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Front Matter
Title Page
Documentation for Health Records
Second Edition
Lead Author
Cheryl Gregg Fahrenholz, RHIA, CCS-P
AHiMA American Health Information Management Association®
Copyright Page
Copyright ©2017 by the American Health Information Management Association. All rights reserved. Except as permitted under the Copyright Act of 1976, no part of this publication may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, photocopying, recording, or otherwise, without the prior written permission of the AHIMA, 233 North Michigan Avenue, 21st Floor, Chicago, Illinois, 60601-5809 (http://www.ahima.org/reprint).
AHIMA Product No.: AB100716
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Megan Grennan, Managing Editor
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ISBN-13: 978-1-58426-554-2
ISBN-10: 1-58426-554-X
eISBN-13: 978-1-58426-557-3
eISBN-10: 1-58426-557-4
Detailed Table of Contents
About the Lead Author… xvii
About the Chapter Contributors… xix
Acknowledgments… xxiii
Introduction… 1
Part I - Clinical Documentation and the Healthcare Delivery System… 11
Chapter 1. Healthcare Delivery… 13
Framework and History of the Healthcare Delivery System… 14
Legislative Impact… 15
Modern Healthcare Delivery… 19
Healthcare Providers and Facilities… 19
Healthcare Services… 22
Trends in Healthcare Delivery… 23
Hospital-Based Services… 25
Continuum of Care… 26
Clinical Documentation in Healthcare: Moving Toward the Electronic Health Record… 31
Affordable Care Act (ACA)… 31
Personal Health Records… 32
Electronic Health Information Exchange… 36
References… 41
Chapter 2. Clinical Documentation and the Health Record… 43
Clinical Documentation and the Health Record… 44
Purpose and Value of Documentation… 44
Owners of the Health Record… 45
Users of the Health Record… 46
Definition of the Health Record for Legal Purposes… 50
Legal Health Record… 50
Patient-Identifiable Source Data… 55
Administrative Information… 56
Derived Data… 56
Personal Health Records… 57
Types of PHRs… 57
Documentation Guidelines… 59
The Future of Clinical Documentation… 61
References… 66
Part II - Utilization of the Healthcare Record… 69
Chapter 3. Principal and Ancillary Functions of the Healthcare Record… 71
Principal Functions of the Health Record… 73
Administrative Information and Demographic Data… 73
Admitting and Registration Information… 73
Patient-Care Delivery… 76
Patient-Care Management and Support… 77
Quality Management and Performance Improvement… 77
Utilization Management… 80
Risk Management… 80
Billing and Reimbursement… 80
Ancillary Functions of the Health Record… 81
Accreditation, Licensure, and Certification… 82
Biomedical Research… 83
Medical Staff Appointments and Privileges… 85
Risk Management and Incident Reporting… 89
Health Records as Legal Documents… 90
Morbidity and Mortality Reporting… 92
Management of the Healthcare Delivery System… 101
Form and Content of Health Records… 101
Release and Disclosure of Confidential Health Information… 102
Redisclosure of Confidential Health Information… 106
Retention of Health Records… 106
Destruction of Health Records… 107
References… 111
Chapter 4. Documentation for Statistical Reporting and Public Health… 115
Research and Statistics… 116
Public Health Reporting… 117
Centers for Disease Control and Prevention WONDER Database… 117
National Center for Health Statistics… 119
The National Health Care Survey… 120
Vital Statistics… 121
Facility-Specific Indexes… 122
Master Patient Index… 122
Physician Index… 124
Disease and Operation Indexes… 124
Registries… 124
Healthcare Databases… 126
National Practitioner Data Bank… 126
Data Quality Issues… 127
Primary and Secondary Data Sources… 128
Standardized Clinical Data Sets… 128
References… 133
Chapter 5. Clinical Information, Nonclinical Data, and Health Record Design… 135
Electronic Health Record… 136
Data, Information, and Knowledge… 136
Benefits to the EHR… 137
Improved Patient Care… 137
Improved Care Coordination… 137
Practice Efficiencies and Cost Savings… 138
Increased Healthcare Consumer Participation… 138
Improved Diagnostics and Patient Outcomes… 138
Barriers to the EHR… 138
Interoperability… 139
Budget Impact… 139
Project Team Collaboration and Commitment… 139
Completing the Implementation Timeline According to Schedule… 139
Vendor Support… 139
Lack of Healthcare Consumer Awareness… 140
Cybersecurity… 140
Components of the EHR… 140
Specialty-Based EHRs… 142
Federal Policies Driving EHR Implementation… 143
National Infrastructure for the EHR… 143
Providers and the Infrastructure for EHRs… 144
User Access… 144
Documentation Standards… 145
Clinical Decision Support… 145
Data Dictionary… 145
Designing an EHR… 145
Data and Information in an EHR… 147
Nonclinical Information… 148
Demographic Data… 148
Financial Data… 148
Preliminary Clinical Data… 149
Consents and Acknowledgments… 149
Documenting in the EHR… 149
Devices Used to Document in the EHR… 150
Regulating Health Record Content… 150
Clinical Documents in the EHR… 151
Medical History… 151
Report of Physical Examination… 151
Physician Orders… 151
Outpatient Services Provided in Acute-Care Facilities… 154
Specialty-Care Documentation… 155
Discharge Summaries… 155
Autopsy Report… 157
Uses for Abstracted Electronic Data… 158
The Hybrid Health Record… 158
Health Record Storage Systems… 158
HIM Functions in an EHR Environment… 159
Authentication of EHR Entries… 159
Guidelines to Prevent Fraud and Ensure EHR Documentation Integrity… 159
Medical Identity Theft… 160
Authorship Integrity… 160
Auditing Integrity… 160
Documentation Integrity: Automated Insertion of Clinical Data… 160
Corrections in Electronic and Clinical Documentation… 161
EHRs in Health Information Exchanges… 161
References… 164
Chapter 6. Clinical Documentation Improvement… 167
The Importance of Clinical Documentation… 168
Evidence-Based Documentation: The Theory of High-Quality Clinical Documentation… 169
Seven Criteria for High-Quality Clinical Documentation… 169
Operational Considerations of the CDI Process… 174
The CDI Professional… 175
Queries… 179
Concurrent Query… 180
Retrospective Query… 180
Query Format… 183
CDI and the EHR… 184
Translating Clinical Documentation into Coded Data… 185
How a Coding Professional Views an Inpatient Health Record… 185
The Relationship between Clinical Documentation and Coding… 188
Clinical Documentation Analysis and Assessment… 191
Data Review… 192
References… 202
Chapter 7. Information Governance… 205
Quality and Safety of Patients… 206
The IG Principles and Examples for Each in Healthcare… 207
IG and Patient Care… 208
Clinical Documentation Improvement… 208
Meaningful Use Requirements… 209
Coding and Quality Measures… 209
Learning Health System and Quality Improvement… 210
The Role of HIM in Information Governance… 212
Adaptive Leadership and IG… 213
Examples of IG Challenges… 215
References… 220
Chapter 8. Data Analytics… 223
Tools Used in Data Analytics… 224
Microsoft Excel… 224
Tableau… 225
Qlik View… 225
R Studio… 225
Public Data Web Sources… 225
National Initiatives on Big Data… 225
Concepts of Database Management… 226
Data Analytics and the Electronic Health Record… 229
Tools and Best Practices When Conducting Research in an EHR Environment… 229
Clinical Care, Data Analytics, and the EHR… 230
Quality and Population Health and the EHR… 231
Data Governance… 232
References… 236
Part III - Organization and Management of the Health Record… 239
Chapter 9. Federal and State Requirements and Accreditation Guidelines… 241
Federal and State Requirements… 243
Federal Healthcare Statutes… 244
HIPAA… 244
HITECH Act… 248
Federal Patient Safety Legislation… 248
CMS Regulations… 250
Medicare Conditions of Participation… 250
Medicare Compliance Surveys… 252
Telehealth Regulation… 253
CMS Quality Measures… 253
Patient Satisfaction as a Quality Measure… 254
Quality Improvement Organizations… 256
Healthcare Corporate Compliance… 256
Office of Inspector General and OIG Work Plan… 257
Recovery Audit Contractors… 258
Federal and State Protection of Sensitive Health Information… 259
Substance Abuse Records… 259
Behavioral Health Records… 260
HIV/AIDS Records… 260
Genetic Information… 260
State Requirements… 261
Licensure… 261
Medicaid Eligibility and Administration… 261
Medicaid Compliance Programs… 262
Accreditation Requirements for Acute-Care Hospitals… 262
The Joint Commission… 263
Healthcare Facilities Accreditation Program… 266
DNV GL Healthcare… 267
Center for Improvement in Healthcare Quality… 267
Internal Hospital Policies and Procedures… 268
HIM Policies and Procedures… 268
Medical Staff Bylaws… 268
Medical Records Committee… 269
References… 272
Chapter 10. Ambulatory Care Documentation, Accreditation, Liability, and Standards… 275
Ambulatory Surgical Centers… 276
Community Health Centers… 277
Private Practice Providers… 278
Diagnostic Imaging Centers… 278
Missing Clinical Information in Outpatient Services… 279
Ambulatory EHR versus Hospital EHR… 280
MU Criteria for Eligible Professionals… 283
MU for Eligible Providers by Stages… 283
Credentialing and Licensure… 285
State and Federal Regulations… 286
Governmental Regulations of Ambulatory Care… 286
State Governments… 288
Ambulatory Care Accreditation Standards… 289
Types of Ambulatory Accreditation Organizations… 290
The Joint Commission… 291
Accreditation Association for Health Care… 291
The Accreditation Association for Ambulatory Health Care… 291
Association for American Accreditation of Ambulatory Surgery Facilities… 292
American College of Radiology… 292
Commission on Accreditation of Rehabilitation Facilities… 292
Community Health Accreditation Partner… 292
The College of American Pathologists… 292
Commission on Cancer… 292
National Committee for Quality Assurance… 292
Role of the Patient's Primary Care Physician and the Maintenance of Health Records… 293
Document Management and Imaging System… 294
Type of Document Imaging Scanners… 294
Documenting Imaging Best Practices… 295
Risk Management and Liability… 296
References… 299
Chapter 11. Long-Term Care Hospitals… 303
Long-Term Acute-Care Hospital Settings… 304
Regulations… 305
Federal Regulations… 305
State Regulations… 306
Accreditation Regulations… 306
Components of the LTCH Prospective Payment System… 307
LTCH Health Record Content… 308
History, Physical, and Referral Information… 308
Principal Diagnosis… 308
Admission Data… 309
Physician Orders… 310
Progress Notes… 310
Problem Lists… 310
Consultation Records… 310
Reevaluations and Assessments… 310
Advance Directives… 310
Laboratory Reports… 310
Specialty Reports… 311
Flow Sheets… 311
Graphical Data… 311
Care Plans… 311
Education… 312
Procedure Records… 312
Miscellaneous Data… 312
Medication Administration Records… 313
Discharge Documentation… 313
LTCH Policies and Procedures… 313
LTCH PPS Tables… 313
References… 319
Chapter 12. Facility-Based Long-Term Care… 321
Skilled Nursing Facility… 322
SNF Health Record Content… 324
Resident Assessments… 325
Resident Assessment Protocols… 328
Other Documentation… 331
SNF Accreditation Standards and Regulations… 334
Medical Necessity and Medicare Documentation… 335
Physician Certification… 335
Standards Governing Assessments… 335
Medicare Quality Indicators for SNFs… 336
Risk Management and Liability… 336
Real-World Case Study… 337
References… 339
Chapter 13. Home Care and Hospice Documentation, Liability, and Standards… 341
Home Health… 342
What Is Medicare-Certified Home Health?… 343
Certified Hospice… 344
Background… 344
Home Health… 345
Home Health Payment Policy… 345
Standard Core Assessment Tool—OASIS… 345
Hospice Conditions of Participation… 345
Hospice Core Assessment Tool—HIS… 346
Increasingly Complex Organizations… 346
Government Influences… 346
Office of Inspector General Oversight… 347
Comprehensive Error Rate Testing (CERT)… 348
The Medicare Home Care Benefit… 348
Documentation of Eligibility of the Provider… 349
Home Health under the Care of a Physician… 349
Home Confinement (Homebound Status)… 350
Skilled Services Requirement for Benefit Eligibility… 351
First Visit Criteria… 352
Intermittent or Part-Time Nursing… 352
Home Health Prospective Payment System… 352
The Medicare Hospice Benefit… 356
Provision of Care under the Medicare Hospice Benefit and Documentation… 357
Payment System for Hospice… 357
Home Health and Hospice Record Content… 358
Intake/Referral… 358
Home Care and Hospice Assessment Information… 361
Home Care and OASIS… 362
Hospice and Assessment… 362
Home Health Plans of Care… 364
Hospice Plans of Care… 364
Hospice Clinical and Progress Notes… 366
Home Health Clinical Notes… 366
Dietary and Nutritional Information… 367
Bereavement Documentation… 367
Progress Notes and the Discharge Transfer Record… 367
Medicare Home Care Surveys… 368
Quantitative Record Review Guidelines… 370
Home Health Medical Review… 371
Medicare Hospice Surveys… 374
Home Health QAPI… 374
Medical Review of Hospices… 374
Medicare Hospice Quality Assessment Performance Improvement… 375
Physician's Documentation Review… 375
Home Care and Hospice Legal Issues… 376
Patient's Rights… 376
Patient Self-Determination Act of 1990… 377
Do-Not-Resuscitate Orders… 377
Home Health Quality Initiative… 380
Patient Outcome Measures… 382
Accreditation Quality Requirements… 382
CHAP Performance Improvement Standards… 383
The Joint Commission Performance Improvement Standards… 383
General Requirements of Documentation… 383
Communication and Timeliness of Documentation… 383
Consistent and Complete Documentation… 384
Development of Documentation Policies and Procedures… 384
References… 386
Chapter 14. Exploring Other Healthcare Settings… 391
Regulations Common to All Healthcare Providers… 392
Outpatient Private Practitioners or Solo Practitioners… 393
Outpatient Ambulatory Integrated Clinical Settings… 409
Government Healthcare Settings… 419
Veterans Health Administration… 419
Other Military Healthcare Systems… 420
Correctional Facilities… 420
Indian Health Service… 421
Other Healthcare Settings… 422
Blood Banks… 422
Coordinated School Health Programs… 423
University-Based Student Health Services… 424
Veterinary Practices… 424
Critical Access Hospitals… 426
A Note on Health Plans and Insurers… 428
References… 430
Glossary… 435
Index… 469
About the Lead Author
Cheryl Gregg Fahrenholz, RHIA, CCS-P, is the president of Preferred Healthcare Solutions, LLC, and has more than 30 years of experience working with healthcare facilities, physicians, and their staff. Her consulting services include revenue cycle integrity management, ICD-10 impact analysis, multispecialty audits related to documentation and coding, Charge Description Master (CDM) reviews, Clinical Documentation Improvement (CDI) audits, operational and financial assessments, coding sessions for physicians and staff, charge capture and charge process redesign, denial audits, risk and sanction analysis, compliance plan evaluations, electronic health record selection and implementation, forensic auditing and litigation support, expert testimony, along with interim or retainer professional support and customized project work.
Before establishing her own consulting firm in 1998, Gregg Fahrenholz served as the director of Documentation, Coding and Reimbursement at the Primary Care Networks of Premier Health Network and as the manager of Information Management at Miami Valley Hospital. Gregg Fahrenholz holds a bachelor of science in health information management (HIM) from Bowling Green State University and is an AHIMA-approved ICD-10 trainer.
Gregg Fahrenholz is a nationally recognized speaker on the topics of revenue cycle, documentation, coding, and compliance. She has published extensively at the national level through books and peer-reviewed articles on revenue cycle integrity, documentation, and coding. She has co-chaired AHIMA's Practice Councils for both the Clinical Coding and Terminology and Physician Practice. She served on AHIMA's Nominating Committee and Annual Meeting Planning Committee among other volunteer opportunities at AHIMA. She served for numerous years on the Ohio Health Information Management Association board of directors. She received the Triumph Discovery Award from AHIMA and the Distinguished Member Award from the Ohio Health Information Management Association and the Miami Valley Health Information Management Association.
About the Chapter Contributors
Dilhari R. DeAlmeida, PhD, RHIA, is an assistant professor in the department of Health Information Management at the University of Pittsburgh. She has a master's degree in health information systems and a doctoral degree focusing on documentation improvement in ICD-10. In addition to her volunteer services for AHIMA, she teaches and advises both undergraduate and graduate students in HIM. Dr. DeAlmeida has published on the topic of data analytics, eResearch, and clinical decision support systems. She serves as a reviewer for Perspectives in Health Information Management. Her research interests include electronic health record research and data analytics in healthcare. She is also an AHIMA-approved ICD-10-CM/PCS trainer.
Thomas J. Hunt, PhD, RHIA, CHDA, FAHIMA, is an assistant professor at Rutgers University in the School of Health Professions Department of Health Informatics. He previously served as associate dean and professor of Health Information Management at Davenport University. Before transitioning to higher education, he was successful in leadership roles with Sparrow Health System, ProMedica Health System, and Mercy Health Partners. He is a past president of the Michigan Health Information Management Association (MHIMA) and is also a past president of the Lake Huron Michigan Health Information Management Association. Dr. Hunt earned a doctor of philosophy degree in Global Leadership with a concentration in Organizational Management from Indiana Institute of Technology, a master of business administration from Davenport University, and undergraduate degrees from Cleary University and Mercy College of Ohio. He has been a presenter at the International Federation of Health Information Management Associations (IFHIMA) Congress and General Assembly, AHIMA Convention and Exhibit, AHIMA Assembly on Education, as well as the MHIMA Annual State Conference.
Ella L. James, MS, RHIT, CPHQ, is the former director of corporate health information management and health information privacy officer at Hospital for Special Care in New Britain, Connecticut. Currently, James is an independent ICD-10-CM coding consultant and auditor for long-term care hospitals across the nation (LTCHs). James is past president of and twice sat on the board of directors for the Connecticut HIMA and was an AHIMA Community of Practice (CoP) facilitator for long-term care. She chaired the coding committee for the National Association of Long Term Hospitals (NALTH). James has presented programs on HIPAA at the state, regional, and national levels and has presented educational programs for coders and physicians on long-term acute-care coding for NALTH. She has consulted on coding and documentation issues for many long-term acute-care hospitals through NALTH. She is the author of Documentation and Reimbursement for Long-Term Care and contributing author of the AHIMA publication Health Information Management Compliance and Documentation for Health Records.
Neisa Jenkins, EdD, RHIA, earned her bachelor of arts degree in Health Information Management at the University of Illinois (Chicago), a master of arts in Health Information Management at the College of St. Scholastica and her Doctorate of Education at Walden University. She has over 25 years of experience in Health Information Management. Her professional background includes HEDIS auditing, consulting, quality improvement, utilization management, release of information, EHR-S implementation, HIPAA implementation, ICD-10-CM/PCS, and teaching in higher education. Dr. Jenkins has taught courses in health information management, health service management, and healthcare administration. She has held positions as program dean, faculty chair, visiting professor, and full professor. Dr. Jenkins's teaching philosophy is borrowed from Martin Luther King Jr.: "Intelligence plus character—that is the goal of true education" (Martin Luther King Jr. "The Purpose of Education." 1947).
Suzanne Paone, MBA, DHA, RHIA, is an accomplished healthcare executive in academic medicine including awards by the American Hospital Association and Microsoft. She transverses academics with 12 years of teaching and curriculum development in analytics, HIM, informatics, and strategy. She speaks to and advises education, healthcare, and technology companies. Current research includes Transformational Analytics curricula development. Full-time appointment is at Ashford University in HIM and dual appointments include: University of Pittsburgh HIM, Pitt Graduate School of Public Health MHA, and the MBA program at Carlow University. She is the president of Innovation Advising, a cooperative platform for professional services based in servant leadership. Suzanne holds several not-for-profit board positions and is published in technology adoption, eHealth, and health data analytics.
Laurie A. Rinehart-Thompson, JD, RHIA, CHP, FAHIMA, is the director of the health information management and systems program and an associate professor at The Ohio State University. She earned her bachelor of science and juris doctor degrees from The Ohio State University. Her professional experiences span HIM education, behavioral health, home health, and acute care. She has served as an expert witness, testifying regarding the privacy of health information. She has chaired the AHIMA Professional Ethics Committee and has served on numerous AHIMA committees and the Ohio Health Information Management Association board of directors. She is a coeditor and coauthor of AHIMA's Fundamentals of Law for Health Informatics and Information Management; author of AHIMA's Introduction to Health Information Privacy and Security; and a contributing author to numerous HIM textbooks and periodicals. She received the Ohio Health Information Management Association's Distinguished Member Award and the AHIMA Legacy Award in 2010, and she became an AHIMA fellow in 2011.
Susan Rossiter, RHIA, CHPS, has over 30 years' experience in a variety of settings within the health information management field. Since 2003, she has been the Health Information Management operations manager for the University of Texas Southwestern Medical Center, a large academic medical center located in Dallas, Texas. Prior to that, she was the Hospital Compliance officer for Terrell State Hospital and has several years of experience in management of HIM departments for acute care, behavioral health, and ambulatory care organizations. Rossiter graduated with honors from Texas Woman's University, where she received the Outstanding Senior Student in the State award from the Texas Medical Record Association and the Dallas Outstanding Senior Student award from Texas Woman's University. In November 2000, she received a Certificate of Recognition from the Governor's Commission for Women as one of the Outstanding Women in Texas Government. As chair for the Executive Women in Texas Government, Dallas Affiliate, she supports and promotes women in leadership service to the state of Texas.
Lisa Selman-Holman JD, BSN, RN, HCS-D, COS-C, HCS-O, HCS-H, is the owner of Selman-Holman & Associates, LLC. A 30-year veteran of home care as an RN and as an attorney, she has participated in the writing of home care regulations and has been involved in accreditation surveys, acquisitions, and many regulatory crises. Responsibilities have included risk management, survey compliance, Medicare appeals, Corrective Action Plans, due diligence audits, consulting with agencies, and education of staff. Selman-Holman obtained her JD from University of Houston and her BSN from the University of Tulsa. She is certified as a home care coder and a hospice coder and is certified in OASIS. She is the chair of the Board of Medical Specialty Coding and Compliance and an editor of the Decision Health coding manual. She has served on regulatory task forces and the Quality Improvement Organization for OBQI. Current projects include online programs through CodePro University and outsource coding through CoDR—Coding Done Right. She is an AHIMA-approved ICD-10-CM trainer.
Valerie J. Watzlaf, PhD, MPH, RHIA, FAHIMA, is an associate professor in the Department of Health Information Management (HIM) at the University of Pittsburgh. She has worked as a HIM practitioner and consulted in several healthcare organizations in HIM, long-term care, and epidemiology. Dr. Watzlaf has chaired and served on multiple AHIMA committees and boards such as the Board of Directors of AHIMA and the AHIMA Foundation and chair of the Council for Excellence in Education (CEE). Dr. Watzlaf was elected as president/chair-elect of AHIMA starting in 2018. She has coauthored the textbook Health Informatics Research Methods: Principles and Practice. Dr. Watzlaf is also on the editorial advisory board for the Journal of AHIMA and for Perspectives in HIM. She has delivered over 100 presentations and authored over 50 publications and is the recipient of numerous awards and professional accolades including the AHIMA Triumph Award for Research, PHIMA's Distinguished Member Award, and the University of Pittsburgh's SHRS Distinguished Alumnus Award.
Acknowledgments
Cheryl Gregg Fahrenholz wishes to thank Ashley Latta, production development editor, for her detailed eye and continued guidance with this publication. Additionally, she thanks the contributing authors for sharing their expertise and time in order to produce a comprehensive publication for HIM readers.
A special thanks from Cheryl to her husband, Mark, and mother, Pat, for their never-ending support. With all of the challenges in our busy lives, they make it easier to balance professional and family life in order for this publication journey to be a success.
AHIMA Press would like to acknowledge the following contributors for their work on prior editions of this textbook.
Kathleen Munn, RHIA
Diana Warner, MA, RHIA, CHPS, FAHIMA
Margaret White, MS, NHA, RHIA, CPHQ
AHIMA Press would also like to thank Ruthann Russo, PhD, MPH, RHIT, for serving as a volume editor in the prior edition of this text.
Finally, we would like to thank Kathleen M. Kirk, MS, RHIA, CHC, for her review and feedback on this text.
Copyright ©2017 by the American Health Information Management Association. All rights reserved.
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