Research Full Report Developing Future Public Health Leaders Trained in Long-term Care Administration N. Ruth Gaskins Little, EdD, MPH; Polly Welsh, MPH, RN-BC; Adam Sholar, JD ABSTRACT Background: America’s population is rapidly aging. Long-term care leaders have not been considered part of the public health workforce. The enumeration of long-term care into the public health workforce taxonomy has not occurred. This article examines the extent of graduate public health education oriented to long-term care and provides a case study of a successful curriculum at East Carolina University (ECU). Method: Web sites displaying the curriculum of 135 graduate programs/schools accredited by the Council on Education for Public Health (CEPH) were analyzed for graduate long-term care orientation. A case-study approach was used to de- scribe the integration of long-term care into the Master of Public Health (MPH) Health Policy Administration & Leadership concentration at ECU. Results: A review of 135 CEPH graduate MPH programs from January to July 2019 found that only 8 institutions offered graduate courses in long-term care administration. Of the 8, ECU Brody School of Medicine Department of Public Health was the only program directly linking coursework to licensure as a long-term care administrator. Program graduates total 30, which include 5 MPH students currently completing their Administrator in Training. At time of graduation, 17 students had obtained North Carolina licensure. Conclusions: Because of increases in population aging, this requires a public health workforce with skills and training in the care of older adults. Formal recognition of long-term care workers as an integral part of the public health workforce is needed. The Institute of Medicine called for this action more than a decade ago. KEY WORDS: education, leadership, long-term care, public health workforce The public health system is defined as “all affect the distribution of health for populations andpublic, private and voluntary entities that advocates for policy changes to improve access tocontribute to the delivery of essential public health care.2 One of the greatest public health policy health services within any jurisdiction.”1 Improving achievements in the 20th century in the United States the health of communities by reducing health dispar- was the passage of Title 19 to the Social Security ities prevalent in underserved lower socioeconomic Act enacting the Medicaid program in 1965.3 A groups is an important focus of public health. Public Kaiser (2017) report finds that 1 in 3 Americans health recognizes how social determinants of health will need nursing home care at some point in his or her lives, with Medicaid paying for the care of 6 of Author Affiliations: Department of Public Health, Brody School of Medicine, every 10 patients.4 Nursing homes are considered an East Carolina University, Greenville, North Carolina (Dr Little); and North integral part of the public health system.5,6 Although Carolina Health Care Facilities Association, Raleigh, North Carolina (Ms Welsh and Dr Sholar). two-thirds of nursing home facilities in the United This work was supported by funding from The Duke Endowment. The States are for-profit, these private sector providers authors gratefully acknowledge Dr Lloyd Novick, founding chair of the are also considered a component of the public health Department of Public Health at Brody School of Medicine; Eastern Area system.1,7 Health Education Center; and Mr Craig Souza, former president of the North Carolina Health Care Facilities Association. Ensuring the health of communities is a vital role The authors declare no conflicts of interest. of the public health workforce.8 Yet, more than two- This is an open access article distributed under the Creative Commons thirds of this workforce in the United States lacks for- Attribution License 4.0 (CCBY), which permits unrestricted use, distribution, mal education/training in public health. Of the one- and reproduction in any medium, provided the original work is properly cited. third with formal public health training, many report Correspondence: N. Ruth Gaskins Little, EdD, MPH, Department of Public 9 Health, Brody School of Medicine, East Carolina University, 115 Heart Dr, the need for management training. Greenville, NC 27834 (littlena@ecu.edu). The current COVID-19 pandemic and its effect on Copyright © 2020 The Authors. Published by Wolters Kluwer Health, Inc. elderly persons, particularly those residing in skilled DOI: 10.1097/PHH.0000000000001188 nursing facilities, imperil a subset of one of our most March/April 2021 • Volume 27, Number 2 www.JPHMP.com E79 E80 Little, et al • 27(2), E79–E86 Future Public Health Leaders in Long-term Care Administration fragile populations.10 Consequently, the Centers for 287 classifications across 12 domains (axes) providing Disease Control and Prevention (CDC) has pro- definitive job classifications including occupational vided explicit policy guidance to nursing homes that setting and employment. Under Axis 2: Local Setting, requires the immediate classification andmanagement hospitals are listed as a local public health setting but of sick patients while also stressing the imperative long-term care facilities were not included.17 Yet, nurs- for prevention education.11 A strong leadership re- ing homes in 2019 constituted twice the number of sponse from nursing home administrators is critical health care facilities as hospitals. There are more than for managing situations of this global magnitude. 15 600 nursing homes in the United States compris- Inclusion of long-term care as a vital element of ing 1.7 million licensed beds caring for more than the US public health workforce is the basis for the 1.3 million residents.7 This compared with 6 210 hos- program described in this article. The nationwide pitals totaling 931 203 staffed beds with 36 510 207 deficit in public health training for long-term care admissions.18 workers parallels or exceeds those in other areas of The Public Health and Welfare United States public health. This article presents a successful model Code, Title 42, 42 USC §1396g, requires federal for training licensed long-term care administrators licensure for nursing home administrators.15 Axis 1: who are also Master of Public Health (MPH) gradu- Management and Leadership does list public health ates trained in prevention, data management, health manager as an occupation, but long-term care or policy, administration, and leadership. nursing home administration is not listed in Axis 9 as an area of expertise or under 1.1.12 Licensure/ Background Regulation/Enforcement worker. Axis 1: Manage- ment and Leadership (1.11-1.1.6) is the only oc- Individuals 65 years and older will constitute 20% of cupational reference that aligns with traditional the total US population by 2030. By 2035, it is pro- federal/state public health positions.17 The Institute jected that there will be 78 million people 65 years of Medicine (IOM) in 2008 pointed out an urgent and older compared with 76.7 million of those who need to improve training and competency of the are younger than 18 years.12 This means that for the eldercare workforce, with a specific challenge to first time in the history of the United States, people public health to enhance the skills of any health care 65 years and older will constitute a greater percent- worker/practitioner involved in providing care to age of the total US population than those 18 years elderly persons.19 Despite 42 USC §1396g15 being and younger. The unprecedented growth in our se- contained under the US Public Health code, leaders nior population will increase demand for services not of long-term care facilities are disadvantaged by the only from hospitals but also from our skilled nurs- lack of enumeration of their employees in the public ing homes and residential long-term care facilities.13 health workforce. The purpose of this article is to In 2016, hospital, nursing home facilities, and home describe a successful collaboration between academic health care comprised 47.2% of total health care practice and long-term care industry leaders to for- expenditures. Skilled long-term care facilities, also mally integrate graduate public health education with known as “nursing homes,” are primarily for-profit long-term care administration, leading to graduates (69.3%) providing care for more than 1.3 million res- attaining licensure as long-term care administrators. idents in 2015.7,14 The East Carolina University (ECU) program serves Nursing home administrators are the designated as a model for other institutions. leaders of their facilities and are required to hold a fed- eral license.15 Many states also require a state license, Methods but not all. Variation exists in the minimum eligibility age for licensure as well as educational degree, length, A list of accredited graduate programs in public health and duration of Administrator in Training (AIT), as was obtained from the Council on Education for Pub- well as the number of hours required for licensure and lic Health (CEPH).20 Each MPH program’s curricu- continuing education requirements. Of note is the fact lum was reviewed for any graduate courses oriented that 19 states require either no education beyond high to long-term care by reviewing institutional Web sites school or GED in order to be eligible to apply to be- (and graduate catalogues if available) for degree and come a nursing home administrator.16 See Table 1. course information. A database was created in Excel The classification and enumeration of the public by the authors containing the name of the institution, health workforce have been difficult to quantify.17 The degree, course number, and title of courses oriented to University of Michigan Center of Excellence in Public long-term care. The purpose of creating the database Health Workforce Studies convened national experts was to determine the prevalence of graduate-level in 2013 to define the public health workforce by coursework in long-term care administration in March/April 2021 • Volume 27, Number 2 www.JPHMP.com E81 TABLE 1 Nursing Home Administrators Licensure Requirements Summarya Licensure Requirements Education AIT Training Examination Minimum Min/Max Board-Approved CE Hours State Age Degree Hours Period Preceptor National State Required Alabama 19 AA 200/2000 Yes Yes Yes 24/Annually Alaska 19 BA Yes No 0/0 Arizona BA 1000 No Yes Yes 50/Biennially Arkansas 21 AA Yes Yes 20/Annually California NHA 18 BA 1000 Yes Yes Yes 40/Biennially Colorado 21 AA 500/1000 Yes Yes Yes 0 Connecticut 0 Yes 0 Delaware 18 Other 100 Yes Yes No 48/Biennially District of 18 BA 1000 Yes Yes Yes 40/Biennially Columbia Florida 18 BA 1000/2000 Yes Yes Yes 40/Biennially Georgia Hawaii 21 BA 30 2080/0 Yes Yes No 0/Biennially Idaho NHA 21 BA 384/384 Yes Yes Yes 20/Annually Illinois 0 1/1 /1 Yes Yes Yes /0 Indiana Other 280 728/1040 Yes Yes Yes 40/Biennially Iowa BA 12 720 No Yes No 40/Biennially Kansas 18 BA 480 Yes Yes Yes 50/Biennially Kentucky 21 BA 1080 No Yes No 30/Biennially Louisiana 21 BA 1040 Yes Yes Yes 15/Annually Maine 0 0 Maryland 21 BA 100/100 2080/2080 Yes Yes Yes 40/Biennially Massachusetts 18 BA 520/1040 Yes Yes No 40/Biennially Michigan 18 Other 0/0 0/0 Yes Yes 36/Biennially Minnesota 21 BA 0/36 0/400 No Yes No 20/Annually Mississippi 21 Other 0/0 1040 Yes Yes Yes 40/Biennially Missouri 21 Other 500/2000 Yes Yes Yes 40/Biennially Montana 18 Other Yes Yes 25/Annually Nebraska 19 AA 640 Yes Yes No 50/Biennially Nevada 21 BA 1000 Yes Yes No 30/Biennially New Hampshire 21 BA 15 No Yes Yes 40/Biennially New Jersey 18 BA 100/100 1750/1750 Yes Yes No 60/0 New Mexico BA No Yes Yes 24/Annually New York 21 BA 15 445/2080 Yes Yes No 48/Biennially North Carolina 18 Other 0/0 480/2000 Yes Yes Yes 30/Biennially North Dakota 18 BA 0 480 Yes Yes Yes 20/Annually Ohio 18 BA 1500/1500 Yes Yes Yes 20/Annually Oklahoma 21 BA 560/560 Yes Yes Yes 24/Annually Oregon BA 960 No Yes Yes 20/Annually Pennsylvania 21 Other 800/1000 No Yes Yes 48/Biennially Rhode Island 18 BA 15 350 Yes No 40/Biennially South Carolina 21 BA 0/0 0/0 Yes Yes Yes 20/Annually South Dakota 18 BA 240 Yes Yes 40/Biennially (continues) E82 Little, et al • 27(2), E79–E86 Future Public Health Leaders in Long-term Care Administration TABLE 1 Nursing Home Administrators Licensure Requirements Summarya (Continued) Licensure Requirements Education AIT Training Examination Minimum Min/Max Board-Approved CE Hours State Age Degree Hours Period Preceptor National State Required Tennessee 18 AA 400 Yes Yes Yes 18/Annually Texas BA 15 1000 Yes Yes Yes 40/Biennially Utah 0 1000 No Yes No 40/Biennially Vermont 18 BA 0/0 1000 Yes Yes Yes 40/Biennially Virginia BA 320/2000 Yes Yes No 20/Annually Washington BA 1500 Yes Yes No 36/Biennially West Virginia 21 BA 12 2040 Yes Yes Yes 20/Annually Wisconsin 0 0 Wyoming BA No Yes No 25/Annually Abbreviations: AA, Associate of Arts; BA, Bachelor of Arts; NHA, nursing home administrator. aFrom National Association of Long Term Care Administrator Boards (https:// www.nabweb.org/ state-licensure-requirements). CEPH-accredited MPH programs. Institutional Web Administration (MHA) program. The University of sites and content were reviewed to determine whether North Florida offers 2 graduate courses in the Brooks any narrative language existed at the program or College of Health as part of the MHA degree. The course level that described the integration of graduate University of Alabama at Birmingham has a graduate MPH coursework as leading to federal/state licensure course in long-term care as part of its Master of Sci- as a nursing home administrator. ence in Health Administration (MSHA) degree; the A case-study approach was used to describe the University of Minnesota has a long-term care course program concentration at the ECU MPH program. as part of a postbaccalaureate certificate in its school The faculty and advisors to the program were inter- of public health. Of the 8 institutions, ECU Brody viewed including input from long-term care industry School of Medicine Department of Public Health was executives, members of the North Carolina state li- the only program that had coursework directly linked censing board, licensed administrators, and the direc- to licensure. See Table 2. tor of the Eastern Area Education Center. Meeting notes, e-mails, AIT information, as well as follow-up interviews were conducted of students participating in Case Study: Development of a Focus on Long-term this concentration. Care Administration at ECU MPH Program The integration of long-term care administration into Results the MPH degree was accomplished by the successful collaboration between research and practice. This A review of CEPH MPH graduate programs and initiative was led by the Director of Field Placement schools of public health from January to July 2019 for the MPH program, who had previous experience found that only 8 institutions had graduate courses in both as a licensed long-term care administrator and long-term care administration. Two of the 8 institu- a local public health director, who with department tions, the University at Albany-SUNY and New York chair support convened health care leaders in prac- Medical College, each offered 2 courses in long-term tice and in academia including the president and care. Oregon State University School of Public Health vice president of the North Carolina Health Care offered 1 graduate MPH course in long-term care. Facilities Association, the president of the North ECU Department of Public Health at Brody School of Carolina Hospital Association, long-term care indus- Medicine offers 3 courses oriented as part of the focus try executives, the executive director of the North on long-term care in theMPHHealth Policy Adminis- Carolina Board of Examiners for Nursing Home tration&Leadership (HPAL) concentration.The Uni- Administrators, a representative from the North versity of Nevada, Las Vegas, offers 1 long-term care Carolina Department of Regulatory Services Admin- course in its School of Public HealthMaster of Health istration, licensed administrators, and the director March/April 2021 • Volume 27, Number 2 www.JPHMP.com E83 TABLE 2 Graduate Courses by CEPH-Accredited Institution Institution Course Title Course Number Location Part of MPH Lead to Licensure? UAB Long Term Care HA643 School of Health No No Administration Professions University of North Long Term Care HSA 6225 Brooks College of No, MHA No Florida Administration Health University of North Long Term Care HAS 6945 Brooks College of No, MHA No Florida Internship Health University of Long Term Care PUBH 8803 School of Public No, postbaccalaureate No Minnesotaa Principles, Health certificate Programs & Policies University of Organization & HCA 680 School of Public MHA No language stating Nevada, Las Management of Health leading to licensure Vegas Long- Term Care Services University at Managing Long Term HPM 528 School of Public Yes, MPH in Health No language regarding Albany-SUNY Care Services Health Policy, Management administrator & Behavior licensure University of Long Term Care HPM 643 School of Public Yes, MPH in Health No language stating Albany-SUNY Administration Health Policy & leading to licensure Management New York Medical Managing Long Term HPMM 6061 School of Health Yes, MPH in Health No language stating College Care Facilities Sciences & Policy & leading to licensure Practice & Institute Management of Public Health New York Medical Long-Term Care HPMM 6029 School of Health Yes, MPH in Health No language stating College Delivery Systems Sciences & Policy & leading to licensure Practice & Institute Management of Public Health East Carolina Long Term Care MPH 6040 Brody School of Yes, MPH HPAL Yes University Administration Medicine concentration East Carolina Field Practicum MPH 6903, Brody School of Yes, MPH HPAL Yes, students focusing in University 6904/6905 Medicine concentration long-term care administration take an additional field practicum course due to length of AIT counting as an elective Oregon Financing & H568 College of Public Yes, MPH Health No language regarding Administration of Health & Human Management & licensure, course Long-Term Care Sciences Policy offered as elective Facilities Abbreviations: AIT, Administrator in Training; CEPH, Council on Education for Public Health; HPAL, Health Policy Administration & Leadership; MHA, Master of Health Admin- istration; MPH, Master of Public Health. aPostbaccalaureate certificate only. of the Eastern Area Education Center. This work Program Requirements group, in partnership with ECU faculty, helped design the curriculum that was ultimately added as a focus TheMPHHPAL concentration consists of 45 hours of within the HPAL concentration in the MPH program coursework including 24 credit hours of core classes at ECU’s Brody School of Medicine. A new course in encompassing public health foundational course- Long Term Care Administration was developed with work.The long-term care focus requires 9 credit hours input from the work group for developing the course of focus courses, 6 credit hours of electives, a 3-credit 21 objectives. Work group members frequently provide internship, and a 3-credit professional paper. An in- guest lectures on their areas of expertise. dividual seeking to become a licensed nursing home E84 Little, et al • 27(2), E79–E86 Future Public Health Leaders in Long-term Care Administration administrator in North Carolina must complete an and 1 from India. Five students are currently complet- AIT requirement prescribed by the North Carolina ing their AIT in the second year of their MPH degree; Board of Examiners for Nursing Home Administra- all 5 are female, with 1 Hispanic, 1 African Ameri- tors based on education and experience.22 Because of can, 1 from India, and 2 White. Four MPH licensed the length of the AIT,MPH students seeking licensure administrator alumni have completed additional fulfill a rigorous field placement to prepare them for training to become certified preceptors in the concen- state and federal licensure and may take a second in- tration and are precepting current MPH students. See ternship course as an elective. Students typically sit Table 3. for their state and national examinations near their graduation. Continuing Education of the Long-term Care Workforce Program Funding for Sustainability The assembled work group identified another com- In 2018, the successful partnership to integrate long- pelling need: to develop and implement a training con- term care administration into the MPH program re- tinuum for the current long-term care workforce tar- sulted in the establishment of the J. Craig Souza En- geted to individuals with associate degrees in nursing dowed Public Health Scholarship at Brody School of so they could obtain their BSN degrees online through Medicine. The scholarship supports MPH students the ECU College of Nursing. They also recommended who choose to train to become licensed administra- that individuals with non-nursing associate degrees tors by providing financial support during their AIT employed in the long-term care workforce could first licensure requirement and field placement courses. obtain their bachelor’s degree in Health Services Infor- Scholarship funding was derived from donations by mation Management online at ECU and then proceed long-term care industry leaders including Mr Souza. to enroll in the MPH program. This work group also articulated the need for en- Program Achievements suring that the future long-term care workforce had training and expertise in public health. This initiative There are now 25 alumni of the long-term care focus led to successful funding from the Duke Endowment, within the MPH program. An additional 5 students demonstrating the strength of partnerships and phil- are completing their AIT, with expected graduation anthropic commitment for preparing current and May 2020. Twenty-one are female and 9 are male stu- future long-term care administrators with graduate dents. Three alumni were long-term care profession- education in public health. The objective of the Duke als, 2 licensed administrators, and 1 an industry exec- Endowment Long-Term Care Training Continuum utive before completing theirMPH degrees. Seventeen proposal was to develop an educational multistep were licensed in North Carolina while completing program responsive to the needs and challenges of their MPH degree (10 females and 7 males). Of those those seeking training in long-term care administra- licensed administrators with an MPH degree, 6 are tion at ECU. Grant funding supported individuals African American, 2 are Native American, 8 white, with associate degrees working in long-term care to TABLE 3 MPH HPAL Student Demographic and Licensure/Preceptor Data Long-term Care MPH But MPH LNHA Professional Current MPH Students Licensed While Not Also Variables Total, Na Completing MPH Seeking Licensure Enrolled in MPH Licensed Preceptors Female 21 2 5 10 4 1 Male 9 1 0 7 1 3 Black 9 0 1 6 1 1 Hispanic 1 0 1 0 0 0 White 15 3 2 8 3 3 Native American 2 0 0 2 0 0 Other 3 0 1 1 1 0 Total, N 30 3 5 17 5 4 Abbreviations: AIT, Administrator in Training; LNHA, Licensed Nursing Home Administrator; MPH, Master of Public Health. aIncludes 5 AITs currently completing their AIT. March/April 2021 • Volume 27, Number 2 www.JPHMP.com E85 obtain their baccalaureate degree in either nursing Implications for Policy & Practice or health services management and subsequently their MPH degree. Continuing education required ? Study findings indicate a need to increase the health care for licensure maintenance is provided by Area Health workforce equipped with public health prevention skills to Education Centers. care for our elderly population that utilizes long-term care services.30 Discussion ? Formal recognition of long-term care as an integral part of While some health care leaders hold an MHA the public health workforce is critically needed to ensure that degree,23 distinct differences exist between the MHA long-term care leaders are trained in public health with the and MPH curricula. The MHA curricula is more fi- skills and competencies to facilitate interprofessional health nancial/business management focused and often lacks care delivery as demanded by our health care system design. curricula attention to public organizations inherent in public health coursework and practice.24,25 The MPH in HPAL includes foundational public health understand the importance of prevention and are coursework content in biostatistics, epidemiology, en- equipped with skills to not only deter outbreaks but vironmental health, health policy administration and also reduce the spread of exposure by effective man- leadership, health behavior, research methods/data agement and enactment of isolation and quarantine management, disaster preparedness in addition to measures when needed. Nursing home administrators concentration coursework in financial management, with an MPH degree are equipped to navigate the health administration/leadership, and health policy totality of the health care system. They understand focusing on reducing health disparities by improving the role and function of the many agencies under the population health understanding of the importance public health umbrella and have been trained to be of social determinants of health.21 In fact, the accred- effective communicators and managers to respond iting body for public health, the CEPH, has specific appropriately and effectively to pandemics as we MPH competencies that must be obtained before are now experiencing worldwide. In addition, the degree conferral that includes planning, management, long-term care focus is fulfilling the IOM’s 2008 and leadership competencies.26 mandate to train more of the eldercare workforce The Council on Linkages Between Academia and in public health.19 With this expansion has come the Public Health Practice has identified core competen- availability of more preceptors with MPH degrees to cies for public health professionals with MPH de- train future administrators grounded in public health grees by tier levels (1-3), with tier 3 competency at- principles, equipped and able to respond to future tainment the expectation for leaders of health care forms of public health disasters. organizations.27 Nursing home administrators are the Women have lower odds of achieving executive- designated leaders of their facilities as required by level leadership positions despite constituting a ma- licensure.15 The CDC’s COVID-19 directives for nurs- jority of the public health workforce.28 The long-term ing homes require systems management and monitor- care focus within the HPAL program is increasing ing for early detection and management of diseased the number of women and minorities in public health patients, surge capacity planning, human resources leadership positions. Recognizing the concern arising staffing, and fiscal evaluation and compliance.11 Su- from the lack of connectivity between educational de- perlative leadership skills are required of nursing grees and workforce skills29 and also student loan home administrators who must coordinate with mul- debt, it is important to note that 16 of the 17 licensed tiple local, state, and federal agencies, as well as the administrators received and accepted offers for em- onslaught of media and family inquiries during this ployment as long-term care administrators by the time pandemic. Yet, current educational requirements for of their MPH graduation. licensure of nursing home administrators do not re- quire these skills. Conclusion The long-term care focus in the HPAL concentra- tion is critically important for the ongoing vitality of The COVID-19 pandemic brings heightened aware- the health care workforce and to ensure the health ness to the demands upon the health care work- of the US population. The program has increased force exacerbated by America’s rapidly aging popu- the number of long-term care administrators with lation. We have entered a new arena that requires a public health education. Administrators with an public health workforce leaders to have the skills and MPH degree can apply their leadership, policy, and abilities to respond to not only social and environ- management skills through a public health lens. They mental problems but also microbial, biological, and E86 Little, et al • 27(2), E79–E86 Future Public Health Leaders in Long-term Care Administration physiological diseases. The partnership between www.census.gov/newsroom/press-releases/2018/cb18-41- academia and the leadership of the long-term care in- population-projections.html. Published 2018. Accessed September dustry in North Carolina resulted in the integration 15, 2019.13. American Health Care Association. LTC patient projections. AHCA of a focus on long-term care administration into the SNF state patient volume projections June 2016. https://www. HPAL concentration for the MPH degree at ECU. Im- ahcancal.org/research_data/Pages/LTC-Patient-Projections.aspx. portantly, this degree leads to state and federal licen- Published 2016. Accessed September 23, 2019.14. Centers for Disease Control and Prevention. Health United sure as a nursing home administrator and serves as a States 2017. https://www.cdc.gov/nchs/data/hus/hus17.pdf. Pub- model for adoption by other graduate public health lished 2017. Accessed September 15, 2019. programs. 15. 42 USC §1396g. State programs for licensing of administrators ofnursing homes. United States; 1972. https://uscode.house.gov/ view.xhtml?req=granuleid:USC-prelim-title42-section1396g& num=0&edition=prelim. Accessed March 23, 2020. 16. National Association of Long Term Care Administrator Boards. 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