What CPT 99395 Is and How the Code Gets Selected
CPT 99395 is the preventive medicine code for an established patient between 18 and 39 years old, and a practice selects it on patient status and age, not on problem complexity or time. It reports a periodic comprehensive wellness visit, not a problem-oriented encounter.
AMA CPT descriptor (99395): the AMA CPT code set defines 99395 as a periodic, comprehensive preventive medicine reevaluation for an established patient aged 18 to 39. It covers an age and gender appropriate history and examination, counseling and anticipatory guidance, risk factor reduction, and the ordering of age appropriate labs or diagnostics.
The full descriptor sits in the AAPC CPT 99395 code listing.
Per the American Medical Association CPT code set, CPT 99395 is selected on two criteria only: the patient’s status as established and the patient’s age at the date of service, which has to fall between 18 and 39 years.
The code isn’t selected on medical decision making complexity or total time. It’s a preventive medicine code, not an evaluation and management code. Applying MDM or time thresholds to 99395 billing misclassifies how the code is chosen.
Code selected when:
- Patient is established: seen in the group practice within the last three years.
- Patient’s age at the date of service is 18 through 39 years.
The Two Eligibility Gates: Age and Established Status
The age gate for 99395 is fixed: the patient has to be 18 through 39 years old at the date of service. A patient who has turned 40 moves to 99396. A new patient in the same age band moves to 99385.
| Gate | Rule | What happens when not met |
|---|---|---|
| Age | 18 through 39 years at the date of service | Use 99385 for a new patient or 99396 for a patient 40 and older |
| Patient status | Established: professional services received from the physician, or from another physician of the same specialty and subspecialty in the same group practice, within the past three years | Use 99385 for a patient last seen outside the group more than three years ago |
Per AMA CPT guidelines, a patient is established for preventive medicine billing if they’ve received professional services from the physician, or from another physician of the same specialty and subspecialty in the same group practice, within the past three years.
A patient seen by a different provider of the same specialty within the same group is established, not new. That distinction sends billing teams to new patient classification rules more often than any other preventive coding question.
When a patient turns 40 before the date of service, bill 99396, not 99395. When a patient is new to the practice, with no visit to the same-specialty group in the past three years, bill 99385, a code our new patient preventive visits guide breaks down, not 99395.
New vs established: the billing distinction that generates the most classification denials: A practice that bills 99395 for a patient last seen outside the group three years and one day ago is billing the wrong code, and the payer’s adjudication system catches it.
What a CPT 99395 Visit Must Include
CPT 99395 reports a comprehensive service built from five components, not a checklist a provider ticks off. Documentation that fails to reflect any one component is what triggers payer reclassification to a lower-paying or problem-oriented code.
What CPT 99395 Must Include
- Age and gender appropriate history: The note has to show history was reviewed and updated for this patient’s age and sex risk profile, not copied from a prior visit. Template-cloned history is the top audit trigger on preventive claims.
- Comprehensive physical examination: The exam has to suit an 18-to-39-year-old, including vital signs and BMI. Payers don’t require every organ system, but the note has to read as a preventive exam, not a problem-focused one.
- Counseling and anticipatory guidance: Payers scrutinize this element most. A note that says “counseling provided” without naming the topics (tobacco, alcohol, safe sex, diet, injury prevention, mental health, reproductive health) won’t hold up in an audit. Name the topics.
- Risk factor reduction interventions: This overlaps with counseling but covers the provider’s active recommendations, not the discussion alone: a smoking cessation referral, SDOH screening, or a specific behavioral change goal.
- Ordering age-appropriate labs or diagnostics: Labs and screenings ordered during the visit aren’t bundled into 99395 and bill separately. This bullet sets up Section 4.
Billing teams who know CMS expanded G2211 in 2026 sometimes try to pair it with a preventive visit. They can’t. The G2211 add-on code rules for 2026 don’t allow it on 99395.
The visit doesn’t require every organ system to be examined, but the documentation has to read as a preventive encounter, not a problem-focused visit with a quick vitals check.
Services That Bill Separately and the Counseling Code Trap
Billing teams lose money on preventive claims in two directions at once. They miss separately billable add-ons and leave revenue behind, or they bundle services that shouldn’t be bundled and trigger CO-97. This section closes both gaps.
Services That Bill Separately on the Same Date as 99395
- Vaccines: administration codes (90471 for the first vaccine, 90472 for each additional) bill separately, and the vaccine itself bills under its own immunization CPT code. Neither is bundled into 99395.
- Lab and diagnostic orders: a lipid panel, hemoglobin A1c, STI screening, or cervical cancer screening ordered during the visit bills under its own lab CPT. The 99395 covers the cognitive work of ordering, not the test.
- PHQ-9 depression screening (96127): billable same day as 99395 when separately documented.
- Smoking cessation counseling (99406): billable same day as 99395 when separately documented. Note the 3-to-10-minute threshold for 99406.
- Pap smear (88141 series or 88175): not included in 99395. It bills under its own pelvic exam and cytology codes.
The AAPC guidance on separately billable preventive services confirms which same-day services report independently from the preventive visit.
Per AMA CPT guidelines, counseling codes 99401 through 99404 can’t be reported in addition to preventive medicine codes 99381 through 99395. The anticipatory guidance and counseling components already sit inside the preventive medicine service descriptor. Billing 99401 to 99404 alongside 99395 draws a claim rejection or CO-97 bundling denial guide scenario.
Codes That Cannot Be Billed With 99395
- 99401 through 99404: bundled, can’t be reported separately with 99395.
- Medical nutrition therapy billed by the same provider on the same day: bundled under many payer policies.
- G2211: can’t be appended to 99395 in any scenario.
Most commercial payers allow one 99395 per rolling 12-month period. Calendar-year plans reset January 1. Rolling-window plans count from the last preventive date of service.
Eligibility verification before the visit has to confirm whether the plan uses a calendar year or a rolling window. Submitting a second 99395 before the window closes is a frequency denial, not a coverage denial.
Medicare Does Not Cover CPT 99395: The G-Code Decision Tree
Per CMS, traditional Medicare Part B excludes routine physical examinations from coverage under a statutory exclusion in the Social Security Act. CPT 99395 submitted to Medicare Part B gets denied.
Medicare provides three separate preventive visit codes: G0402 (Welcome to Medicare IPPE, once within the first 12 months of Part B enrollment), G0438 (Initial Annual Wellness Visit, for beneficiaries with 12 or more months of Part B who’ve never had an AWV), and G0439 (Subsequent Annual Wellness Visit, for each AWV after G0438).
CMS prohibits billing G0438 or G0439 within 12 months of billing G0402 for the same patient, as the CMS Annual Wellness Visit billing guidance sets out.
| Scenario | Correct code | Key restriction |
|---|---|---|
| New Medicare Part B beneficiary within first 12 months | G0402 (IPPE) | Once per lifetime. Don’t repeat. |
| Beneficiary enrolled more than 12 months, never had an AWV | G0438 (Initial AWV) | Once per lifetime. Can’t be billed within 12 months of G0402. |
| Beneficiary who has had a prior AWV (G0438 or G0439) | G0439 (Subsequent AWV) | Once per 12-month period. Can’t be billed within 12 months of prior G0439. |
| Established patient, not Medicare, age 18 to 39 | 99395 | Annual. Commercial payer rules apply. |
Medicare Advantage plans vary by plan sponsor. Some MA plans reimburse commercial preventive codes including 99395. Verify coverage directly with the individual MA plan before billing. Don’t assume AWV codes apply to every MA patient.
Providers billing G0402 for the first time have to be enrolled and credentialed with Medicare before the claim. A new provider who isn’t yet enrolled in Medicare gets a denial regardless of the code billed.
One O Seven RCM manages Medicare and Medicaid provider enrollment across all 50 states. If your practice is adding a provider or expanding into Medicare AWV billing, our provider credentialing for Medicare enrollment team handles enrollment from NPI registration through first-claim submission.
Modifier 25 and Same-Day E/M: How to Bill Both Without Getting Denied
When a significant, separately identifiable problem-oriented E/M service happens on the same date as CPT 99395, modifier 25 goes on the problem-oriented E/M code (99212 through 99215), not on CPT 99395.
Appending modifier 25 to the preventive code makes the modifier non-functional and can deny both claims. It’s the single most commonly misapplied modifier in preventive medicine billing, per the AMA Modifier 25 reporting guidance.
| Scenario | Codes | Modifier placement | Payer outcome |
|---|---|---|---|
| Annual preventive visit, no problems addressed | 99395 | None | Paid as preventive, zero patient cost-sharing on a compliant commercial plan |
| Preventive visit plus separately documented chronic condition management (e.g. hypertension medication adjustment) | 99395 + 99213 | Modifier 25 on 99213 only | Both payable if documented separately. E/M portion subject to cost-sharing. |
| Preventive visit plus high-complexity problem with its own assessment and plan (e.g. new cardiac symptoms with workup) | 99395 + 99215 | Modifier 25 on 99215 only | Both payable if documented separately. E/M portion subject to cost-sharing. |
| Preventive visit with a minor complaint noted but not separately evaluated | 99395 only | None | E/M not payable. Note the complaint, but don’t bill a second code without separate documentation. |
The Row 2 and Row 3 examples lean on established-patient E/M levels. Our CPT 99215 billing guide and CPT 99213 billing rules cover how to document each level so the same-day E/M survives review.
The note needs a completely separate section for the problem: its own HPI, targeted exam, assessment, and plan, distinct from the wellness documentation. Intermingled documentation is the top modifier 25 denial cause. A biller who sees a modifier 25 denial should check the note first, not the claim.
If your practice keeps seeing modifier 25 denials on 99395 claims, the root cause is almost always documentation structure, not a coding error.
Our medical billing support team reviews documentation against payer requirements before submission and catches these separability issues before they become denials.
Modifier 33: ACA-mandated preventive services: Modifier 33 signals that a service billed alongside a preventive visit is mandated by the Affordable Care Act under Section 2713, so the payer covers it without patient cost-sharing.
It goes on the separately billable USPSTF A or B rated service (a depression screening or a BRCA risk assessment, for example), not on CPT 99395 itself.
Confirm against the AMA preventive services coding guides that the specific USPSTF service needs modifier 33 before appending it.
Can nurse practitioners and physician assistants bill CPT 99395?: Nurse practitioners, physician assistants, and other qualified healthcare professionals authorized to deliver E/M services within their scope can bill CPT 99395.
The requirement is that the QHP documents every preventive component: history, examination, counseling, and ordering of labs or screenings. Billing independently under the QHP’s own NPI follows standard preventive documentation rules. Incident-to billing under a supervising physician’s NPI follows commercial payer incident-to rules and requires the physician to be present in the office suite.
ICD-10 Codes for CPT 99395: What to Use, What to Avoid, and Why It Matters
The primary ICD-10 code on a CPT 99395 claim decides whether the payer processes it under the patient’s preventive benefit or the diagnostic benefit. That single coding choice controls patient cost-sharing, payer adjudication, and audit risk.
| Code | Description | When to use | Billing implication |
|---|---|---|---|
| Z00.00 | Encounter for general adult medical examination without abnormal findings | All findings normal, no new conditions identified | Payer processes as preventive; zero patient cost-sharing on compliant commercial plans |
| Z00.01 | Encounter for general adult medical examination with abnormal findings | One or more abnormal findings identified (elevated BP, abnormal lab, incidental finding) | Use Z00.01 as primary plus the specific finding as a secondary code. Still processes as preventive. |
| Z23 | Encounter for immunization | Immunization given during the visit | Secondary code only, alongside Z00.00 or Z00.01. Not a standalone primary for a preventive visit. |
| Z13.xx | Preventive screening codes | Age-appropriate screening performed | Secondary code alongside Z00.00 or Z00.01. Examples: Z13.220 lipid screening, Z13.1 diabetes screening. |
Diagnosis Codes That Reclassify a Preventive Visit as Diagnostic
Using a condition-specific or symptom-based ICD-10 code as the primary diagnosis on a CPT 99395 claim makes the payer’s adjudication system reclassify the visit as a diagnostic encounter. The claim then processes under the patient’s medical benefit, not the preventive benefit, which applies deductibles and copays the patient didn’t expect to owe.
- Any R-code (symptom codes like R07.9 chest pain or R06.00 dyspnea).
- Any chronic condition code as a standalone primary (E11.9 type 2 diabetes, I10 hypertension).
- Any injury or acute illness code.
Abnormal findings rule: when Z00.01 is the primary diagnosis, the specific abnormal finding should appear as a secondary code on the claim. If elevated blood pressure was found but hypertension hasn’t been formally diagnosed, use R03.0, not I10.
A mismatched primary diagnosis is the mechanism behind CO-11 denials on preventive claims. The payer’s adjudication engine validates the diagnosis-to-code relationship automatically and returns a CO-11 diagnosis mismatch denial before clinical review.
CPT 99395 Reimbursement in 2026: What Commercial Plans Pay and How RVUs Work
Reimbursement for CPT 99395 isn’t based on Medical Decision Making complexity. It’s a preventive medicine code. Payment is calculated from Relative Value Units in the Medicare Physician Fee Schedule, then adjusted by the payer’s contracted rate and geographic index.
| Component | Value | What it represents |
|---|---|---|
| Work RVU (wRVU) | Approximately 1.92 | Provider cognitive effort, clinical judgment, and time |
| Practice Expense RVU | Verify via CMS PFS Look-Up Tool | Operational overhead (staff, equipment, facility) |
| Malpractice RVU | Verify via CMS PFS Look-Up Tool | Professional liability component |
| Total RVU | Verify via CMS PFS Look-Up Tool | Sum of all three components before geographic adjustment |
The wRVU of about 1.92 comes from published fee schedule tools. Verify the current-year total RVU through the CMS Physician Fee Schedule Look-Up Tool before using it for contract benchmarking.
Under the CY 2026 Medicare Physician Fee Schedule (CMS-1832-F, effective January 1, 2026), CMS set two separate conversion factors for the first time in Medicare history: $33.40 for non-qualifying APM participants and $33.57 for qualifying APM participants, per the CMS CY 2026 Physician Fee Schedule final rule fact sheet.
Primary care services, preventive medicine codes among them, are expected to see reimbursement increases under the 2026 final rule. The total payment for CPT 99395 is the total RVU multiplied by the applicable conversion factor, then adjusted by the Geographic Practice Cost Index for the practice’s location.
| Payer | Average rate |
|---|---|
| BCBS | $135.57 |
| UnitedHealthcare | $137.37 |
| Aetna | $137.39 |
| Cigna | $176.78 |
| OB/GYN specialty practices | $333 to $371 (UHC examples from federal transparency data) |
Commercial rates vary by contract, geography, and specialty. OB/GYN providers billing 99395 regularly see higher rates than primary care, especially through UHC. These figures come from federal price-transparency data and represent negotiated rates, not Medicare payment. Primary care teams running high preventive volume lean on structured preventive billing services to keep these rates captured cleanly.
Practices that benchmark their 99395 contracted rates against federal transparency data routinely find negotiation gaps worth thousands of dollars a year. Our revenue cycle management services include payer contract analysis as part of the full RCM workflow, so your preventive care reimbursement reflects what the market supports.
Eight Denial Codes That Hit CPT 99395 Claims and How to Resolve Each One
Preventive medicine claims generate a distinct denial pattern. Most denials on CPT 99395 don’t come from incorrect code selection. They come from documentation gaps, eligibility failures, and classification errors that were preventable before the claim left the practice.
| Denial code | What it means for this code | Most common root cause | Resolution |
|---|---|---|---|
| CO-16 | Missing or incomplete information on the claim | Missing counseling documentation, preventive intent not stated, or an incomplete history section | Resubmit with complete documentation. Build a counseling checklist into the note template. |
| CO-50 | Service not medically necessary | Symptom or condition-specific ICD-10 used as primary, so adjudication reads the visit as diagnostic | Correct the primary diagnosis to Z00.00 or Z00.01. Resubmit with preventive-intent documentation. |
| CO-96 | Non-covered charge | CPT 99395 submitted to Medicare Part B | Don’t submit 99395 to Medicare. Use G0402, G0438, or G0439 per CMS eligibility rules. |
| CO-97 | Service included in another already paid | Counseling code 99401 through 99404 billed alongside 99395 | Remove the counseling code. The anticipatory guidance is included in 99395 per AMA CPT rules. |
| CO-11 | Diagnosis inconsistent with the procedure | Condition-specific primary diagnosis paired with a preventive CPT | Correct the primary diagnosis to Z00.00 or Z00.01. Resubmit. |
| CO-197 | Pre-authorization required | Same-day E/M without separate documentation, or a payer that requires PA for certain modifier 25 pairings | Confirm the payer’s PA rules for same-day E/M. Make sure documentation separates the preventive and problem-oriented services. |
| Frequency denial | Benefit limit reached | A second 99395 submitted before the 12-month window closed | Verify the last preventive date of service before scheduling. Confirm calendar year versus rolling 12 months. Resubmit with a gap-in-care appeal if warranted. |
| Patient responsibility conversion | Claim reprocessed from preventive to diagnostic | Symptom or condition codes without a proper Z-code primary, or modifier 25 E/M that didn’t separate services | Appeal with the complete note showing preventive intent. Provide the separate E/M documentation if modifier 25 was used. |
Each denial code has a dedicated resolution guide: CO-16 missing information guide, CO-97 bundling denial guide, CO-96 non-covered charge guide, CO-11 diagnosis mismatch denial, and CO-197 prior auth denial guide.
Practices with a high volume of CPT 99395 denials in CO-16 and CO-50 usually share one root cause: the note template doesn’t require explicit counseling documentation, and billers submit claims without confirming the note reflects all five AMA descriptor components. Fixing the template upstream clears both denial types at once.
If CO-16 and CO-50 show up together on your 99395 remittance reports, the fix is upstream, not in the appeal. Our denial management services team reviews your note templates and claim-submission workflow to find the documentation gap before it generates the next round of denials.
Three 2026 Updates That Affect How Practices Bill Preventive Visits
Three policy developments shape how practices bill alongside CPT 99395 in 2026. Each one affects what can be billed on the same date, what can’t, or who has to cover the service at zero cost-sharing.
Update 1: The G0136 SDOH Risk Assessment and Same-Day Documentation
CMS recognizes HCPCS code G0136, the Social Determinants of Health risk assessment, as a separately billable service when the provider uses a standardized SDOH screening tool, documents the tool name, records the score, and notes any referrals or interventions. G0136 carries a frequency limit of not more than once every six months.
CMS introduced the SDOH risk assessment as an optional element through the 2024 Physician Fee Schedule, and it remains in effect, as the CMS SDOH risk assessment G0136 guidance sets out. Commercial coverage for G0136 alongside a preventive visit varies by payer, so confirm the plan’s policy first.
Update 2: G2211 Cannot Be Appended to CPT 99395 in 2026
G2211 expanded in 2026 to include home and residence E/M codes (99341 through 99350). It didn’t expand to preventive medicine codes. G2211 can’t be reported with CPT 99395 under any scenario.
Billing teams that try to append G2211 to a 99395 claim get an automatic rejection. The G2211 expansion covers E/M codes only. The G2211 guide on this site breaks down the full add-on rules.
Update 3: ACA Section 2713 Requires Zero Cost-Sharing on Non-Grandfathered Commercial Plans
Under Section 2713 of the Affordable Care Act, non-grandfathered health plans must cover USPSTF A or B rated preventive services at zero patient cost-sharing when delivered in-network. CPT 99395 as a comprehensive preventive visit qualifies under this mandate when coded with Z00.00 or Z00.01 as the primary diagnosis.
Plans that existed before March 23, 2010 and haven’t made significant coverage changes may be grandfathered and aren’t required to cover preventive services at zero cost-sharing. Medicare Advantage plans vary by sponsor and should be verified individually.
If the visit includes a separately billed problem-oriented E/M with modifier 25, the E/M portion may be subject to standard cost-sharing even though the 99395 portion isn’t.
CPT 99395 Questions Billing Teams Ask Most
What is CPT code 99395?
CPT 99395 is the preventive medicine billing code for a comprehensive periodic wellness visit for an established patient between 18 and 39 years of age.
It covers an age-appropriate history, physical examination, counseling and anticipatory guidance, risk factor interventions, and the ordering of appropriate labs and screenings. It isn’t selected on Medical Decision Making or time, but on the patient’s established status and age at the date of service.
What is the difference between CPT 99395 and 99396?
CPT 99395 applies to established patients aged 18 through 39, and CPT 99396 applies to established patients aged 40 through 64.
Both codes cover the same type of comprehensive preventive visit but differ in the age-appropriate screenings and counseling required. When a patient turns 40 before the date of service, the correct code is 99396, not 99395. Billing 99395 for a 40-year-old draws an automatic age-range denial on most payer systems.
What is the age limit for CPT 99395?
CPT 99395 applies to patients who are 18 through 39 years of age at the date of service.
The age must be confirmed at the time of billing, not at the time of scheduling. For new patients in the same age range, the correct code is 99385. For patients 40 and older, use 99396.
Does CPT 99395 need a modifier?
CPT 99395 doesn’t require a modifier when billed alone for a preventive-only visit.
Modifier 25 belongs on the problem-oriented E/M code, not on 99395, when a significant, separately identifiable problem-focused service happens the same date. Modifier 33 may be required on specific USPSTF-mandated preventive services billed separately. No modifier belongs on 99395 itself in either scenario.
Is Medicare covered under CPT 99395?
No. Traditional Medicare Part B doesn’t cover CPT 99395 for routine preventive physical examinations.
Providers billing Medicare patients for annual preventive visits must use G0402 (Welcome to Medicare IPPE), G0438 (initial Annual Wellness Visit), or G0439 (subsequent Annual Wellness Visit) depending on the patient’s benefit history. Submitting 99395 to Medicare Part B generates a CO-96 non-covered charge denial. Medicare Advantage plans vary and should be verified per plan.
Does ACA cover CPT 99395?
Yes, non-grandfathered commercial health plans must cover CPT 99395 at zero patient cost-sharing when billed correctly as a preventive visit.
Under ACA Section 2713, USPSTF A or B rated preventive services must be covered without deductibles or copays for in-network providers. Plans grandfathered before March 23, 2010 are exempt. If the same visit also includes a separately billed problem-oriented E/M with modifier 25, the E/M portion may be subject to standard cost-sharing even though the 99395 portion isn’t.
Is a pap smear included in CPT 99395?
No, a pap smear isn’t included in CPT 99395 and bills separately under the appropriate cytology and pelvic exam codes.
The 99395 descriptor covers the preventive evaluation work: history, examination, counseling, and lab ordering. The pap smear itself, meaning specimen collection and cytology interpretation, bills under CPT 88141, 88142, 88175, or the variant matching the collection method. Billing teams shouldn’t include pap smear codes on the 99395 claim line.
Can a nurse practitioner bill CPT 99395?
Yes, nurse practitioners, physician assistants, and other qualified healthcare professionals can bill CPT 99395 when they document all required preventive service components.
The QHP must be authorized to deliver evaluation and management services within their scope of practice. Billing under the QHP’s own NPI follows standard preventive documentation rules. Incident-to billing under a supervising physician’s NPI follows commercial payer incident-to rules and requires the physician to be present in the office suite at the time of service.
Does CPT 99395 unbundle from CPT 90471?
No, CPT 99395 doesn’t bundle with CPT 90471.
CPT 90471 is the vaccine administration code for the first immunization given during a visit. It bills separately alongside 99395 when immunizations are administered. The 99395 code covers the preventive evaluation; 90471 covers administering the vaccine. NCCI edits don’t bundle these two codes, and both are payable on the same claim when documented.
Before You Submit: A Pre-Submission Checklist for CPT 99395 Claims
Every preventive visit claim is clean or broken before it leaves the practice. Run this check against every CPT 99395 submission before it hits the clearinghouse.
- Confirm the patient’s established status: professional services from the same specialty in the same group within the past three years.
- Confirm the patient’s age at the date of service is 18 through 39. If 40 or older, use 99396.
- Confirm the note documents all five AMA descriptor components: history, examination, counseling, risk factor interventions, and lab or screening orders.
- Confirm counseling topics are named in the note, not stated as “counseling provided.”
- Confirm the primary ICD-10 is Z00.00 or Z00.01, with no symptom or condition code as primary.
- Confirm no 99401 through 99404 codes sit on the same claim line.
- Confirm payer eligibility: the patient hasn’t had a preventive visit within the plan’s defined 12-month window.
- If a same-day E/M is billed, confirm modifier 25 is on the E/M code, not on 99395, and the note has a separate section for the problem.
- Confirm the patient’s plan isn’t Medicare Part B. If Medicare, substitute the appropriate G-code.
- Confirm the claim goes out under the correct provider NPI and that the provider is enrolled and credentialed with the payer.
Practices that run this check consistently on 99395 claims clear the majority of preventable denials before they reach AR aging. If your team needs a more systematic approach across your full preventive billing volume, our billing services for primary care include pre-submission review as a standard workflow step.
