Florida 2025 2025 Regular Session

Florida House Bill H0633 Analysis / Analysis

Filed 03/19/2025

                    STORAGE NAME: h0633a.HSS 
DATE: 3/19/2025 
 	1 
      
FLORIDA HOUSE OF REPRESENTATIVES 
BILL ANALYSIS 
This bill analysis was prepared by nonpartisan committee staff and does not constitute an official statement of legislative intent. 
BILL #: CS/HB 633 
TITLE: Behavioral Health Managing Entities 
SPONSOR(S): Koster 
COMPANION BILL: SB 1354 (Trumbull) 
LINKED BILLS: None 
RELATED BILLS: SB 1354 (Trumbull) 
Committee References 
 Human Services 
17 Y, 0 N, As CS 

Health Care Budget 
 

Health & Human Services 
 
 
SUMMARY 
 
Effect of the Bill: 
Behavioral health managing entities (MEs) are contracted by the Department of Children and Families (DCF) to 
provide safety-net mental health and substance use disorder services for individuals who are uninsured or 
underinsured.  In FY 2022-23, the safety-net behavioral health system served 243,403 individuals with $1.083 
billion in funding allocated to managing entities.    
 
HB 633 requires MEs to submit data and information to DCF in a specific electronic format to ensure 
interoperability and allow for analysis.  DCF must conduct operational and financial audits addressing specific 
topics for each ME contract, and prepare and submit a report of findings to the Governor and Legislature by 
December 1, 2025. HB 633 also specifies performance measures for client outcomes that MEs must track and 
submit to DCF. 
 
Fiscal or Economic Impact: 
The bill will have a significant, negative, recurring and non-recurring fiscal impact on the Department of Children 
and Families.  
 
  
JUMP TO SUMMARY 	ANALYSIS RELEVANT INFORMATION BILL HISTORY 
 
ANALYSIS 
EFFECT OF THE BILL: 
Behavioral health managing entities (MEs) are contracted by the Department of Children and Families (DCF) to 
plan, subcontract for, and coordinate safety-net mental health and substance use disorder services for individuals 
who are uninsured or underinsured.  There are seven (7) managing entities, which together serve the entire state. 
MEs subcontract with community providers, which serve clients directly. 
 
ME Submission of Data and Information to DCF 
 
MEs provide data and information to facilitate DCF oversight of ME services.  By contract, MEs currently must 
submit this data and information electronically to DCF.  HB 633 additionally specifies electronic reporting formats 
and processes for this data and information to ensure interoperability and analysis, as follows:  
 
 For information: 
o Use of a standardized format for electronic data interchange that is used for health care claims 
processing. 
o Information organized into discrete, machine-readable data elements that allow for efficient 
processing and integration with other datasets. 
o Data fields compliant with department-established protocols. 
o Compatibility with automated systems to enable the downloading, parsing, and combining of data 
with other sources for analysis.  JUMP TO SUMMARY 	ANALYSIS RELEVANT INFORMATION BILL HISTORY 
 	2 
o Required validation checks to confirm adherence to the required data structure and format before 
acceptance. 
 For data: 
o A format that allows for accurate text recognition and data extraction, as specified by DCF, which 
may include, Portable Document Format or machine-readable text files. 
o Accompanying metadata containing key information, such as a descriptive and unique name for 
the document, the date the document is uploaded, a predefined classification indicating the nature 
or category of the document; any relevant identifiers, such as application numbers, case numbers, 
or tracking codes, as specified by DCF; and the name, contact information, and any other required 
identification number, such as a contract, license or registration number of the person or 
organization submitting the document. (Section 1) 
 
The bill does not specify any actions that DCF is to take using the data and information in this new electronic 
format.  
 
DCF-Contracted Audits of MEs 
 
HB 633 requires DCF to contract biennially for operational and financial audits of each of the seven MEs, including:  
 
 Business practices, personnel, financial records, related parties, compensation, and other areas as 
determined by DCF. 
 Services administered, the method of provider payment, expenditures, outcomes, and other 
information as determined by DCF. 
 Referral patterns, including referral volume, referral assignments, services referred,  length of time 
to obtain services, and key referral performance measures. 
 Adequacy and participation in DCF’s available bed platform, the Opioid Data  Management System, 
and other DCF-required provider data submissions. 
 Expenditures and claims, at a minimum, comparing services administered, outcomes, and Medicaid 
expenditures for behavioral health services for each ME and analyzing services funded by MEs 
rendered to individuals who are Medicaid beneficiaries to, at a minimum, assess the extent to which 
MEs are funding services that are also available as covered services under the Medicaid program.  
 
DCF must prepare and submit a report on the findings to the Governor, President of the Senate, and Speaker of the 
House of Representatives by December 1, 2025. (Section 1) 
 
Required ME Performance Measures 
 
HB 633 requires MEs to submit specific performance measures to DCF regarding individual outcomes and system 
functioning. None are current performance measures, though similar measures to those in the bill on access 
timeframes are in new ME contracts that begin July 1, 2025, and some others in the bill are tracked and reported to 
DCF, though not as performance measures.
1  
 
HB 633 requires the measures to include data from individuals served by the ME, for only services funded by the 
ME, to the extent feasible and appropriate. The performance measures must be reported and posted stratified by, 
at a minimum, whether the individual is a child or an adult and whether the individual is a Medicaid recipient. Such 
measures must include, at a minimum, all of the following: 
 
 The number and percentage of high utilizers of crisis behavioral health services. 
 The number and percentage of individuals referred to outpatient behavioral health services after 
discharge from mental receiving or treatment facilities or emergency departments or inpatient or 
residential licensed service components who begin receiving services within 7 days after discharge. 
 The average wait time for initial appointments for behavioral health services, by type of service. 
                                                            
1
 DCF, Agency Analysis of HB 633, p. 6 (March 7, 2025), on file with the House Health Services Subcommittee.  JUMP TO SUMMARY 	ANALYSIS RELEVANT INFORMATION BILL HISTORY 
 	3 
 The number and percentage of individuals with significant behavioral health symptoms seeking 
urgent but non-crisis acute care who are scheduled to be seen within one business day of initial 
contact with a provider. 
 The number and percentage of emergency department visits per capita for behavioral health-related 
issues. 
 The incidence of medication errors. 
 The number and percentage of adverse incidents, including but not limited to, self-harm, occurring 
during inpatient and outpatient behavioral health services. 
 The number and percentage of individuals with co-occurring conditions who receive  integrated 
care. 
 The number and percentage of individuals discharged from receiving or treatment facilities or 
inpatient or residential licensed service components who successfully transition to ongoing services 
at the appropriate level of care. 
 The rate of readmissions to emergency departments due to behavioral health issues or to crisis 
stabilization units, addictions receiving facilities, or other inpatient levels of care within 30 days 
after discharge from inpatient or outpatient behavioral health services. 
 The average length of stay for inpatient behavioral health services.  
 
The bill requires MEs to report each measure using a standard methodology as determined by DCF. The bill also 
requires DCF to establish a deadline for MEs to submit the required data and to post the performance measures on 
the agency’s website by the 15
th of each month. The measures must reflect performance for the previous calendar 
month. (Section 1) 
  
DCF will need to amend the ME contracts and procure a vendor to assist with a redesign of its business processes.  
DCF estimates that the estimated time to complete all these activities is 18 to 24 months.
2  
 
The bill provides an effective date of July, 1, 2025. (Section 2) 
 
RULEMAKING:  
The bill will require DCF to revise certain administrative rules in Chapter 65E-14, F.A.C., the Office of Substance 
Abuse and Mental Health Financial Rule.  DCF will need to update over 20 administrative rules in total.
3 The 
department has sufficient rulemaking authority to implement the bill. 
 
Lawmaking is a legislative power; however, the Legislature may delegate a portion of such power to executive 
branch agencies to create rules that have the force of law. To exercise this delegated power, an agency must 
have a grant of rulemaking authority and a law to implement. 
 
FISCAL OR ECONOMIC IMPACT:  
 
STATE GOVERNMENT:  
Fiscal impact on DCF: 
 
 Data System Updates: $6.92 million non-recurring to replace DCF’s current data system, the Financial and 
Services Accountability Management System, and meet all new data system requirements, and $3.9 million 
recurring.  The non-recurring cost includes: 
o IT Contractors: data architects, developers, analysts, report developers) - $120/hour * 2,000 hours 
each = $240,000 per FTE--$1,920,000 
o Cloud Infrastructure & Security: Hosting, cloud storage, cybersecurity measures)--$800,000 
o Business Advisory & Project Management: Oversight, requirement gathering, stakeholder 
engagement, risk management--$1,500,000 
                                                            
2
 Id. at 5. 
3
 Id.   JUMP TO SUMMARY 	ANALYSIS RELEVANT INFORMATION BILL HISTORY 
 	4 
o Training, OCM for MEs: Training managing entities on new processes, data formats, portal usage--
$700,000 
o Upgrading ME Systems: Grants or funding assistance to help MEs modernize/replace legacy 
systems to ensure interoperability--$1,000,000 
o Additional Software, licensing: Integration with new portal, back-end application programming 
interfaces, data ingestion, and partner credentialing--$1,000,000 
 Auditing services: $3 million to procure auditing services for the operational and financial audits of the 
seven ME contracts.
4  
 
 
PRIVATE SECTOR:  
MEs may experience a fiscal impact to upgrade systems and processes to collect and report required data and 
information. This amount is indeterminate. 
 
 
RELEVANT INFORMATION 
SUBJECT OVERVIEW: 
 
Behavioral Health  
 
Mental illness affects millions of people in the U.S. each year. It is estimated that more than one in five adults live 
with a mental illness.
5 In 2023, approximately 22.8 percent of adults experienced mental illness.
6  
 
Approximately, 48.5 million people in the U.S. aged 12 and older had a substance use disorder in 2023.
7 The most 
common substance use disorders in the U.S. are from the use of alcohol, tobacco, cannabis, stimulants, 
hallucinogens, and opioids.
8 
 
Publicly-Funded Behavioral Health Services 
 
Several agencies provide publicly-funded behavioral health services in Florida.  For example, agencies such as the 
Department of Education and the Department of Corrections provide behavioral health services ancillary to their 
broader missions of education, and incarceration and rehabilitation, respectively.  The Agency for Health Care 
Administration provides behavioral health services as part of its primary charge to provide health care but 
restricts services to those individuals who are eligible based on factors such as income, age, and disability.   
 
However, the Department of Children and Families (DCF), responsible for safety-net behavioral health services, 
serves all Floridians who are otherwise unable to obtain certain behavioral health services, based on priority 
populations and the limitations of available funding.  DCF administers a statewide system of safety-net services for 
substance abuse and mental health (SAMH) prevention, treatment and recovery for children and adults meeting 
eligibility requirements based on the nature of illness and inability to pay.
9 SAMH programs include a range of 
prevention, acute interventions (e.g. crisis stabilization), residential treatment, transitional housing, outpatient 
                                                            
4
 Id at 7-9. 
5
 National Institute of Mental Health (NIH), Mental Illness, https://www.nimh.nih.gov/health/statistics/mental-illness (last 
visited March 16, 2025). 
6
 Substance Abuse and Mental Health Services Administration (SAMHSA), Key Substance Use and Mental Health Indicators in 
the United States: Results from the 2023 National Survey on Drug Use and Health available at 
https://www.samhsa.gov/data/sites/default/files/reports/rpt47095/National%20Report/National%20Report/2023-nsduh-
annual-national.pdf, (last visited March 16, 2025).  
7
 Id. 
8
 National Library of Medicine, Commonalities and Differences Across Substance Use Disorders: Phenomenological and 
Epidemiological Aspects, available at https://pmc.ncbi.nlm.nih.gov/articles/PMC5096462/,  (last visited March 16, 2025). 
9
 S. 394.674, F.S.  JUMP TO SUMMARY 	ANALYSIS RELEVANT INFORMATION BILL HISTORY 
 	5 
treatment, and recovery support services. Services are provided based upon state and federally-established 
priority populations.  DCF provides these services primarily through behavioral health managing entities (MEs).
10 
 
Behavioral Health Managing Entities 
 
In 2001, the Legislature authorized DCF to implement MEs as the management structure for the delivery of local 
mental health and substance use disorder services.
11 The implementation of the ME system initially began on a 
pilot basis and, in 2008, the Legislature authorized DCF to implement MEs statewide.
12 MEs were fully 
implemented statewide in 2013, serving all geographic regions.  
 
DCF currently contracts with seven MEs for behavioral health services throughout the state.  These contracts 
totaled $1.083 billion
13 in FY 2022-23, with $919 million spent on direct services.
14 MEs plan for and coordinate 
the delivery of community mental health and substance use disorder services, improve access to care, promote 
service continuity, purchase services, and support efficient and effective service delivery.  MEs subcontract with 
community providers to serve clients directly; this allows services to be tailored to the specific behavioral health 
needs in the various regions of the state.
15  
 
In FY 2022-23, in the aggregate, DCF reported serving 243,403 unduplicated behavioral health clients
16, including 
through the MEs.  Client counts for individuals served through some ME specialty programs included: 
 
 Mobile response teams (MRT): 28,394.
17 
 Care coordination: 4,701.
18 
 Family Intensive Teams (FIT): 1,581.
19 
 
DCF contracts specify ME responsibilities based on requirements in Florida law.  For example, MEs are responsible 
for the system of care in their regions.  MEs also must provide data and information to facilitate DCF oversight of 
ME services. 
 
 Coordinated System of Care 
 
MEs are required to promote the development and implementation of a coordinated system of care.
20 A 
coordinated system of care means a full array of behavioral and related services in a region or community offered 
by all service providers, participating either under contract with a ME or by another method of community 
partnership or mutual agreement.
21 A community or region provides a coordinated system of care for those with a 
mental illness or substance use disorder through a no-wrong-door model, to the extent allowed by available 
resources.  
 
There are several essential elements which comprise a coordinated system of care, including:
22 
 
 Community interventions;  
                                                            
10
 S. 394.9082, F.S. 
11
 Ch. 2001-191, Laws of Fla. 
12
 Ch. 2008-243, Laws of Fla. 
13
 DCF, A Comprehensive, Multi-Year Review of the Revenues, Expenditures, and Financial Positions of the Managing Entities 
Including a System of Care Analysis, p. 5, available at  https://myflfamilies.com/document/57451, (last visited March 17, 2025) 
14
 Id. at 11. 
15
 Department of Children and Families, Managing Entities, available at https://www.myflfamilies.com/services/   
samh/provIders/managing-entities, (last visited March 16, 2025). 
16
 DCF, supra note 15, at 14. 
17
 Id. at 18. 
18
 Id. at 20. 
19
 Id. at 23.  
20
 S. 394.9082(5)(d), F.S. 
21
 S. 394.4573(1)(c), F.S. 
22
 S. 394.4573(2), F.S.  JUMP TO SUMMARY 	ANALYSIS RELEVANT INFORMATION BILL HISTORY 
 	6 
 Case management; 
 Care coordination; 
 Outpatient services;  
 Residential services;  
 Hospital inpatient care;  
 Aftercare and post-discharge services; 
 Medication assisted treatment and medication management; and  
 Recovery support. 
 
A coordinated system of care must include, but is not limited to, the following array of services:
23 
 
 Prevention services; 
 Home-based services; 
 School-based services; 
 Family therapy;  
 Family support; 
 Respite services; 
 Outpatient treatment;  
 Crisis stabilization; 
 Therapeutic foster care; 
 Residential treatment; 
 Inpatient hospitalization; 
 Case management; 
 Services for victims of sex offenses; 
 Transitional services; and 
 Trauma-informed services for children who have suffered sexual exploitation. 
 
 Oversight and Accountability 
 
DCF collects a wide variety of data and information to assess the performance of the MEs, such as about persons 
served and their outcomes and costs of services provided through the contract.
24 One such document is a financial 
and compliance audit, which pursuant to the contract, the MEs must submit the earlier of 180 days after the end of 
the provider’s fiscal year or 30 days after the ME’s receipt of the audit report. MEs must submit these documents at 
specific points and intervals. DCF specifies that documents required under contract be submitted electronically to 
the DCF Contract Manager and also added to the MEs secure web-based document vault.
25 
 
How DCF uses this data and information to assess and improve performance varies. For example, DCF negotiated 
the following performance standards for MEs in the current contracts: 
 
 Monitoring of at least 20% of all network service providers each fiscal year. 
 Ensuring 100% of the cumulative annual network service provider expenses comply with the federal 
block grant and maintenance of effort allocation standards. 
 Achieving 95% of the annual target levels for each of the network service provider measures, measured 
across all ME providers, as listed below.
26  
                                                            
23
 S. 394.495(4), F.S. 
24
 Department of Children and Families, Managing Entities FY24-25 Templates, EXHIBIT C3 – ME Required Reports, Plans, and 
Functional Tasks, https://www.myflfamilies.com/services/samh/providers/managing-entities/managing-entities-fy24-25-
templates (accessed March 9, 2025).  Examples of required reports are the Network Service Provider Monitoring Plan, 
Managing Entity Monthly Expenditure Report, and the Monthly Data Submission to SAMH Data System. 
25
 Id. 
26
 Department of Children and Families, Managing Entities FY24-25 Templates, Exhibit E, 
https://www.myflfamilies.com/services/samh/providers/managing-entities/managing-entities-fy24-25-templates (accessed 
March 9, 2025).  JUMP TO SUMMARY 	ANALYSIS RELEVANT INFORMATION BILL HISTORY 
 	7 
 
 
 
 
 
 
 
 
Target Population and Measure Description
27 
Network 
Target 
Minimum 
Acceptable 
ME Network 
Performance 
Adult Community Mental Health 
MH003 
Average annual days worked for pay for adults with severe and 
persistent mental illness  
40 38 
MH703 
Percent of adults with serious mental illness who are competitively 
employed  
24% 22.8% 
MH742 
Percent of adults with severe and persistent mental illnesses who 
live in stable housing environment  
90% 85.5% 
MH743 
Percent of adults in forensic involvement who live in stable 
housing environment 
67% 63.7% 
MH744 
Percent of adults in mental health crisis who live in stable housing 
environment  
86% 81.7% 
Adult Substance Abuse 
SA753 
Percentage change in clients who are employed from admission to 
discharge  
10% 9.5% 
SA754 
Percent change in the number of adults arrested 30 days prior to 
admission versus 30 days prior to discharge 
15% 14.3% 
SA755 
Percent of adults who successfully complete substance abuse 
treatment services  
51% 48.5% 
SA756 
Percent of adults with substance abuse who live in a stable housing 
environment at the time of discharge  
94% 89.3% 
Children’s Mental Health 
MH012 
Percent of school days seriously emotionally disturbed (SED) 
children attended  
86% 81.7% 
MH377 
Percent of children with emotional disturbances (ED) who 
improve their level of functioning 
64% 60.8% 
MH378 
Percent of children with serious emotional disturbances (SED) 
who improve their level of functioning 
65% 61.8% 
MH778 
Percent of children with emotional disturbance (ED) who live in a 
stable housing environment 
95% 90.3% 
MH779 
Percent of children with serious emotional disturbance (SED) who 
live in a stable housing environment 
93% 88.4% 
MH780 
Percent of children at risk of emotional disturbance (ED) who live 
in a stable housing environment 
96% 91.2% 
Children’s Substance Abuse 
SA725 
Percent of children who successfully complete substance abuse 
treatment services 
48% 45.6% 
SA751 
Percent change in the number of children arrested 30 days prior to 
admission versus 30 days prior to discharge  
20% 19.0% 
SA752 
Percent of children with substance abuse who live in a stable 
housing environment at the time of discharge 
93% 88.4% 
 
                                                            
27
 Id.   JUMP TO SUMMARY 	ANALYSIS RELEVANT INFORMATION BILL HISTORY 
 	8 
DCF has set additional performance measures for specific services, such as outcomes for participants in FIT and 
Community Action Treatment (CAT) teams.
28 
 
If the ME fails to meet the contract requirements, the contract specifies that “corrective action may be required for 
noncompliance, nonperformance, or unacceptable performance under this contract. Financial consequences may 
be imposed for failure to implement or to make acceptable progress on such corrective action.”
29 The contract 
does not include specific dollar amounts for financial penalties. 
 
All ME contracts expire on June 30, 2025. The contracts have been reprocured, and the same seven providers were 
awarded the new ME contracts.
30 DCF reports that the new contracts include additional performance measures and 
financial penalties, such as regarding timely access: 
 
Measure Description 
Minimum Acceptable ME Network 
Performance 
Effective 
7/1/2025 
Effective 
7/1/2027 
Effective 
7/1/2029 
Appointments for urgent services (services needed to preclude 
a crisis) provided within 48 hours of a request. 
70% 80% 90% 
Appointments for rapid intervention for children, families, or 
individuals in distress or at risk for entry into foster care, 
justice systems or more intensive services within 72 hours 
from the date of a referral or request for assistance. 
70% 80% 90% 
Appointments for outpatient follow-up services provided 
within 7 days after discharge from an inpatient or residential 
setting. 
70% 80% 90% 
Appointments for initial assessment are provided within 14 
days of a request for treatment. 
70% 80% 90% 
 
DCF reports on ME performance specifically, and system performance more broadly, in three statutorily-required 
annual reports.  These are the:  
 
 Comprehensive, Multi-Year Review of the Revenues, Expenditures, and Financial Positions of the 
Managing Entities Including a System of Care Analysis,  
 Assessment of Behavioral Health Services, and 
 Triennial Plan for the Delivery of Mental Health and Substance Abuse Services and updates. 
 
Performance Information Reported for Safety-Net Mental Health Services under Federal Block Grant 
Requirements 
 
Under the federal Substance Abuse and Mental Health Services Administration’s requirements for the Community 
Mental Health Services Block Grant, which funds a portion of the safety-net mental health services administered by 
DCF, state mental health agencies like DCF compile and report annual data.  Below are 2023 data reported by DCF 
compared to national data, for a subset of outcomes on which DCF reported, for individuals DCF served
31: 
                                                            
28
 Id. 
29
 Id. 
30
My Florida Marketplace, Advertisement Number: ITN-06623, Intent to Award, 
https://vendor.myfloridamarketplace.com/search/bids/detail/6623 (accessed March 9, 2025). 
31
 Substance Abuse and Mental Health Services Administration, Florida 2023 Mental Health National Outcome Measures 
(NOMS): SAMHSA Uniform Reporting System, https://www.samhsa.gov/data/report/2023-uniform-reporting-system-urs-
table-florida (accessed March 13, 2025).   JUMP TO SUMMARY 	ANALYSIS RELEVANT INFORMATION BILL HISTORY 
 	9 
 
 
 
 
 
 
Measure 	Florida U.S. 
Percent of adults in labor force (employed) 	41.9% 52.6% 
Percent of children/families with improved social 
connectedness 
87.7% 88.0% 
Percent of adults with improved social connectedness 86.9% 76.5% 
Percent of children/families reporting positively about 
general satisfaction with care 
82.5% 87% 
Percent of adults reporting positively about general 
satisfaction with care 
83.7% 88.6% 
 
 
 
RECENT LEGISLATION:  
 
YEAR BILL #  HOUSE SPONSOR(S) SENATE SPONSOR OTHER INFORMATION 
2023 HB 1095 Smith, Barnaby Rouson Died in House 
2022 SB 2526 Health – Senate 
Appropriations Committee 
 Passed (LOF 2022-150) 
 
  JUMP TO SUMMARY 	ANALYSIS RELEVANT INFORMATION BILL HISTORY 
 	10 
BILL HISTORY 
COMMITTEE REFERENCE ACTION DATE 
STAFF 
DIRECTOR/ 
POLICY CHIEF 
ANALYSIS 
PREPARED BY 
Human Services Subcommittee 17 Y, 0 N, As CS 3/18/2025 Mitz Curry 
THE CHANGES ADOPTED BY THE 
COMMITTEE: 
The amendment: 
 Requires DCF to contract biennially for operational and financial audits 
for each ME. 
 Revises the information that must be analyzed during the audits to 
require an analysis to assess the extent to which MEs are funding 
services for Medicaid beneficiaries that are covered under the Medicaid 
program. 
 Narrows the scope of documents that MEs must submit to DCF, 
requiring the submission of all documents that are required under 
contact for submission on a routine basis to be submitted to DCF.  
 Revises the performance measures for client outcomes that MEs must 
track and submit to DCF to require MEs to submit specific measures for 
services funded by MEs regarding individual outcomes and functioning.  
 Requires DCF to post the performance measures reported by the MEs 
to its website by the 15
th of each month. 
 Requires MEs to report the measures using the reporting methodology 
determined by DCF. 
Health Care Budget Subcommittee    
Health & Human Services 
Committee 
    
 
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THIS BILL ANALYSIS HAS BEEN UPDATED TO INCORPORATE ALL OF THE CHANGES DESCRIBED ABOVE. 
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