Adoption Assistance Program (AAP) Level of Care (LOC) Rate Determination and Re-Determination
0200-511.06 | Revision Date: 12/11/2024

Overview

This policy guide provides information on how to apply the Adoption Assistance Program Level of Care (LOC) Protocols to determine the rate for an eligible child in accordance to All County Letter (ACL) 21-54. This policy works in conjunction with procedural guides 0200-511.05, Adoption Assistance Program Benefits and Medi-Cal Benefits, 0900-522.00, Level of Care (LOC) and Specialized Care Increment (SCI) Rate Determinations/Redeterminations, and 0900-511.12, Dual Agency Rates.

Table of Contents

Version Summary

This new policy was developed to align with the statewide rate determination process.
POLICY

Adoption Assistance Program (AAP) Level of Care (LOC) Protocol

The AAP Protocol was designed to support a consistent, statewide rate determination process using four core domains: Physical, Behavioral/Emotional, Educational, and Health.  It is a strength-based rate setting methodology that identifies the AAP eligible child’s individual care and supervision needs.  Each domain is scored separately and totaled to identify an AAP LOC payment rate.

This Protocol is used to determine an AAP eligible child’s maximum eligible LOC rate to be negotiated for initial agreements and subsequent amended agreements.  The rate structure used for initial AAP agreements signed on or after April 1, 2021 includes the statewide Resource Family (RF) Basic Level rate (LOC 1) through LOC 4 rate.  The Protocol applies to:
  • For initial AAP agreements signed on or after April 1, 2021, and agreements where an AAP LOC assessment was not conducted due to the delay in the release of ACL 21-54, a reassessment of the LOC rate should be completed using the AAP LOC protocol. If the reassessment determines the child is eligible for a LOC rate of 2, 3, or 4 an amended agreement must be completed and signed.  The payment for the reassessed rate should be payed retroactive to the start date reflected on the signed initial AAP agreement.
  • For initial AAP agreements signed on or after January 1, 2017, when a reassessment is requested or occurs, agreements that have been renegotiated and an amended agreement signed on or after April 1, 2021.  If the reassessment determines the child is eligible for an AAP LOC rate 2, 3, 4, an amended agreement must be completed and signed.

The roles of the prospective and adoptive parent(s) is factored in the determination process as it accounts for their efforts to meet their adopted child’s care and supervision needs based on the four core domains. The protocol consists of three components:  AAP Level of Care Rate Determination Instruction Guide (AAP9), AAP LOC Matrix (AAP9A), and the AAP Digital Scoring Form (AAP9B).  The protocol also includes the Prospective or Adoptive Parent(s) Reporting Tool (AAP10). An Adoptive Placement or Post Adoption CSW will assist the AAP LOC Unit by providing the AAP 10, Prospective or Adoptive Parent(s) Level of Care (LOC) Reporting Tool, to the Prospective or Adoptive Parents with instructions to complete the tool and submit it to the AAP LOC CSW assigned to their case.  The completed AAP 10 can also be returned to the Adoptive Placement (AP) or Post Adoption Social (PAS) Worker to forward to the AAP LOC Unit when the case is referred for AAP LOC Determination/Re-determination.

The negotiated AAP rate is based on the child’s care and supervision needs and the circumstances of the family and may include the Specialized Care Increment (SCI), if eligible. The SCI rate is to be added to the child’s eligible AAP LOC rate to make up the total AAP rate to be negotiated.  For dual agency children, the eligible AAP LOC rate plus applicable SCI is to be used as the total rate to be negotiated, if this rate is greater than the maximum eligible dual agency rate.  For children age, 0-3 eligible for the Early Start Program through Regional Center, the applicable LOC Rate plus the Tier 2 SCI rate is higher than the 0-3 Dual Agency (P1) Rate. See policy, 0900-511.12, Dual Agency Rates, for more information.

The Adoptive Placement or Post Adoption Social Worker should request an AAP LOC rate assessment following a triggering event.  In relation to AAP, a triggering event would be the determination of a child’s eligibility for AAP benefits prior to the adoption finalization or the reassessment and benefit renegotiation per the adoptive parent(s) request post finalization.

At the completion of the assessment, the AAP LOC CSW will provide to the Adoptive Placement or Post Adoption CSW copies of all relevant documents used to justify the AAP LOC rate for record keeping.  These documents include but are not limited to: AAP 9A, AAP LOC Rate Determination Protocol Matrix, AAP 9B, AAP LOC Digital Scoring Form, AAP 10, Prospective or Adoptive Parent(s) Level of Care (LOC) Reporting Tool and DCFS 1696 SCI Scoring Tool, in order for the Adoptive Placement or Post Adoption CSW to provide copies to the Prospective Adoptive and Adoptive Parent(s):

  • AAP 9A
  • AAP 9B
  • AAP 10
  • Completed DCFS 1696 and SCI Scoring Form

The determination of the maximum eligible AAP LOC rate is documented on the Adoption Assistance Program Negotiated Benefit Amount and Approval Form (AAP 6) and all related documentation, (i.e., AAP9A, AAP9B, AAP10, medical, developmental and mental health assessments, etc.), is attached and filed in the child’s AAP case file that is maintained by Adoptions/Post Adoption Services.

AAP LOC Matrix

The AAP LOC rate determination/redetermination is based on the child’s care and supervision needs that have been identified in the four core domains.  The level of intensity within each domain starts with basic care and supervision needs and increases to a higher intensity of care and supervision.  The assigned point value corresponds with the determined level of care and supervision.

The AAP LOC CSW must consider all the care and supervision needs of the child in the four core domains and the family circumstances.  To score each domain thoroughly and accurately, the AAP LOC CSW should base the assessment on all available current information including, but not limited to, direct observation of the child, information contained in the child’s case file, and information provided by the prospective or adoptive parent(s), which may include verbal information, documentation from the child’s current service providers (medical, therapeutic, education, or other community provider), and the completion of the Prospective or Adoptive Parent(s) Reporting Tool (AAP 10).  Upon the completion of the AAP LOC Matrix (AAP 9A), the AAP LOC Digital Scoring Form (AAP 9B) is to be completed.

AAP LOC Matrix Core Domains

  1. Physical Domain is defined as age/developmentally appropriate actions that are provided by the prospective or adoptive parents(s) to meet the daily activities of living needs. Activities may include eating, clothing, hygiene, community and social functioning, and age and developmentally appropriate life and physical skills even when developmental delays are present.
  2. Behavioral/Emotional Domain is defined as actions in which the prospective or adoptive parent(s) promotes resilience and social and emotional wellbeing for the child/youth, as well as encourage the child/youth to engage in prosocial behavior, healthy activities, and healthy relationships.
  3. Educational Domain is defined as actions in which the prospective or adoptive parent(s) engages in activities, promotes student achievement, fosters education excellence and equal access to services, and when required, responds to suspensions and/or expulsions. School aged child/youth is defined as any child/youth who is attending and participating in early childhood through adult educational programs.
  4. Health Domain is defined as actions in which the prospective or adoptive parent(s) engages to promote the child’s physical health and/or healthy sexual development by arranging and facilitating health care such as medical, dental, vision, transgender needs, medication administration including psychotropic medications and/or monitoring, and ensuring access to services that address special health care needs. Prospective or adoptive parent(s) addresses medical needs, prescribed exercise or nutritional needs.

AAP LOC Digital Scoring Form

The AAP LOC Digital Scoring Form is completed once the level of the child’s care and supervision needs have been determined based on the completed AAP LOC Matrix.  The scoring form automatically calculates and totals the points entered which results in the maximum eligible AAP LOC rate.

Prospective or Adoptive Parent(s) Reporting Tool (AAP 10)

The purpose of the Prospective or Adoptive Parent(s) Reporting Tool (AAP 10) is to promote a shared understanding of the child’s care and supervision needs and the family circumstances by gathering the prospective or adoptive parent(s) input through a dialogue guided by key questions. This tool assists in the determination of the child’s maximum eligible LOC rate for AAP. This tool is intended to identify the child’s care and supervision needs that exceed what would be considered typical for the child’s age and development. If there is more than one parent, the completion of the tool should reflect each parent(s) level of activities required to meet their child’s care and supervision needs. The tool may be completed by the prospective or adoptive parent(s) or in collaboration with the Adoptive Placement or Post Adoption Services Worker. A copy of the completed tool will be provided to the prospective or adoptive parent by mail or e-mail depending on the preference of the prospective or adoptive parent. The AAP 10 may also be completed telephonically with the adoptive parent.  Currently, the AAP 10 is only available in English.

Triggering Events

  • AAP prior to finalization
  • Reassessment (every 2 years) and renegotiation of AAP Rate requested by adoptive parents after finalization of adoption
  • Change in circumstances in the child’s physical, emotional, educational, health, or developmental

Completing Adoption Assistance Program Benefit Forms

The Adoptive Placement (AP) CSW will place a phone call or arrange to meet with the prospective or adoptive parent to discuss the AAP benefits process and to review and complete the AAP 10, Prospective or Adoptive Parent(s) Level of Care (LOC) Reporting Tool, to identify the child’s care and supervision needs.  If there is more than one parent, the completion of the tool should reflect each parent(s) level of activities required to meet their child’s care and supervision needs.

The Adoptive Placement CSW will complete the referral form and submit the AAP 10 and all available supporting documentation (i.e., education, medical, developmental, and mental reports, etc.) to the AAP LOC Unit at aaploc@dcfs.lacounty.gov to determine the AAP LOC rate and score on the AAP 9A and AAP 9B.

AAP LOC Unit CSW will provide the Adoptive Placement CSW the completed AAP 9A and AAP 9B forms to complete the AAP forms.

The Adoptive Placement CSW must document communication with collateral contacts and each step of their work progress in the Case Notebook in Adoptions Integrated System (AIS) or CWS/CMS. AP CSW shall download three (3) sets of the AAP forms from the state’s website (Forms are also found on the Adoption website in LA Kids https://mylakids.dcfs.lacounty.gov/rfspd-new/2019/10/09/aap/ ).  One set with original signatures is for the caregiver, the second set for filing in the AAP Case folder, and the third original signature set is filed in the AAP Document Folder.

AAP LOC Assessment Timeline

AAP LOC CSW has sixty (60) days to complete the AAP LOC assessment from date of assignment to obtaining all necessary approvals.

The AP CSW or designated support staff will mail the AAP 10 form to the prospective or adoptive parent upon receipt of the intake or reassessment request, along with instructions to return the completed form within five (5) business days or request additional time if needed.  The AP CSW must explain that the form is optional but very helpful to determine the child’s care needs and LOC rate.  The AP CSW will also provide their name and phone number of where to call if the caregiver(s) need help to fill out the form.

If the caregiver does not complete the form or asks for assistance or additional time within five (5) business days, the AP CSW may ask the caregiver if they prefer to complete the form telephonically and proceed to mail/email the caregiver the completed form. The AP CSW will proceed with submitting AAP LOC referral. As mentioned above, to score each domain thoroughly and accurately, the AAP LOC worker should base the assessment on all available current information including, but not limited to, direct observation of the child, information contained in the child’s case file, and information provided by the prospective or adoptive parents, which may include verbal information, documentation from the child’s current service providers (medical, therapeutic, education, or other community provider).

PROCEDURE

Case Assignment

Adoptive Placement (AP) CSW Responsibilities

AAP Prior to Adoption Finalization

  1. Review and begin preparing documentation from the current service providers (physical/medical/developmental, behavioral/emotional, educational) and psychosocial background information. Information that may support a higher AAP rate should be included with the referral to AAP LOC in order to allow a thorough review. The AAP 10 form sent to and completed by the prospective adoptive parent(s) will allow best collaboration of the AAP negotiation process.
  2. Complete the referral form and any supporting documentation for rate adjustments for adoption cases and submit to the AAP LOC Unit. AP CSWs may include and indicate forms such as the DCFS 149, Medical Care Assessment Request, JV220s. Psychotropic Medication Authorization, Mental Health reports, IEP, Regional Center documents, etc.

Post Adoption Services (PAS) Assignment Clerk Responsibilities or Designee

AAP After the Adoption is Finalized

  1. Assign AAP case to PAS CSW.

Post Adoption Services (PAS) Children’s Social Worker (CSW) Responsibilities

  1. Complete the referral form, submit medical, developmental, educational or mental health documentations, and any supporting documentation for reassessment and renegotiation of AAP rate requested by adoptive parent(s) and submit to the AAP LOC Unit.

AAP LOC Unit

  1. Receives the AAP LOC referral form and any supporting documentation from the AP CSW or PAS CSW and logs it on the LOC log.
  2. If not already completed, mail/email the AAP 10, Prospective or Adoptive Parent(s) Report Tool, form to prospective or adoptive parent(s) within two (2) days of referral intake with instructions to return the completed form or request additional time to complete the form within five (5) business days of receipt. The mail/email must explain that the form is optional but very helpful to determine the child’s care needs and LOC rate. The mail/email will also provide a name and phone number of where to call if the caregiver(s) need help to fill out the form.
  3. If the Prospective or Adoptive Parent(s) prefer, the AAP LOC CSW may assist them to complete the AAP 10 form telephonically, and then email/mail out a completed copy to the caregiver.

AAP LOC CSW Responsibilities

  1. Complete the determination assessment within fifty-five (55) calendar days of assignment.
  2. Within three (3) business days of assignment, inform the AP/PAS CSW and SCSW they are assigned on the case via email.
  3. Within three (3) business days of assignment, contact via phone the prospective or adoptive parent(s) of the identified child. If initial attempt failed, another attempt must be made within the same week. Additional calls, as well as attempts, by text and e-mail should be made. Communication efforts must be documented on the LOC log and in the contacts section of CWS/CMS.
    1. If unable to reach the prospective or adoptive parent(s) and the AAP 10 form was not received, complete the AAP 9A and AAP 9B. To score each domain thoroughly and accurately, the assessment should be based on all available current information including, but not limited to, direct observation of the child, information contained in the child’s case file, and documentation from the child’s current service providers (medical, therapeutic, education, developmental, or other community provider).
  4. Complete the following when contact has been made with the prospective or adoptive parents(s):
    1. Ask the prospective or adoptive parent(s) if they received or previously completed the AAP 10 form and explain the LOC rate determination process.
    2. Explain the important role they have in this process by providing their input on the AAP 10 form. Explain that completing the form will assist in the determination of the child’s care and supervision needs and LOC rate.
    3. Advise the prospective or adoptive parent(s) that they may complete the AAP 10 form and mail or email back to you or it can be discussed over the phone.
    4. If the AAP 10 form is completed over the phone, document in CWS/CMS that the prospective or adoptive parent(s) gave you permission to document their answers telephonically directly onto the AAP 10 form. A copy of the completed form will be sent to the prospective or adoptive parent(s), by mail or e-mail depending on their preference.
    5. Document their answers on the AAP 10 and indicate in CWS/CMS the language that the interview was conducted in if other than English.
    6. Explain that the information gathered from the AAP 10 and the supporting relevant educational, developmental, medical and mental health documentation provided will be used to complete the AAP 9A form to determine the level of intensity needed to care and supervise the child and to set the LOC rate.
  5. Obtain and review educational, developmental, medical and mental health records from case carrying CSW, Adoptive Placement CSW, or PAS CSW.
  6. Contact service providers, PHNs, regional center, mental health professionals to obtain additional health, developmental, educational and mental health information. Supporting documentation can assist in providing information on additional tasks and higher levels of caregiving being provided by the prospective or adoptive parent(s). However, please note as indicated on the AAP 9A “Prospective or adoptive parent(s) do not need to provide documentation of hours spent on activities.”
  7. Contact the AP/PAS CSWs to request feedback, if any.
  8. Obtain foster care LOC documentation for each case and consult with primary CSW if appropriate.
  9. Document contact with resource parent(s), case carrying/PAS CSW’s and any other collateral information providers in CWS/CMS.
  10. Every child assessed for the LOC must also have a specialized care increment (SCI) assessment. For the medical portion of the SCI assessment, refer to the public health nurse (PHN) and mental health provider for recommendations regarding the SCI. For Finalized, PAS, and Independent/Step-Parent cases: complete the Public Health Nursing Consultation Request and send via email to the PHN Inbox (CWPHNPAS@ph.lacounty.gov). For all open cases: the Specialized Care Increment (SCI) requests should be emailed to the secondary assigned PHN and their Supervising PHN; including the DCFS 1696 a form (SCI three (3) tier Indicators matrix), along with a fully completed DCFS 149 or other appropriate medical documents that include all the required information for assessment. Medical Care records must be dated within six (6) months of the request. The exception is for reassessment of AAP rates prior to 4/1/2021 (or rates that are requesting reassessment of rates prior 1/1/2017), the DCFS 1696 (4-tiered F-rate assessment form) is to be used.
  11. Review all available supporting documentation prior to scoring the domains of the AAP 9A LOC Matrix. Documents below are examples of documents to be provided, no one supporting document is required, and other documents can be utilized so long as the child’s condition is reasonably proven through the records obtained. In addition, prospective or adoptive parent(s) do not need to provide documentation of hours spent on activities. Documents to review include, but are not limited to the following:
    • AAP 10, Prospective or Adoptive Parent(s) Level of Care Reporting Tool, as well as other verbal and/or written information from the prospective or adoptive parent(s).
    • The completed DCFS 1696 Specialized Care Rate Increment Indicator form.
    • Assessments/evaluations, such as the CANS assessment
    • Child and Family Team Meeting (CFTM) Notes
    • Court Reports
    • Minute orders
    • Case plans
    • Medical records/Health Education Passport (HEP)
    • Educational records
    • Mental health records
    • Delivered service log
    • Regional Center and/or other developmental reports
    • Communication with the FFA CSW
  12. Complete the AAP 9A based on information from the prospective or adoptive parent(s) and documentation gathered and reviewed to determine the level of intensity/expectation in each domain.
  13. Transfer the score to the AAP 9B, Section A, and complete the fields on the top portion of the form, including Sections C (resources used to inform the decision), and Section D (social worker’s signature and date). The total score in Section A and the Level of Care Rate in Section B will automatically populate. Total Specialized Care Rate includes any applicable SCI determined.
    1. If the identified child scores five (5) or more in any domains, the child must be moved up a level. (This process will be automatically completed when utilizing the electronic LOC Scoring form).
  14. Document the collaboration efforts in CWS/CMS for open cases.
  15. Submit the following documentation to AAP LOC SCSW for review and approval:
    • AAP LOC Referral Form
    • AAP 9A
    • AAP 9B
    • AAP 10 (recommended but not required)
    • Signs the completed DCFS 1696 Specialized Care Rate Increment Indicator form
    • Supporting documents
  16. When all work is completed and approved, all completed documents shall be sent to the assigned AP/PAS CSW. This will consist of the original referral, AAP 9A, AAP 9B, AAP10, DCFS 1696, and any additional documentation. 

AAP LOC SCSW Responsibilities

  1. Review the completed LOC submission within two (2) days of receipt.
    1. If approved, sign and obtain any required signatures for the DCFS 1696 Specialized Care Rate Increment Indicator form within five (5) days and return the approved LOC packet. See procedural guides 0900-522.00 Level of Care (LOC) and Specialized Care Increment (SCI) Rate Determinations/Redeterminations and 0200-511.05 Adoption Assistance Program Benefits and Medi-Cal Benefits for more information on SCI.
    2. If approval is needed from the ARA for Tier 2 – Tier 3, forward the completed LOC submission for approval. If not approved, advise if additional documentation is needed to complete the packet.

AAP LOC ARA Responsibilities

  1. Review the completed LOC submission for approval within two (2) days of receipt.
    1. If approved, sign and obtain any required signatures for the DCFS 1696 Specialized Care Rate Increment Indicator form. Return the approved LOC packet to SCSW.
      1. If approval is needed from the Adoptions Division Chief for Tier 3, forward the completed LOC submission for approval.
    2. If not approved, advise if additional documentation is needed to complete the packet and return to SCSW.

Adoptions Division Chief or Designee Responsibilities

  1. Review the completed LOC submission for approval within two (2) days of receipt.
    1. If approved, sign and obtain any required signatures for the DCFS 1696 Specialized Care Rate Increment Indicator form. Return the approved LOC packet to ARA.
    2. If not approved, advise if additional documentation is needed to complete the packet and return to ARA.

AAP LOC Support Staff Responsibilities

  1. Monitor the AAP LOC Inbox aaploc@dcfs.lacounty.gov for referrals and inquiries.
  2. Assign incoming referrals in CWS/CMS on a daily basis, forwarding documents to the assigned AAP LOC CSW. Email assigned AP/PAS CSW and SCSW of assignment.
  3. Update the LOC master log on a daily basis.
  4. End-date assignments once AAP LOC assessments are complete.

AP CSW Responsibilities

Upon receiving the AAP LOC rate determination documents, share all of the documentation and findings with the prospective/adoptive family. This information will be part of the AAP rate negotiation process with the AAP 6, Adoption Assistance Program Negotiated Benefit Amount and Approval, form.
  1. Share findings with the CS CSW/SCSW so they may ensure the current foster care rate is up to date.
  2. Prepare all necessary AAP documentation prior to the adoptive placement.
  3. At the adoptive placement, AP CSW ensures that all AAP documents are completed and signed.
  4. Send the approved initial AAP documents to the AAP Intake Unit of Revenue Enhancement Division’s (RED) DCFS AAP Intake Unit Inbox (dcfsaapintake@dcfs.lacounty.gov). For open cases, send the required documents to the Eligibility Worker assigned to the case and copy the Eligibility Worker’s Supervisor, cc the AP SCSW and the AP unit’s Adoption Assistant (AA), when sending initial and reassessed AAP documents.
  5. Follow instructions on AAP negotiation process in procedural guide 0200-511.05 Adoption Assistance Program (AAP) Benefits and Medi-Cal Benefits.

Post Adoption Services (PAS) CSW Responsibilities

  1. Upon receiving the AAP LOC rate determination, share all of the documentation and findings with the Adoptive Family; along with preparing all necessary AAP documentation needed for the reassessment.
  2. Obtain signatures on AD 4320, AAP 2, AAP 6, and submit required documents to the assigned Eligibility Worker (and Eligibility Supervisor if needed).
  3. Update the information on AIS.
  4. Follow the instructions on PAS negotiation process in procedural guide 0200-511.05, Adoption Assistance Program (AAP) Benefits and Medi-Cal Benefits.
APPROVALS

SCSW Approval

  • LOC 1 – LOC 4

ARA Approval

  • Tier 2 – Tier 3

Division Chief or Designee Approval

  • Tier 3
HELPFUL LINKS

Forms

LA Kids

AAP 6, Adoption Assistance Program Negotiated Benefit Amount and Approval

AAP 9, Adoption Assistance Program (AAP) Level of Care Rate Determination Instruction Guide

AAP 9A, Adoption Assistance Program Level of Care Determination Protocol Matrix

AAP 10, Prospective or Adoptive Parent(s) Level of Care (LOC) Reporting Tool

DCFS 149, Medical Care Assessment

DCFS 1696, F-Rate & Regional Center Rate Indicators

Hard Copy

AAP 9B, Adoption Assistance Program Level of Care Digital Scoring Form

DCFS Public Health Nursing Consultation Request

REFERENCED POLICY GUIDES

0200-509.35, Adoptive Placements

0200-510.00, Post Adoption Services

0200-511.05, Adoption Assistance Program Benefits and Medi-Cal Benefits

0900-522.00, Level of Care (LOC) and Specialized Care Increment (SCI) Rate Determinations/Re-determinations

0900-522.10, Specialized Care Increment (SCI) – D-Rate

0900-522.11, Specialized Care Increment (SCI) – F-Rate

0900-511.12, Dual Agency Rates

STATUTES AND OTHER MANDATES

ACL 18-48 , Provide guidance on the use of SCI rates in combination with the LOC rate structure and protocol.

ACL 20-68, Adoption Assistance Program (AAP) Rates

ACL 21-54, Adoption Assistance Program (AAP) Rates Level of Care (LOC) Protocol

ACL 21-97, Provides rate structures for agreements signed prior to January 1, 2017.

California Department of Social Services (CDSS) Manual of Policies and Procedures (MPP), Title 22, Div 2, Adoptions Manual, Subchapter 5, Section 35326-35341 – Summarizes the procedures for the reassessment of a child's needs.

WIC Section 16118 – Addresses the duties and responsibilities of the agency providing financial assistance through the AAP.

WIC Section 16119 – Summarizes the requirements for informing prospective adoptive parent(s) about the availability of AAP benefits and how AAP benefits are determined.

WIC Sections 16120-16120.1 – Summarizes eligibility for AAP benefits, requirements for the adoption assistance agreement, and reimbursement of nonrecurring expenses for a child eligible for AAP. WIC Section 16120(d) (1)(2)(3) states the specific conditions that must be met for eligibility.

WIC Section 16121 – Summarizes adoption assistance, benefit amounts, out-of-home placement requirements/amounts, maximum time, the application process, and adjustments to the adoption assistance payment rate structure.