenance & Backup Protocol
Preventive schedule · breakdown response · IRS mileage log via Samsara
Preventive
Weekly: sanitation, supply check. Monthly: oil, fluids, tire pressure. Quarterly: full service per van schedule. Annual: GA vehicle inspection. All scheduled in Samsara maintenance module.
Breakdown Response
Rental standby contract (Enterprise/Penske) activated within 2 hours. Care coordinator reschedules all affected members. Priority: RPM-enrolled and TOC patients within 30-day window.
Mileage & Fuel
IRS mileage log auto-maintained via Samsara GPS. Fuel card issued to driver — single account. Target: <$0.55/mile all-in. Samsara monthly report feeds MSO ops review.
Stage 5 · Operations & Business Processes · Section 5.3
Clinical Operations — Visit Flow, CCM/APCM, RPM & Escalation
Day-to-day clinical workflow from member check-in through visit completion, monthly CCM/APCM documentation, RPM monitoring, and escalation decision tree. Every step is billable or compliance-critical.
§ 5.3LPN → NP → MD → 911
CCM: 20-min monthly doc
RPM: 16-day data threshold
Visit Flow — Check-In to Billing
Every encounter follows the same protocol · Commure AI scribes in real time
①
Member Check-In & AI Intake (10 min)
Klara SMS check-in. LPN captures vitals (Vital Signs Station: BP, weight, SpO2, temperature). i-STAT POC lab if ordered. Commure AI surfaces prior visit note, medication list, active diagnoses, care gaps, RPM alerts. Structured pre-visit note pushed to NP before exam room opens.
②
NP Exam (15–20 min)
NP conducts clinical assessment — in-clinic or via Doxy.me. Commure Ambient scribes in real time. NP diagnoses, prescribes, orders labs, codes visit. LPN present throughout. Documentation complete before member exits.
③
Care Plan Update & CCM/APCM Check
NP updates care plan in Chronic Care IQ. Confirms monthly CCM/APCM clock status. If AWV visit: initiates CCM/APCM consent and enrollment workflow. Care coordinator notified of new enrollments in real time.
④
Checkout & Next-Visit Scheduling
LPN schedules next appointment before member leaves. QMB status verified in EHR — coinsurance billing suppressed automatically. Member receives written visit summary (CMS CCM requirement).
⑤
Same-Day Claim Submission
NP validates Commure AI note → Commure RCM charge capture → billing review → Palmetto GBA J-J submission. QMB flag confirmed. Target: zero next-day unbilled encounters.
CCM / APCM & RPM Monthly Protocol
Non-visit recurring revenue · runs every month between encounters
CCM Monthly Checklist (per member)
□ 20-min contact clock running · activity-specific log entries
□ Care plan reviewed and updated this month
□ Medication reconciliation documented
□ Specialist referral follow-up logged
□ Member consent on file and current
□ NP co-signature on monthly note before claim
APCM Monthly (G0558/G0557/G0556)
□ Enrolled with signed consent on file
□ Active care plan maintained in EHR
□ No concurrent CCM for same member same month
□ Eligibility confirmed (QMB status for G0558)
RPM Monthly Checklist
□ ≥16 days transmitted data (99454) · or 2–15 days (99445 new 2026)
□ Staff clinical review ≥20 min documented (99457)
□ Alert events logged with response action + timestamp
□ Tenovi server log exported for audit
Escalation Protocol — LPN Clinic Decision Tree
Every condition has a predefined pathway · LPN never acts unilaterally
Stable, routine: LPN completes intake vitals, NP conducts exam. Standard encounter — no escalation.
Elevated concern (BP >180/110, SpO2 <92%, acute pain): LPN alerts NP immediately. NP decides: manage in-clinic, urgent consult, or direct to ER. LPN does not act without NP direction.
Life-threatening (chest pain, FAST stroke signs, unresponsive): LPN calls 911 + NP simultaneously. NP stays on line directing LPN until EMS arrives. Document exact time, presentation, actions.
Post-escalation: Care coordinator initiates TOC protocol (Bamboo PatientPing). NP coordinates with NGHS receiving hospital. Full escalation chain documented in EHR within 2 hours.
Stage 5 · Operations & Business Processes · Section 5.4
Systems & Technology — Stack, Architecture & Workflow Integration
The finalized technology backbone — EHR, AI documentation, CCM platform, RPM, billing, connectivity, and fleet. All systems selected, priced, and integrated end-to-end from intake to Palmetto GBA J-J.
§ 5.4EHR: Athelas AIR / Athenahealth
Commure RCM + Ambient AI
Palmetto GBA J-J · HIPAA-grade
EHR — Final Two Candidates
Selection required by Month 2 · must be live before first billable encounter
Candidate A — AI-Native
Athelas AIR
AI-native EHR built for value-based primary care. Strong CCM/APCM workflow integration. Native Commure compatibility. Purpose-built for chronic care management model. Confirm offline mode and Palmetto GBA J-J EDI in demo.
Candidate B — Cloud-Native · Large Network
Athenahealth
Cloud-native, strong billing integration, HEDIS tracking dashboard, large rural clinic network. Proven Palmetto GBA J-J EDI compatibility. Confirm offline mode (critical for NE Georgia connectivity gaps) and Chronic Care IQ API.
Common requirements for both: HIPAA BAA · Commure Ambient integration · Chronic Care IQ API · Palmetto GBA J-J EDI · offline mode for rural dead zones · QMB billing flag at intake
Commure Stack — Sits On Top of EHR
Commure Ambient AI ($100/provider/mo)
Ambient scribing during all encounters. CPT coding suggestions validated by NP. Note drafted before patient exits. Reduces per-visit documentation from ~12 min to under 3 min. NP validates every note.
Commure RCM (4% of net collections)
Charge capture → coding review → Palmetto GBA J-J submission → ERA reconciliation → denial management. QMB coinsurance billing suppressed automatically. Scheduling bundled at no additional cost.
RPM & Care Management Platforms
Tenovi 4G cellular devices · Chronic Care IQ CCM/APCM platform
Tenovi RPM — $40 COGS/enrolled/month
4G cellular hub (no WiFi required) + BP cuff + weight scale + SpO2 + glucose. Auto-uploads daily. Alert thresholds: BP ≥180/110, weight gain ≥2 lbs/24h (CHF), SpO2 <88% → same-day coordinator contact. Server logs = 99454 billing audit trail.
Chronic Care IQ — $6/enrolled member/month
CCM/APCM panel management, care plan templates, auto-time log from coordinator activity (primary OIG audit defense), HEDIS gap tracking, monthly billing-ready documentation. EHR API integration.
Bamboo Health PatientPing — $1,500/month portfolio
ADT feeds from NGHS and Stephens County Hospital. When a SPARK Senior Health-enrolled member is discharged, care coordinator is notified within 24 hours — initiating the TOC billing window (99495/99496).
Infrastructure & Operations Stack
Always-on clinic · HIPAA-grade network · MDM-enrolled devices
Connectivity — $400/clinic/month
Fiber primary + cellular LTE failover. Sub-30-second automatic switchover. Clinical VLAN isolated from guest WiFi. EHR offline mode required. Fiber 4–8 week install lead time — order during buildout.
Patient Engagement — Klara $300/clinic · Doxy.me $235/clinic
Klara: HIPAA-compliant SMS check-in, appointment reminders, care gap outreach. Doxy.me Pro + Zoom for Healthcare: NP telehealth supervision. All HIPAA BAAs in place before go-live.
Ops Stack — Rippling $12/emp/mo · Compliancy Group $400/mo · Samsara $40/vehicle
Rippling: HR/payroll + MDM for all clinic devices + OIG exclusion screening. Compliancy Group: HIPAA compliance + BAA tracking. Samsara: fleet tracking + mileage log.
Systems Architecture — End-to-End Operational Flow
EHR is system of record · all other platforms connect via API · no manual dual-entry anywhere
📱
Klara / AI Intake
SMS check-in · pre-visit note
→
💻
EHR + Commure
Athelas/Athena · ambient scribing
→
💰
Commure RCM
Palmetto GBA J-J · same-day claim
Chronic Care IQCCM/APCM time logs auto-populated · care plan templates · HEDIS gaps → 99490/G0558 billing
Tenovi RPM4G auto-upload → alert thresholds → coordinator → 99454/99457 codes · server logs = audit trail
Bamboo PatientPingNGHS ADT feeds → TOC outreach 24hr → 99495/99496 billing window triggered
Samsara + Rippling + CompliancyFleet tracking + mileage · HR/payroll/MDM · HIPAA compliance
Stage 5 · Operations & Business Processes · Section 5.5
Community Partnerships — Enrollment Channels & Clinical Integration
Enrollment in rural NE Georgia runs on trust, not marketing spend. Four primary enrollment channels, three clinical integration partners, and NGHS as the strategic anchor for the entire portfolio.
§ 5.5NGHS anchor partner
Faith · hospital · SNF
NEMT reciprocal referral
Primary Enrollment Channels — Ranked by ROI
Warm referral sources · trust is the enrollment currency in rural NE Georgia
⛪
Faith Organizations (Highest ROI)
Fixed clinic within 15–30 min drive. Pastor trust eliminates cold outreach entirely. One Sunday bulletin announcement drives more enrollments than a month of digital advertising. NE Georgia counties have dense faith community networks — Habersham County alone has 60+ active congregations with FFS-age members.
Action: Secure 3 anchor church agreements in Habersham County before Clinic 1 opens · Offer free Annual Wellness Visit as enrollment introduction
🏥
NGHS Hospital Discharge Teams
Patients leaving NGMC Habersham, NGMC Lumpkin, or Stephens County Hospital without a PCP are the highest-priority TOC targets. Newly motivated, unattributed, within the 30-day readmission window — urgency is mutual. Bamboo PatientPing ADT feed automates the notification. The hospital's readmission penalty incentive aligns with our TOC billing revenue.
Action: Schedule meetings with discharge coordinators at NGMC Habersham and Stephens County Hospital before launch · Demonstrate TOC billing and readmit reduction value proposition
🏠
Senior Living Communities
Independent living, assisted living, and memory care facilities in each county. Facility directors are enrollment partners — they want reliable nearby primary care for residents. FFS members in senior communities are dense, transport-accessible (van stops at facility), and high-CCM-eligible.
Action: Identify 2–3 senior communities in Habersham and Lumpkin counties with FFS-majority residents · Propose scheduled clinic appointment slots
🚐
NEMT Providers (Reciprocal Referral)
Non-Emergency Medical Transport drivers already know which rural members are mobility-limited and FFS-enrolled. Reciprocal referral: we refer members needing specialist transport; they refer members needing a PCP. Zero cost, natural alignment. Informal enrollment channel into the hardest-to-reach segment.
Action: Contact NEMT operators in Habersham, Lumpkin, Stephens counties before launch · Build referral protocol into member intake workflow
Clinical Integration Partners
Partners that extend clinical reach without adding headcount
🏨
Skilled Nursing Facilities (SNFs)
TOC alignment: patients transitioning from SNF to home need a PCP immediately. SPARK Senior Health provides care continuity and reduces readmissions; the SNF benefits from improved CMS quality scores. Mutual financial incentive — formal warm handoff protocol pre-launch.
Target: SNFs in Habersham, Lumpkin, Stephens · warm handoff protocol before Clinic 1 opens
🏡
Home Health Agencies (Non-MA FFS Only)
FFS home health agencies see members between clinic visits. Complementary, not competitive. Joint RPM identification: they flag members with deteriorating vitals at home; we respond as PCP of record. Avoid MA-contracted agencies — misaligned incentives.
Confirm: non-MA contracted agencies only · shared member communication protocol
💊
Local Independent Pharmacies
Polypharmacy management is a chronic disease crisis in NE Georgia. Pharmacist-led Medication Therapy Management (MTM) is billable under Medicare Part D. Referral partnership: we identify polypharmacy cases; pharmacy conducts MTM; we close the loop in the CCM care plan. Target independent pharmacies — not chains.
Target: independent pharmacies in each clinic county
CMS Attribution Strategy & NGHS Partnership
Win and keep FFS attribution · NGHS as strategic anchor across the portfolio
Attribution wins: AWV (G0438/G0439) is the most powerful single attribution claim — establishes SPARK Senior Health as PCP of record. CCM/APCM monthly billing reinforces attribution every month between visits. Together: very difficult for a competing provider to dislodge.
NGHS as strategic anchor: NGHS has every financial incentive to reduce readmissions and ER overutilization. SPARK Senior Health reduces both. ADT feed via Bamboo PatientPing enables NGHS-SPARK Senior Health care coordination across all 10 counties. Formal referral agreement with NGHS is the highest-value pre-launch partnership activity.
Watch for: ACO-affiliated PCPs competing for FFS attribution. Monitor ACO presence by county at each clinic launch. Our retention tool is physical presence, trust, and transport access. Monitor FFS-to-MA conversion rate annually — each conversion shrinks the addressable pool.
Stage 5 · Operations · Summary & Investment Book Close
Stage 5 Summary — & The Investment Case
Operations framework complete. Five stages of analysis — the model is validated, the market is defined, the numbers are grounded. Here is what remains before capital raise, and the case in full.
∑All 5 Stages Complete
Investment Book v2.0
10–14
Target visits/day per clinic · AI-enabled NP throughput
3
Opening-team roles per clinic · NP/PA, LPN/MA, driver · others added as workload justifies
5
Daily workflow steps · morning huddle → encounters → doc → claims
92%
Clean claim rate target · first-pass Palmetto GBA J-J via Commure RCM
3
Anchor faith partners needed pre-launch · Habersham County
Mo 2
EHR selection deadline · before PECOS enrollment finalizes
Stage 5 Chapter Recap
Five sections · what was established
5.1HR — Each clinic opens with an NP/PA, LPN/MA and driver; care coordinator and front desk added when workload justifies (Habersham ~M8 / ~M10). Contracted Physician Owner + Collaborating Physician (Permit Health bid pending); compliance owned by the MSO CCO/CLO. KPIs by role. Per-clinic clinical team ~$307K–$489K/yr at ramp completion (incl. driver). Commure RCM at 4% of collections at launch — in-house option evaluated as volume grows. Per-diem LPN backup pool.
5.2Transport — Van is logistics only (member pickup/return). Fixed clinic delivers all care. AM pickup → clinic hours → PM return. 7:30 AM daily huddle (NP + LPN teleconference) is the highest-value daily operational habit. Samsara fleet tracking + rental standby within 2 hours.
5.3Clinical Ops — 5-step visit flow (Klara check-in → AI intake → NP exam → care plan → same-day claim). CCM/APCM/RPM monthly checklists. Escalation decision tree (LPN→NP→MD→911). TOC protocol via Bamboo PatientPing. HEDIS and CMMI documentation targets.
5.4Systems — EHR final two candidates (Athelas AIR / Athenahealth). Commure Ambient + RCM. Chronic Care IQ. Tenovi RPM. Bamboo PatientPing. Klara / Doxy.me. Rippling / Samsara / Compliancy Group. All integrated end-to-end, all HIPAA BAA in place.
5.5Partnerships — Faith organizations (highest ROI channel). NGHS hospital discharge teams (TOC pipeline via ADT). Senior living communities. NEMT reciprocal referral. SNFs, home health, independent pharmacies. CMS attribution via AWV + CCM monthly.
The SPARK Senior Health Investment Case — In Full
The market: 44,376 confirmed Medicare FFS members across HPSA-designated NE Georgia counties. Rural seniors averaging 1.4 PCP visits per year. 24% have no established primary care provider. The problem is structural and not being solved by traditional clinic economics.
The model: Fixed-clinic primary care + member transport + CCM/APCM/RPM. The fixed clinic solves the access problem. Transport removes the last barrier. Visits plus CCM/APCM/RPM build to ~$163/member/month by Y5 (total PMPM before COGS; ~$140 net) — a bottom-up sum of 2026 CMS billing codes. AI-enabled NP throughput of 10–14 visits/day. Per-clinic EBITDA positive at Month 8. 10 clinics, 10 counties, 3-year rollout.
The return: $4M (Lease) / $5M (Own/Mortgage) Series Seed raise · 70% Founders / 10% ESOP / 20% Investors · Safe or convertible note. Portfolio EBITDA breakeven Year 2. Base case (25% pen · 18-mo ramp · 2.0→4.0 visits · 10 clinics): ~11,097 members at Y4/Y5 maturity · ~$163 total PMPM (Y5, before COGS) · EBITDA ~$6.8M Y5 (Lease) / ~$6.7M (Own) · Exit ~$55M (Lease) / ~$65M (Own) at ~8–10× Y5 EBITDA · Investor share (20%) = ~$11M on $4M (2.75×) / ~$13M on $5M (2.6×) · IRR ~18% / ~17% after federal capital-gains tax (~22% / ~21% with QSBS). CMMI non-dilutive pathway: $3.36M/year in documented CMS savings at 400 enrolled members, rising to ~$93M/year in potential savings across the ~11,100-member portfolio.
Why now: GA 2024 APRN scope expansion, 2026 CMS APCM and 99445 RPM code additions, NE Georgia HMO penetration below 4%, and 44,376 FFS members uncontested — all create a window for a fixed-clinic, FFS-native, for-profit operator to claim attribution before the market consolidates. The HPSA moat is real. The community trust latency is real. Both are very difficult to replicate once lost.
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