RFP-Pharmacy Services for RACSB.pdf

RAPPAHANNOCK AREA COMMUNITY SERVICES BOARD

REQUEST FOR PROPOSALS (RFP)

Issue Date:

Title: ON-SITE PHARMACY SERVICES

RFP 23-0223

Issuing Agency: Rappahannock Area Community Services Board

600 Jackson Street

Fredericksburg, VA 22401

Work Location: Remote and on-site

Proposals will be accepted electronically via eVA (eva.virginia.gov) until noon (EST) on May 17, 2024.

Questions: See RFP Section XI for details.

In compliance with this Request for Proposals and the conditions imposed therein and hereby incorporated by reference, the undersigned offers and agrees to furnish the services in accordance with the attached signed proposal or as mutually agreed upon by subsequent negotiation.

Name of Firm:

Firm Address:

Firm Representative (Print):

Firm Representative Signature:

Firm Representative Title:

Date:

Federal EIN:

eVA Vendor #:

DUNS #:

Phone Number:

Email Address:

Request for Proposal (RFP): On-Site Pharmacy Services

I. Purpose

RACSB is seeking proposals from qualified vendors for the purpose of selecting an agency which will provide on-site pharmacy services on program pharmacy needs in conjunction with the Rappahannock Area Community Services Board within the Fredericksburg Clinic located at 600 Jackson Street, Fredericksburg, VA 22401.

II. Agency Overview

RACSB is an agency of local government, dedicated to education, recovery, treatment, and wellness of Planning District

16 residents affected by mental health and substance use disorders and developmental disabilities. RACSB is one of forty

Community Services Boards in the Commonwealth of Virginia.

RACSB provides services to the residents of the City of Fredericksburg and the counties of Caroline, King George, Spotsylvania and Stafford. Our goal is to serve the community by providing desperately needed services for people with behavioral health concerns. And when possible, we’re committed to preventing behavioral health issues before they arise.

We meet these goals through a variety of services, including early intervention, outpatient therapy, medication management, crisis services, residential care, peer support, support coordination, case management, day support, prevention services, and more. RACSB receives funding from Federal, State and Local sources as well as from clients and third-party insurance payors. No one is turned away due to inability to pay. Since 1970, RACSB has been the face of public behavioral healthcare and developmental disability support in the greater Fredericksburg area. RACSB has approximately 600 positions and pays approximately 540 employees per pay period.

III. Intent

It is expected that the selected proposer will establish on-site pharmacy services for clients of RACSB in space provided in Fredericksburg, VA. The selected proposer will be expected to provide an adequate level of qualified staffing to support the smooth operation of the proposed service model. Proposer must be qualified to dispense narcotic and psychotropic medications prescribed under a behavioral health formulary. Proposer must be qualified to dispense routine medications associated with a primary care practice and must be qualified to dispense these prescriptions in accordance with all applicable Federal, State, and local statutes and regulations. Selected proposer is expected to provide services during RACSB’s regular business hours which are Monday through Friday, between 8:00 am and 7:00 pm. Proposer must also have after hour access for medications, either through a partner 24-hour pharmacy or as part of their proposal.

Priority will be given to proposers who offer closed-door weekend hours and holiday hours to support agency programs.

Proposers are encouraged to include any additional, innovative pharmacy services offerings available.

It is expected that the proposer will provide pharmacy services as a convenience to RACSB clients as part of the operation of a licensed pharmacy and therefore will not charge fees to RACSB for staffing, equipment, supplies, or other traditional pharmacy expenses, and will be compensated solely by billing third party payers and clients for medications dispensed.

IV. Scope of Work and Deliverables:

Selected proposer will provide at minimum on-site pharmacy services and RACSB program services in conjunction with the Rappahannock Area Community Services Board operating within the Fredericksburg Clinic location at 600 Jackson

Street, Fredericksburg, VA 22401. On-site pharmacy services will be required during regular business hours of 8 am to 7 pm Monday through Friday, with preference given to proposers who can offer closed-door pharmacy services on weekends and holidays to support RACSB program pharmacy needs and those who offer additional service offerings for

RACSB programs. Proposer must also have after hour access for medications, either through a partner 24-hour pharmacy or as part of their proposal.

The selected proposer will provide services as an independent contractor and will lease the identified pharmacy space from the Rappahannock Area Community Services Board. RACSB is offering approximately 500 square feet of space for the project. A space lease agreement will be part of final contract between RACSB and the successful proposer.

Interested applicants may request to view the available space prior to proposal submissions by contacting Kelli Lawrence-

Byrd at purchasing@rappahannockareacsb.org.

Pharmacy services will be available to clients receiving services from the Rappahannock Area Community Services

Board.

While the Fredericksburg Clinic will be the primary population to receive pharmacy services, all RACSB locations and programs may be served by the pharmacy. The Fredericksburg location serves adults and children with serious mental illness, substance use challenges, individuals with developmental disabilities, and employees of the RACSB. The RACSB currently employs 12 prescribing psychiatrists and nurse practitioners.

The primary pharmacy site serves approximately 4,000 individuals with 21,000 individuals receiving an agency service annually. The agency currently operates 40 different programs within the five-locality service area. Current insurance payor mix of RACSB clients is approximately: 50% Medicaid, 5% Medicare, 16% private insurance, 34% sliding fee scale, and the remainder are other public/private funds.

Proposers may direct any additional questions regarding this Request for Proposals to Kelli Lawrence-Byrd at purchasing@rappahannockareacsb.org. General responses, revisions, and additional information will be made available to all identified potential proposers.

Services requested include, but are not limited to:

1. Provide on-site pharmacy services. Staff the proposed pharmacy services model with licensed qualified pharmacists or other staff as reasonably necessary to operate the services on a day-to-day basis as determined by selected Proposer and RACSB in compliance with all applicable federal and state laws;

bill clients and third party payers for medications dispensed; manage and retain records pertinent to the pharmacy services pursuant to applicable laws and regulatory retention standards; purchase all supplies reasonably needed to operate the pharmacy as determined by selected Proposer at Proposer’s discretion;

comply with and adhere to the Business Associates Agreement (attached to the signed contract) and

HIPAA guidelines, as periodically revised.

2. Prepare and dispense behavioral health and physical health medications in a multi-pill adherence packaging system.

3. Re-package medications as needed to reflect mid-cycle prescription changes.

4. Dispense medications directly to clients and/or RACSB staff for delivery to clients on a daily, weekly, monthly basis or other timeframe as determined in coordination with RACSB and prescribers.

5. Assist in completing Prior Authorization and Patient Assistance application forms.

6. Coordinate medication refills in a timely manner with RACSB or community Mental Health Service

Providers, Primary Care Physicians (PCPs), or other prescribers as needed.

7. Assist RACSB to maintain a perpetual inventory of sample medications and, to the extent permitted by the Virginia Board of Pharmacy, serve as RACSB’s agent for properly authorized prescriber in connection with the storage and dispensing of sample medications.

8. Provide mail delivery services as frequently as weekly for clients needing this service.

9. Manage or dispose of returned, expired, or unused medications in accordance with federal and state standards

10. Regularly coordinate with RACSB medical team and other staff concerning client needs and pharmacy operations

11. Have the ability to offer pharmacy services to other agency programs –which may include an understanding of administrative rules and packaging/delivery requirements related to medication mailto:purchasing@rappahannockareacsb.org mailto:purchasing@rappahannockareacsb.org administration in adult group homes, crisis receiving centers, crisis stabilization units, and residential treatment homes and facilities.

12. If not provided by the Proposer, contract with an after-hour pharmacy that can access patient profiles and prescriptions with the ability address urgent needs.

Minimum Qualifications

Prospective pharmacy service providers for the program must:

1. Hold a current license(s) recognized by the Virginia Board of Pharmacy which permits the provider agency and associated staff to dispense drugs and medications in accordance with all Federal, State, and local statutes and regulations.

2. Be able to certify that, in performing the specified work, the agency will not discriminate against any person on the basis of race, color, religious creed, political ideas, gender, age, sexual identity, marital status, physical or mental disability, national origin, or ancestry.

3. Be able to ensure equal access to services for clients with diverse cultural or language requirements, geographic barriers, and/or transportation needs.

4. Maintain an accounting and financial management system which complies with generally accepted accounting principles and which is adequate to meet Federal, State, and local government requirements. The system must provide adequate documentation, monitoring, access, and reporting concerning the organization’s financial position.

5. Adhere to Employee Background Security. The selected Proposer shall obtain a criminal background check, including state- and nation-wide, for each employee or agent that provides services at the

RACSB location. The background check shall include fingerprinting for each individual performing service under the contract. This check may be performed by a public or private entity. A successful criminal background check shall be completed prior to any and all employees providing services on-site at any location covered by this proposal. The selected Proposer shall provide certification to

RACSB that the selected Proposer has completed the required employee criminal background check and that the employee successfully passed the background check. Any employee of the selected

Proposer who has been convicted of a felony shall not be permitted to work on RACSB premises pursuant to this Proposal.

Compensation

The successful proposer will be responsible for directly billing and collecting payments for traditional pharmacy services provided to RACSB clients and shall not look to RACSB for payment for such traditional pharmacy services rendered.

V. Timeline

A high-level timeline is provided below for the project. A Project Implementation Plan with specific deliverables and timelines will be developed immediately following contract execution.

Activity Date

RFP Posted April 26, 2024

Questions Due May 3, 2024

Response to Questions May 7, 2024

Proposal Responses Due May 17, 2024

Firms Selected for Presentation (as necessary) TBD

Contract Executed TBD

Proposals must include an implementation timeline with expected milestones and target completion dates based on the

Scope and Deliverables in Section III and the timeline outlined above.

VI. Proposal Guidelines

Please provide a written response to each section. Your application will be reviewed and scored according to the following evaluation criteria. All proposals will be reviewed for demonstrated capacity to provide the services sought through this solicitation and evaluated for any proposed costs to RACSB.

Proposals must include:

1. Minimum Qualifications: Describe your agency’s ability to meet the minimum qualifications as outlined under Instructions and Conditions section.

2. Space Requirements and Cost:

a. Describe your agencies space requirements for proposed services. Include size, security, storage, and other necessities.

b. Provide a detailed estimate of proposed rent offered for the space.

c. Describe your agency’s plan and expectations for covering the cost of any needed changes to existing space, and completion of needed changes.

3. Relevant Experience:

a. Describe your agency’s experience in providing pharmacy, pharmacy-related services, and dispensing psychiatric medications to clients with a mental health condition, developmental disabilities, and working with behavioral health program staff.

4. On-site service plan:

a. Describe your agency’s proposal for on-site services at RACSB, specifically full pharmacy vs. on-site staff or other arrangement.

b. Include the proposed level and type of staffing, qualifications and role of on-site staff and a plan for coverage to maintaining adequate staffing.

5. Scope of Basic Services:

a. Provide a detailed description of the proposed medication packaging system.

b. Describe your plan for and experience in managing mid-cycle changes and re-packaging, and required coordination with insurance companies. Include your plan for managing any client co-pays.

c. Describe plan for coordinating medication refills with RACSB, primary care or other medical providers.

d. Describe any challenges that your agency has experienced with this system and a plan for managing these.

e. Describe your agency’s plan for managing mid-cycle prescription changes which include controlled substances.

f. Describe plan for dispensing medications directly to clients and/or RACSB staff for delivery to clients on a daily, weekly, monthly basis or other time frame as determined in coordination with

RACSB.

g. Describe plan for coordinating with RACSB medical team and other staff concerning client needs.

6. Additional Services:

a. Describe your agency’s ability and plan, if applicable, to provide any other services outlined in

Scope of Work - Services Requested. Please address:

a. Prior Authorization and Patient Assistance

b. Managing a supply of sample medication to the extent permitted by Virginia Board of

Pharmacy

c. Medication Mail Delivery services when needed

d. Assistance with weekly medication boxes for client’s unable to utilize standard adherence packaging system

e. Disposal of returned or expired medications in accordance with federal or state standards.

f. Experience and/or ability to offer services to mental health residential programs which would include understanding of administrative rules and medication packaging/administration requirements as relevant to adult foster homes, and residential treatment homes and facilities.

g. Describe any other services that your agency will offer that are not outlined under the

Scope of Work.

7. Proposals must address all questions listed in the section titled “narrative” below and include the following supporting documents attached in an appendix:

• An organizational chart which details all staff, including names and position titles, indicating those that will be assigned to the proposed program and how the program relates to the rest of the organization.

• Job descriptions for key personnel assigned to the proposed program.

• A signed proposal response form (included in attachments section).

• A copy(s) of current license(s) recognized by the Virginia Board of Pharmacy which permits the provider agency and associated staff to dispense drugs and medications.

• An example of medication adherence packaging system.

VII. Submission Instructions

Proposals are due by noon EST on May 17, 2024__and must be submitted electronically via eVA (eva.virginia.gov), Virginia’s electronic procurement portal. Late or incomplete submissions will not be reviewed. Completed proposals include those with all specified questions answered and all required documents and attachments included as part of the submission.

A. RFP Response: In order to be considered for selection, offerors must submit a complete response to this RFP.

Responses must be submitted electronically via eVA (eva.virginia.gov). No other distribution of the proposal shall be made by the offeror.

B. Proposal Preparation: Proposals shall be signed by an authorized representative of the offeror. All information requested should be submitted. Failure to submit all information requested may result in the purchasing agency requiring prompt submission of missing information and/or giving a lowered evaluation of the proposal. Proposals which are substantially incomplete or lack key information may be rejected by the purchasing agency. Mandatory requirements are those required by law or regulation or are such that they cannot be waived and are not subject to negotiation.

C. Oral Presentation: Offerors who submit a proposal in response to this RFP may be required to give an oral presentation of their proposal to the agency. This provides an opportunity for the offeror to clarify or elaborate on the proposal. This is a fact finding and explanation session only and does not include negotiation. The issuing agency will schedule the time and location of these presentations. Oral presentations are an option of the purchasing agency and may or may not be conducted.

VIII. RFP Questions and Answers

Offerors can submit questions regarding the RFP until 5pm (EST) on May 3, 2024. Questions must be submitted via email to purchasing@rappahannockareacsb.org with “RFP for Pharmacy Services” in the subject line. Emails received after 5pm on May 3, 2024 and emails that do not contain “RFP for Pharmacy Services” in the subject line will not be answered. All questions and answers will be included as an addendum to the RFP on eVA.

IX. Special Terms and Conditions

A. Audit: The contractor shall retain all books, records, and other documents relative to this contract for five (5) years after final payment, or until audited by RACSB or the Commonwealth of Virginia, whichever is sooner. The agency, its authorized agents, and/or state auditors shall have full access to and the right to examine any of said materials during said period.

B. Award of Contract: Selection shall be made of two or more offerors deemed to be fully qualified and best suited among those submitting proposals on the basis of the evaluation factors included in the Request for Proposals, if so stated in the Request for Proposals. Negotiations shall be conducted with the offerors so selected. Price shall be considered, but need not be the sole determining factor. After negotiations have been conducted with each offeror so selected, the agency shall select the offeror which, in its opinion, has made the best proposal, and shall award the contract to that offeror. RACSB may cancel this Request for Proposals or reject proposals at any time prior to an award, and is not required to furnish a statement of the reasons why a particular proposal was not deemed to be the most advantageous (Code of Virginia, § 2.2-4359D). Should RACSB determine in writing and in its sole discretion that only one offeror is fully qualified, or that one offeror is clearly more highly qualified than the others under consideration, a contract may be negotiated and awarded to that offeror. The award document will be a contract incorporating by reference all the requirements, terms and conditions of the solicitation and the contractor’s proposal as negotiated.

C. Cancellation of Contract: The purchasing agency reserves the right to cancel and terminate any resulting contract, in part or in whole, without penalty, upon 30 days written notice to the contractor. Any contract cancellation notice shall not relieve the contractor of the obligation to deliver and/or perform on all outstanding orders issued prior to the effective date of cancellation.

D. Renewal of Contract: This contract may be renewed by RACSB upon written agreement of both parties for successive one-year periods, under the terms of the current contract, and at a reasonable time (approximately 60 days) prior to the expiration.

E. Insurance: By signing and submitting a proposal under this solicitation, the Offeror certifies that, if awarded the contract, it will have the following insurance coverages at the time the work commences. Additionally, it will maintain these during the entire term of the contract and that all insurance coverages will be provided by insurance companies authorized to sell insurance in Virginia by the Virginia State Corporation Commission.

During the period of the Contract, RACSB reserves the right to require the Contractor to furnish certificates of insurance for the coverages required by RACSB as indicated.

Coverages Required: Professional insurance, as applicable.

Worker's Compensation - Standard Virginia Workers' Compensation Policy.

Broad Form Comprehensive General Liability - $ 500,000 Combined Single Limit, with the RACSB named as additional insured. The coverage shall include:

Premises - Operations; Products/Completed Operations: Contractual;

Independent Contractors; Owners and Contractor's Protective; Personal

Injury (Liable, Slander, Defamation of Character, etc.);

Automobile Liability - $500,000 Combined Single Limit

X. General Terms and Conditions

A. Announcement of Award: Upon the award or the announcement of the decision to award a contract as a result of this solicitation, RACSB will publicly post such notice on the eVA website (www.eva.virginia.gov) for a minimum of

10 days.

B. Drug-Free Workplace: During the performance of this contract, the contractor agrees to (i) provide a drug- free workplace for the contractor's employees; (ii) post in conspicuous places, available to employees and applicants for employment, a statement notifying employees that the unlawful manufacture, sale, distribution, dispensation, possession, or use of a controlled substance or marijuana is prohibited in the contractor's workplace and specifying the actions that will be taken against employees for violations of such prohibition; (iii) state in all solicitations or advertisements for employees placed by or on behalf of the contractor that the contractor maintains a drug-free workplace; and (iv) include the provisions of the foregoing clauses in every subcontract or purchase order of over $10,000, so that the provisions will be binding upon each subcontractor or vendor.

For the purposes of this section, “drug-free workplace” means a site for the performance of work done in connection with a specific contract awarded to a contractor, the employees of whom are prohibited from engaging in the unlawful manufacture, sale, distribution, dispensation, possession or use of any controlled substance or marijuana during the performance of the contract.

C. Nondiscrimination Of Contractors: A bidder, offeror, or contractor shall not be discriminated against in the solicitation or award of this contract because of race, religion, color, sex, national origin, age, disability, faith- based organizational status, any other basis prohibited by state law relating to discrimination in employment or because the bidder or offeror employs ex-offenders unless the state agency, department or institution has made a written determination that employing ex-offenders on the specific contract is not in its best interest. If the award of this contract is made to a faith-based organization and an individual, who applies for or receives goods, services, or disbursements provided pursuant to this contract objects to the religious character of the faith-based organization from which the individual receives or would receive the goods, services, or disbursements, the public body shall offer the individual, within a reasonable period of time after the date of his objection, access to equivalent goods, services, or disbursements from an alternative provider.

D. Bid Price Currency: All proposals shall be in U.S. Dollars (USD).

E. Authorization to Conduct Business in The Commonwealth: A contractor organized as a stock or nonstock corporation, limited liability company, business trust, or limited partnership or registered as a registered limited liability partnership shall be authorized to transact business in the Commonwealth as a domestic or foreign business entity if so required by Title 13.1 or Title 50 of the Code of Virginia or as otherwise required by law. Any business entity described above that enters into a contract with a public body pursuant to the Virginia Public Procurement Act shall not allow its existence to lapse or its certificate of authority or registration to transact business in the

Commonwealth, if so required under Title 13.1 or Title 50, to be revoked or cancelled at any time during the term of the contract. A public body may void any contract with a business entity if the business entity fails to remain in compliance with the provisions of this section.

F. Governing Law and Jurisdiction: Contractor(s) agree any current or future agreement will be governed by, construed and enforced in accordance with the laws of the Commonwealth of Virginia. Parties agree that personal jurisdiction shall exist in the Commonwealth of Virginia and that the Commonwealth of Virginia shall have subject-matter jurisdiction over any issues arising from interpretation or enforcement of any current or future Agreement. Any lawsuits arising out of any current or future Agreement shall be brought in Fredericksburg, Commonwealth of

Virginia.

XI. Evaluation

An evaluation committee will review and evaluate all replies and detailed proposals that meet the minimum qualifications herein. RACSB may request applicants to conduct oral presentations that will also be evaluated by the committee. The evaluation committee will have only the responses to this RFP to review for selection of finalists and, therefore, it is important that offerors emphasize specific information considered pertinent to the services to be provided.

RACSB reserves the right to select and contract with multiple vendors in order to meet the desired outcomes and timelines. Offerors can propose to deliver all or part of the contract activities and must be clear in which parts are proposed for completion and specify which components of the solicitation were intentionally excluded.

The evaluation criteria and associated scores in the box provided below will be used by the selection committee to rate and rank qualified proposals based upon the Narrative answers provided by the Proposer:

Evaluation Criteria Point Value

Minimum Qualifications Pass/Fail

Space Requirements and Cost 35

Relevant Experience 10

On-site Service Plan 20

Scope of Basic Services 20

Additional Services 15

Total 100 Points

Attachment A: Vendor Data Sheet

Note: The following information is required as part of your response to this solicitation. Failure to complete and provide this sheet may result in finding your proposal nonresponsive.

• Qualification: The vendor must have the capability and capacity in all respects to satisfy fully all of the contractual requirements.

• Vendor’s Primary Contact:

Name:_________________________________________ Phone:________________________________

• Years in business: Indicate the length of time you have been in business providing this type of good or service.

___________Years ______Months.

• eVA Vendor ID or DUNS

Number:________________________________________________________________

• Indicate below at least three current or recent accounts, either commercial or governmental, that your company is servicing, has serviced or has provided similar goods. Include the length of service and the name, address and telephone number of the point of contact.

1. Company:_____________________________________ Contact:______________________________

Phone:__________________________________Email:______________________________________

Project:____________________________________________________________________________

Dates of Service:_____________________________________________________________________

2. Company:_____________________________________ Contact:______________________________

Phone:__________________________________Email:______________________________________

Project:____________________________________________________________________________

Dates of Service:_____________________________________________________________________

3. Company:_____________________________________ Contact:______________________________

Phone:__________________________________Email:______________________________________

Project:____________________________________________________________________________

Dates of Service:_____________________________________________________________________

I certify the accuracy of this information.

Signed:______________________________________________ Title:______________________________________

Date:________________________________________________

Attachment B: State Corporation Commission Form

Virginia State Corporation Commission (SCC) registration information. The undersigned Offeror:

is a corporation or other business entity with the following SCC identification number:

-OR-

is not a corporation, limited liability company, limited partnership, registered limited liability partnership, or business trust is an out-of-state business entity that does not regularly and continuously maintain as part of its ordinary and customary business any employees, agents, offices, facilities, or inventories in Virginia (not counting any employees or agents in Virginia who merely solicit orders that require acceptance outside Virginia before they become contracts, and not counting any incidental presence of the offeror in Virginia that is needed in order to assemble, maintain, and repair goods in accordance with the contracts by which such goods were sold and shipped into Virginia from offeror’s out-of-state location) is an out-of-state business entity that is including with this proposal an opinion of legal counsel which accurately and completely discloses the undersigned offeror’s current contacts with Virginia and describes why those contacts do not constitute the transaction of business in Virginia within the meaning of § 13.1-757 or other similar provisions in Titles

13.1 or 50 of the Code of Virginia.

**NOTE** >> Check the following box if you have not completed any of the foregoing options but currently have pending before the SCC an application for authority to transact business in the Commonwealth of Virginia and wish to be considered for a waiver to allow you to submit the SCC identification number after the due date for proposals (the

Commonwealth reserves the right to determine in its sole discretion whether to allow such waiver):

Signature:________________________________________________ Date:________________________

Print Name and Title:______________________________________________________________________

Name of Firm:____________________________________________________________________________

Attachment C – Proprietary/Confidential Information Identification

Trade secrets or proprietary information submitted by an Offeror shall not be subjected to public disclosure under the

Virginia Freedom of Information Act; however, the Offeror must invoke the protections of § 2.2-4342F of the Code of

Virginia, in writing, either before or at the time the data or other material is submitted. The written notice must specifically identify the data or materials to be protected including the section of the proposal in which it is contained and the page numbers, and state the reasons why protection is necessary. The proprietary or trade secret material submitted in the original and all copies of the proposal must be identified by some distinct method such as highlighting or underlining and must indicate only the specific words, figures or paragraphs that constitute trade secret or proprietary information submitted shall be submitted on this form. The classification of an entire proposal document, line item prices and/or total proposal prices as proprietary or trade secrets is not acceptable. If, after being given reasonable time, the Offeror refuses to withdraw such a classification designation, the proposal will be rejected.

__________________________________ invokes the protections of § 2.2-434F of the Code of Virginia for the following portions of our proposal submitted on __________________.

Signature:______________________________________________ Date:_____________________________

Title:__________________________________________________

DATA/MATERIAL TO BE

PROTECTED

SECTION/PAGE NO. REASON NECESSARY