Subject: Re: ROA and the LACK of ACTION on the 7200 Point Rule (DOD Policy)


Ms Lukas,

Thank you for your reply.  This represents the most informative yet I have seen on the subject from the ROA

Susan Lukas wrote:
 

Afternoon, Maj Gen McIntosh asked me to respond to your e-mails as I have recently been appointed as the new ROA Director for Legislation.  You are talking about two different legislative pieces in your correspondence and I want to clarify what they are before proceeding in my update.  There are two pieces of legislation related to disability pay.  The first is concurrent receipt and the second is Combat Related Special Pay.  Since Congress as a complete body could not agree on concurrent receipt language or how it would be paid for they passed a compromise provision called Combat Related Special Pay (CRSP).  This special pay legislation is where the 7200 point eligibility provision resides.

I am familiar with the 7200 point rule as implemented as a consequence of Special Compensation for the Severely Disabled (SCSD, 10 USC 1413) and as rubber stamped for the Combat Related Special Compensation (CRSC, 10 USC 1413a) which is now being implemented.  The oldest document I have that references the 7200 point policy is DFAS-CL 1352.2PH, dated April 2001.  CRSP is a new one for me ... I suspect that is the proposed title for what is now being negotiated in the NDAA 2004 Joint Committee?
 

 Last year when the House Armed Services Committee met with the Reserve and Guard to announce the Combat Related Special Pay legislation, Col Anderson and I both attended, along with other Military Coalition associations.  I believe it was Col Anderson who brought up the 7200 point issue and how it basically excluded all Reserve Components.  A discussion then ensued with the Chairman, Duncan Hunter, and other Representatives and committee staff.  It was my impression that they did not understand the full implications until then but were sincere in wanting to get it fixed.  The point was a combat disability is a combat disability and it has nothing to do with points earned.  Believe me the Marine Reservist I know of who has lost his leg at 25 years old can’t bring that leg back no matter how many points he does or does not do. 

With a mere 100 (0.63%) of 15,976 Guard and Reservists with disability actually drawing SCSD (based on DFAS provided numbers ... see attachment) I would say "basically excluded" is being kind ... it is near absolute exclusion ... especially when some 29,000 (33.6%) of 88,000 active service retirees with a minium of 60% service connected disability are drawing SCSD.  I think a 33% difference is signficiant.

If the Committee members and their staffs do not understand the implication of this illegal policy ... give me a time, date and place, and I will gladly explain it to them.  I will also gladly explain to them how the Reserve retirement system works to include the award of points, qualification of retirement years, and how point capping works to prevent a Guard Reserve from attaining 360 points/year.  I estimate 2 hours to adequately cover the subject to include questions and answers.
 

 ROA has continued to take every opportunity to talk to Congress and have our voice heard on this issue.  With Col Anderson as The Military Coalition representative and on the Guard and Reserve Subcommittee the 7200 point discrepancy was put as the number one issue being represented by the TMC Retiree Committee to Congress on their priority list this year.  The reason it may appear nothing is being done is because of the proposed concurrent receipt legislation.  Please note, however, the September and October (coming out) magazines where Gen McIntosh and I both address the concurrent receipt issue.

Not everybody receives the ROA magazine.  Why not post a legislative update to the web as do MOAA, TREA, NAUS, and several other organizations? 
 

 A majority of the House and Senate are supporting passage of concurrent receipt legislation this year and their focus has been on how that legislation will be worded.  If this language is passed it will supersede the Combat Related Special Pay and the 7200 points will no longer be an issue.  ROA has been working both of these issues to make sure everyone understands the impact to the Reserve Components and so if one, but the other doesn’t go through, the Reserve Components will not be again excluded.

I beg to differ that 7200 points will no longer be an issue.  The policy must specifically be voided in the NDAA.  I am not a lawyer, but when I read 10 USC 12733 upon which DOD cites as authority for the policy, I see egregious logic errors in making the leap to the policy.  How can the DOD have used this section for some 50+ years to implent the reserve retirement system without much difficulty and then take a 180 degree opposite tack with the 7200 point policy?

Please note that in the attachment, first enclosure, I have provided suggested wording changes to 10 USC 17233 that should remove any doubt in the DOD General Counsel's thinking as to the purpose of dividing total points by 360 to arrive at equivalent years for retirement pay which for a reservist are NOT THE SAME as years of service for pay as they are for the active component.
 

 The reason you have recently seen a position paper on our website is because Maj Gen McIntosh has asked me to strengthen our grassroots program and this is one of several initiatives in that area.  We are also trying to pump up our CAPWIZ site for our members to communicate with Congress and holding a seminar during Mid-Winter on Congressional visits.  These are just a few of the things we are doing. 

This has been a long time in coming and is very much overdue.  ROA must recognize that the internet has forever changed communications among and between people.  Where in the past with paper and telephone media much of the communications was vertical from the grass roots to the national organization.  With the internet there is very much more horizontal communications among the grass roots and those national organizations that fail to get into the loop will simply be bypassed.  I wrote the ROA President in January 2003 concerning the 7200 point issue and never received a reply ... thus I bypassed the organization that should have been the vanguard on this issue since 2001.
 

 Again thank you for your comments; it was indeed very disheartening to see Reservists excluded from a policy yet again, even if it was unintentional.  The amount of legislation Congress has to get through each year is almost inconceivable which is exactly why ROA represents their members on national defense issues.  Together we will work the issues so important to our force.

Congression intent is fairly clear, they made no distinction between the reserve and active components, thus one can infer equitable treatment under the law, but I can not say the same for the Department of Defense.  I have letters from the ASD-RA Thomas Hall and DASD-RA(M&P) John Winkler that use circular logic based on a faulty major premise to defend the 7200 point policy as being consistent with the law and neither offered a review or reconsideration of the policy.  Only after I was able to process the DFAS provided data that is summarized at the end of enclosure 2 to the attachment, did the ASD-RA state that corrective words would be included in the DOD legislative package for 2005.  He also said the same thing in December 2002 for the DOD legislative package for 2004, which had no such wording.  On the presumption that the DOD is not stupid, I must conclude the exclusion was intentional. 

Further, I suspect that the 54 state Adjutants General do not understand the implications of the 7200 point exclusionary policy.  The exceptions are Oklahoma, Pennsylvania and New Mexico, who responded to my February letter to them asking for their concern and interest. 

I also note that the DOD has yet to comply with my FOIA request to provide documentation showing the audit trail and decision making process to include those who signed off on the 7200 policy.  My conclusion at this point is that they are "winging" the policy ... they do not have the documentation.

Charles D. Revie
LTC, USAR, Retired, 25 credited/qualified retirement years, 6818 career points
100% Service Connected Disability (non Hodgkin's Lymphoma, Agent Orange, Vietnam)
Excluded by illegal DOD 7200 point policy from the benefits of SCSD and CRSC


 

-- 

Charlie Revie



Urge your Representatives and Senators to 

* Support passage of Sec 644 HR-1588 (NDAA 2004) without change.

* Abolish the DOD 7200 point policy that excludes Guard and Reserve

from intended disability benefits.



**********************

*OUT THE DOOR IN 2004*

**********************



Sign the petition

<http://www.PetitionOnline.com/VVBMRHC/>



Report all SPAM to <uce@ftc.gov>
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UNIFORMED SERVICES DISABLED RETIREES

Director for Guard and Reserve Affairs

720 Sundown Court, Las Cruces, NM 880011

Telephone 505-522-3317

                                                                                                                       September 2, 2003

 

 

Joint Committee Members

National Defense Authorization Act of 2004

 

 

Ladies and Gentlemen: 

As you return from your August recess I remind you of the arbitrary Department of Defense 7200 point policy implemented during the Clinton administration that excludes National Guard and Reserve retirees from the intended benefits of Special Compensation for the Severely Disabled (SCSD, 10 USC Section 1413).  

The effect of the 7200 point policy (not law, not regulation, not in the public record, and apparently not available under the Freedom of Information Act) is that a mere 100 (0.63%) of 15,976 disabled Guard and Reserve retirees actually draw SCSD, while some 29,706 (33.6%) of 88,481 disabled active component retirees with at least 60% disability draw SCSD.  I think we agree that a 33% difference is very significant?   

Even if SCSD included all disabilities, a mere 478 (2.99%) of Guard and Reserve retirees would qualify because of the 7200 point threshold. 

With the authorization of more liberal benefits under the more recently authorized Combat Related Special Compensation (CRSC, 10 USC Section 1413a), the current administration blindly copied forward the 7200 point policy.  As CRSC does not relax the 7200 point threshold, these numbers will not change for Guard and Reserve retirees; yet one can anticipate full 100% qualification of those 88,481 active component retirees with at least 60% disability.  I think we can agree that this 99.37% difference confirms a total exclusion of the Guard and Reserves from this benefit. 

Now, we arrive at your task for this September:  Regardless of how, you, the Joint Committee, negotiate the proposed Section 644 of the National Defense Authorization Act of 2004 (as is, delete, or compromise), there remains no reason to believe that the Bush administration, as represented by the Department of Defense, will not again blindly rubber stamp the 7200 point policy forward as it did for CRSC.  After all, the Department of Defense would like to have us all believe that these compensations (CRSD, CRSC, Concurrent Receipt/Disabled Retirement Tax) are taking dollars away from their budget when, in fact, we all know that dollars for the Military Retirement Trust Fund are effectively entitlement funded.  Protests, arm and antennae waving notwithstanding, end of discussion. 

As the Department of Defense ambivalently references 10 USC Section 12733 as the basis for the 7200 point exclusionary policy, I suggest that as part of the NDAA 2004, you clarify the wording of that section to show that the computation of dividing retirement points by 360 is to determine the number of equivalent years for the computation of the base pay multiplier used in 10 USC Section 12739 for the computation of retired pay.  Until the advent of SCSD and duplicity of the 7200 point policy, the Department of Defense had no difficulties since the current rules were established in 1947, understanding and implementing the intent of Section 12733 for retirement of Guard and Reserve.  In other words, the computation of my retirement pay (see note following) follows this law, basically unchanged for 56 years, but the logic used to derive the 7200 point policy upon this same law is new and wanting. 

Note:  Per Section 12733, my 6818 career points divided by 360 is 18.84 equivalent years for retirement computation.  Per Section 12739, 18.84 equivalent years multiplied by 2.5% provides a base pay multiplier of 47.35%.  Also, per Section 12733, I have a total of 25 years credited for retirement based on a minimum of 50 points earned for each of those yearsnot 360 pointsThe result is that while I have 25 years "credited" (per 10 USC 1413 and 1413a) for retirement, I do not qualify for these compensations because I lack 7200 points (per policy). 

With the Bush administration's aggressive commitment of the National Guard and Reserve in support of the war on terrorism and in actual combat, I think you will agree that the 7200 point policy excludes them from promised benefits that accrue to the active component.  I do not think that such discrimination against the National Guard and Reserve was the intent of Congress in the passage of this legislation. 

Are National Guard and Reserves at risk?  Just this past July a 54 year old, retirement eligible, National Guardsman, a grandfather with 7 grandchildren, was killed in Iraq.  Since the beginning of the Iraq War nearly 300 US Soldiers have been killed in action, a full 25% of these are Guard and Reserve.  To avoid manpower ceiling limits, the Secretary of Defense proposes to maintain Guard and Reserve units and personnel on active duty for up to one year on a rotational basis with call ups no more frequent than once every six years.  There is already a case in the courts were an employer dismissed an employee because he is a reservist [Balodis v. The Pep Boys Manny Moe & Jack, No. CV-03-022 (D. Ariz.)]. 

Enclosure 1 provides my suggested change to 10 USC Section 12733 to clarify the intent of that section. 

Enclosure 2 is same as provided in my August letter. 

I urge your strongest efforts to void by law, the Department of Defense policy that discriminates against and excludes National Guard and Reserve retirees from benefits to which they would otherwise be entitled as intended by Congress.  Thank you for your earnest involvement in this matter. 

Sincerely,

 

Charles D. Revie

Lieutenant Colonel, US Army Reserve Retired

100% Service Connected Disability

USDR Director for Guard and Reserve Affairs

 


 

 

Guard and Reserve Disability Equity Act of 200_


A BILL

To amend title 10, United States Code, to permit retired members of the National Guard and Reserve who have a service-connected disability to receive either the Special Compensation for the Severely Disabled or the Combat Related Special Compensation otherwise authorized by title 10, United States Code, Sections 1413 and 1413a.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

This Act may be cited as the `Guard and Reserve Disability Equity Act of 200_ '.

SEC. 2. FULL PAYMENT OF BOTH RETIRED PAY AND COMPENSATION TO DISABLED MILITARY RETIREES.

RESTORATION OF FULL RETIRED PAY BENEFITS- Section 12733 of title 10, United States Code, is amended, by inserting the words "for retirement pay," to read as follows:

` Sec. 12733. - Computation of retired pay: computation of years of service

`For the purpose of computing the retired pay of a person under this chapter, the person's years of service for retirement pay and any fraction of such a year are computed by dividing 360 into the sum of the following: '

SEC. 3. EFFECTIVE DATE; PROHIBITION ON RETROACTIVE BENEFITS.

(a) IN GENERAL- The amendments made by this Act shall take effect on--

 

(1) the first day of the first month that begins after the date of the enactment of this Act; or

 

(2) the first day of the fiscal year that begins in the calendar year in which this Act is enacted, if later than the date specified in paragraph (1).

 

(b) RETROACTIVE BENEFITS- No benefits may be paid to any person by reason of sections 1413 and 1413a of title 10, United States Code, as amended by section 2, for any period before the effective dates of Sections 1413 and 1413a.

 

 


 

                                                                                                            July 16, 2003

 

Talking Paper:  7200 Point Exclusion of Guard and Reserve from Benefits

 

1.  Special Compensation for the Severely Disabled (SCSD)

 

    a. Enacted as 10 USC 1413 with NDAA 2000 (PL 106-65) with 70% minimum disability.  Revised by NDAA 2001 (PL 106-398) with 60% minimum disability.

 

    b. Statutory eligibility requirements--

        * 20 years of "creditable" service in the uniformed services.  No requirement that years of service be active duty time.

        * 60% minimum "qualifying" service-connected disability

        * Disability rating received within 4 years following retirement (this restriction has no other purpose than as the confessed cost containment measure)

 

    c.  The maximum amount payable is $350/month for 100% service connected disability.

 

    d. There is no mention of the reserve component.

 

2.  DoD 7200 Policy established for the reserve component in response to SCSD.

 

    a.  Based on DFAS data for 15976 guard reserve retirees with disability, 2929 (18.3%) have a minimum of 60% disability and 478 (2.9%) have a minimum of 7200 points.  The result is that a mere 154 (0.96%) qualify for SCSD.  Of this number only 100 (0.63%)are actually drawing SCSD.  The enclosed table shows this breakout.

 

    b.  Policy established by secondary reference only such as found in the --

 

        * DoD Financial Management Regulations, paragraph 60202, which states,

"A Reservist with retired pay computed under provisions of 10 USC, Chapter 1223, must have at least 20 years or more of qualifying service as defined by 10 USC 12733.  Thus, a retired Reservist must have 7200 points or more and be in receipt of retired pay (unless waived) to be eligible for special compensation.  A retired Reservist in a drilling status is not entitled to the special compensation."  (underlining added for emphasis)

 

        * The underlined portions of the above reflect the leap to a conclusion that resulted in the 7200 point policy.  The 7200 point requirement disregards the fact (see below) that a Guard Reservist not on extended active duty is limited to 60, 75, or 90 points/year for reserve duty and will acquire 15 active duty points/year for active duty for training.

 

    c.  10 USC 12733 provides "… years of service … are computed by dividing 360 into the sum of the following … " retirement points.  Note that 12733 says nothing about 7200 points.

 

    d. 10 USC 12732-12733 qualify retirement points as --

        * earned while on active duty limited to 365/366 per year

        * earned while on reserve duty limited to 60-75-90 per year depending upon the date earned --

        ** 60/year for service before and including Sept 23, 1966

        ** 75/year for the period Sept 23, 1966, to Oct 30, 2000, inclusive

        ** 90/year beginning with and including Oct 30, 2000.

 

        Comment -- be prepared to discuss in a fair amount of detail how a reservist earns points to include 15 membership points, 1 point/day of active duty (15 days of annual training/year), 1 point/drill (48 drills/year, at two 4-hour drills/day the only time at which one can earn more than 1 point/day), and various other sources of points.  With the 60 point cap, a typical reservist had 100% participation (48 drills and 15 membership points)  lost 3 reserve points (48 + 15 = 63) and earned a total of 75 points (60 reserve + 75 active).  When the usual two weeks active duty for training each year (15 points) the typical number of total points/year will be 75, 90, or 105 depending upon the year in which earned.

 

    e.  10 USC 12732 qualifies years for retirement as any year in which a minimum of 50 points was earned.  Thus, at reservist can retire at age 60 with 20 "qualified" years.

 

    f.  Before the advent of SCSD, the purpose of 10 USC Chap 1227 was to qualify points and years for retirement based on the following --

 

        * 10 USC 12732 defines how points could be earned and qualified.

 

        * 10 USC 12733 defines how points are and years are quantified for computation of years for retirement pay purposes (as differentiated from qualification for retirement) by dividing total qualified years by 360.

 

        * 10 USC 12739 specifies the equivalent years determined in 12733 be multiplied by 2.5% to determine the percentage multiplier to be used in conjunction with the base pay amount (based on total years of service and pay grade) to determine the amount of retirement pay.

 

3.  Combat Related Special Compensation (CRSC)

 

    a.  Enacted as 10 USC 1413a with the NDAA 2003 (PL 107-314).

 

    b.  Statutory eligibility requirements--

        * 20 years of "creditable" service in the uniformed services.  No requirement that years of service be active duty time.

        * Either of the following --

        ** 60% minimum "qualifying" service-connected disability, or,

        ** Purple Heart recipient with at least 10% disability associated with the Purple Heart.

 

    c.  The maximum amount payable is the amount of retirement pay waived.  One may receive either SCSC or CRSC, but not both.  Unless otherwise indicated by the recipient, DFAS will pay the greater amount.

 

    d.  As with SCSC, there is no mention of the reserve component.

 

    e.  DoD 7200 point policy contained in DoD Guidance for CRSC, Note 3, which states "A retired Reservist with retired pay computed under the provisions of chapter 1223 (formerly chapter 67), title 10, USC, must have 20 or more years of services as defined by 10 USC 12733.  Thus, to be eligible for CRSC, such retirees must have 7,200 or more total points under clauses (1), (2), (3), and (4) of 10 USC 12733." (underlining added for emphasis)

 

Comment:  For clarification --

    Clause 1 credits 1 point/day of active duty (extended active duty)

    Clause 2 credits 1 point/day of active duty for training (drill status)

    Clause 3 credits membership, drill and similar points capped at 60-75-90 points/year depending upon when earned

    Clause 4 credits 1 point/funeral detail

 

4.  DISCUSSION --

 

    a. The crux of this issue lies with the intended definition of "20 years of service in the uniformed services that are creditable for purposes of computing the amount of retired pay to which the member is entitled" as expressed in both Sections 1413 and 1413a.

 

    b. For one having 20 years of active duty, a creditable year is simply 365/366 days.  One must have 20 "creditable" years for retirement.  The percentage of the pay amount to be used for retirement pay is simply 2.5% multiplied by the number of years and fractions thereof.  Thus, 21.5 years provides a multiplier of 53.75%.

 

    c. For a reservist the same philosophy applies:  One must have 20 "creditable" years for retirement, but reserve years are "qualified" for retirement based on the accrual of a minimum of 50 points (effectively 50 days of duty) for each year credited for retirement.  Per Section 12733, the sum of qualified points is divided by 360 to determine the number of equivalent years to be used for the computation of the pay multiplier.  These equivalent years have no other purpose.  Per Section 12739, the number of years determined under 12733 is multiplied by 2.5% to obtain the percentage of pay to be paid for retirement.  Thus, 3119 points number of points earned by 15976 Guard Reserve retirees with disability (see enclosed table) provides 8.66 equivalent years multiplied by 2.5% provides a multiplier of 21.66%.

 

    d.  The question remains:  Is a "qualified" reserve retirement year any different from a "creditable" year under Sections 1413 and 1413a?  Consider a service retirement requires 20 years of active duty and a reserve retirement requires 20 qualified reserve years.  There are no differences in retirement benefits whether they be access to medical care, commissary, post exchange, or other benefits and services.  The retired ID card makes no reference to the component from which retired.  Like a service retiree, a reserve retiree is retired with 20 years of creditable service, is in receipt of retired pay, and has a service connected disability.  So, what does the number of retirement points have to do with the qualification of that reserve retiree for SCSD or CRSC?  Absolutely nothing.  100% disability is 100 percent disability without regard to basis of retirement or number of points earned.

 

    e.  The enclosed table represents a breakout of raw data provided by DFAS, on 2 July 2003, to Charles Revie under the Freedom of Information Act.  These numbers reflect the Guard and Reserve Retirees authorized retirement pay and who have waived retirement pay to receive VA service connected disability information.  The impact of the 7200 point policy is readily apparent.

 

        * Of the 15976 retirees involved, a mere 154 (0.99%) meet both the 7200 point policy and 60% disability (law) criteria and are qualified to receive SCSD.  Based on another FOIA request, only 100 (0.64%) of this number are actually receiving SCSD.  On the other hand, 29,706 (33.6%) of 88, 481 service retirees with disability from active duty are drawing SCSD.

 

        * Removal of the 7200 point threshold would extend eligibility to a total of 2929 (18.33%) of these retirees who meet the 60% disability threshold.  This percentage is consistent with 14% of the total number of military retirees with at least 60% disability.

 

        * The difficulty of attaining 7200 points is reflected by the mean value of 3991 points which leaves 9394 (58.8%) retirees BELOW the average mark.  It is also reflected by the median (50%) value of 3607.  The difficulty of attaining the 7200 point threshold is further indicated by there being only 478 (2.99%) retirees who meet the criteria.

 

        * The average disability rating of 32% for Guard Reserve retirees with disability is consistent with the average disability rating of 29% for the 495,000 military retirees with disability.

 

5.  CONCLUSIONS --

 

    a.  Because of the DoD 7200 point policy, neither SCSD nor CRSC will provide substantive benefit to Guard Reserve retirees with otherwise qualifying disabilities.  Less than 1% (154) will receive benefit from this legislation.

 

    b.  The quantitative effect of the DoD 7200 point policy upon Purple Heart recipients can not be established from this data, but the potential benefits will be limited to less than 3% (478) of the Guard Reserve retirees who might benefit from this legislation.

 

    c.  The DoD 7200 point policy has no basis in the US Code.  It is derived based on faulty logic.

    d.  The DoD 7200 point policy obviously discriminates against Guard Reserve retirees as a class compared to the active component.  This is a violation of 10 USC Section 10209, "Regular and Reserve components: discrimination prohibited" which simply provides that "Laws applying to both Regulars and Reserves shall be administered without discrimination (1) among Regulars; (2) among Reserves; and (3) between Regulars and Reserves."

Prepared by:  Charles D. Revie, LTC, USAR, Retired, 100% Service Connected Disability, 6818 points, 28 years of service.  Address 720 Sundown Court, Las Cruces, NM 88011, telephone 505-522-3317

                                                  * * * *

Guard and Reserve Retirees with Disability (source DFAS-CL, 2 July 2003)

 

Number of Retirees     15976

Disability Mean           32.1113

Points Mode             2916     (most frequently occurring value)

Points Median           3607     (mid point of distribution)

Points Mean             3991.1858

Points Stnd Deviation   1478.0737

Points Maximum          10800     (40% disability)

Points Minimum          1228      (10% disability)

Skewness (mode)            0.7020

Skewness (median)          0.6545

 

Points  Cnt|  10%   20%   30%   40%   50% |  60%   70%   80%   90%  100%

 

 1200   841|  398   141    87    56    29 |   31     8     3     1    87

 2200  5335| 2604   810   562   355   193 |  171    58    29    29   524

 3200  3866| 1708   648   399   293   154 |  155    62    31    29   387

 4200  2443|  961   398   282   221   116 |  105    34    29    19   278

 5200  1799|  607   276   220   198    96 |   99    35    21    24   223

 6200  1214|  345   172   169   144    81 |   83    38    19    18   145

            ------------------------------------------------------------

 7200   400|   78    55    58    52    31 |   26    20    16     7    57

 8200    75|   14    11    13     9     2 |    7     4     5     2     8

 9200     2|    0     0     0     0     0 |    0     0     1     0     1

10200     1|    0     0     0     1     0 |    0     0     0     0     0

 

      ---Points-- -----Count----- | --Disab 10 50-- | --Disab 60-100--

       min - 7199 15498 ( 97.01%) | 12723 ( 79.64%) |  2775 ( 17.37%)

      7200 - max    478 (  2.99%) |   324 (  2.03%) |   154 (  0.96%)

          totals  15976 (100.00%) | 13047 ( 81.67%) |  2929 ( 18.33%)