Corrective Action Plans

Finding 505369 (2024-001)

Significant Deficiency 2024

IL

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehe...

The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehensive process to resubmit corrected enrollment files to the NSC, covering Spring 2023, Summer 2023, and Fall 2023. In collaboration with NSC, we followed their established process to rectify the error, which required reloading each submission one at a time in succession from the original submission with the error. This process caused delays in our subsequent submissions until the corrections were fully completed. To prevent recurrence, we have implemented enhanced checks and controls prior to each submission to review the file and file size to ensure the correct number of students are submitted to NSC. Additionally, all submissions post-Spring 2023 have been reviewed, and we have confirmed that this was an isolated incident.

View Audit 328046

Finding 505349 (2024-002)

Significant Deficiency 2024

Mount Marty University

SD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding Summary: One instance was identified in which the student was over-awarded Federal Pell assistance. The Watertown location does not use the auto package tool within Anthology for awarding students; rather, awarding student assistance is a manual process. The incorrect line item was read on t...

Finding Summary: One instance was identified in which the student was over-awarded Federal Pell assistance. The Watertown location does not use the auto package tool within Anthology for awarding students; rather, awarding student assistance is a manual process. The incorrect line item was read on the PELL chart resulting in the student being over-awarded Pell assistance in the summer of 2023. Responsible Individuals: Lauren Svanda, Director of Financial Aid Corrective Action Plan: When implementing the FAFSA changes for 2024, the SIS was configured to utilize the Auto Packaging function for the Watertown location which significantly reduces the likelihood of a student being awarded the incorrect amount of PELL. After each student is Auto Packaged, it is reviewed to ensure accuracy of the PELL calculation. Anticipated Completion Date: Resolved – Spring 2024

View Audit 327987 Questioned Costs: $1

Finding 505306 (2024-002)

None 2024

University Preparatory Charter School for Young Men

NY

Subrecipient Monitoring Reporting

Audit Recommendation 2024-002: • The School should ensure that the data being reported is accurate. The Implementation Plan of Action(s): • Both ESSER and ARP ESSER reports are conducted by a 3rd party agency. To ensure accuracy, they will be monitored internally; reviewed and approved prior to the...

Audit Recommendation 2024-002: • The School should ensure that the data being reported is accurate. The Implementation Plan of Action(s): • Both ESSER and ARP ESSER reports are conducted by a 3rd party agency. To ensure accuracy, they will be monitored internally; reviewed and approved prior to the final submission/upload of the report. Reports will not be submitted without final approval of School Officials. Implementation Date: • This change will be reflected in the upcoming 2025 annual report. Control processes will be communicated between the School and the 3rd party reporting agency. Person Responsible for Implementation: • This process will be managed by the Director of Business and reviewed by the Chief Financial Officer.

View Audit 327915

Finding 505305 (2024-001)

Material Weakness 2024

University Preparatory Charter School for Young Men

NY

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Audit Recommendation 2024-001: • The School should ensure that processes are in place to understand reporting requirements that ensure that the data being reported is accurate. The Implementation Plan of Action(s): • Elementary and Secondary School Emergency Relief Fund (ESSER) and American Rescue ...

Audit Recommendation 2024-001: • The School should ensure that processes are in place to understand reporting requirements that ensure that the data being reported is accurate. The Implementation Plan of Action(s): • Elementary and Secondary School Emergency Relief Fund (ESSER) and American Rescue Plan (ARP ESSER) reports are conducted by a 3rd party agency. To ensure accuracy, they will be monitored internally; reviewed and approved prior to the final submission/upload of the report. Reports will not be submitted without final approval of School Officials. Implementation Date: • This change will be reflected in the upcoming 2025 annual report. Control processes will be communicated between the School and the 3rd party reporting agency. Person Responsible for Implementation: • This process will be managed by the Director of Business and reviewed by the Chief Financial Officer.

View Audit 327915

Finding 505278 (2024-001)

Significant Deficiency 2024

McNc

NC

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Name of Contact Person: Sarah Taylor, CFO Corrective Action: The Organization agrees that a significant deficiency exists regarding internal controls over financial reporting related to the revision to the fiscal year 2023 consolidated financial statements for a gross vs. net presentation error rela...

Name of Contact Person: Sarah Taylor, CFO Corrective Action: The Organization agrees that a significant deficiency exists regarding internal controls over financial reporting related to the revision to the fiscal year 2023 consolidated financial statements for a gross vs. net presentation error related to ASC 606. The Organization identified the error in the current year review of revenue contracts in accordance with ASC 606, and informed Forvis Mazars of the presentation error. As part of the corrective action plan, Management continually assesses existing and new contracts with ASC 606 and has implemented policies and procedures surrounding the adherence to GAAP accounting requirements. Implementation Date: July 1, 2023

View Audit 327907

Finding 505277 (2024-001)

None 2024

Albany College of Pharmacy and Health Sciences

NY

Student Financial Aid Subrecipient Monitoring Reporting

Finding Number: 2024-001 Federal Assistance Listing Number: 84.268 Federal Direct Student Loans Year Ended: June 30, 2024 Responsible Individual: Christine Banewicz Director of Student Accounts Management’s Response and Corrective Action Plan: The College agrees with the finding and recommendation. ...

Finding Number: 2024-001 Federal Assistance Listing Number: 84.268 Federal Direct Student Loans Year Ended: June 30, 2024 Responsible Individual: Christine Banewicz Director of Student Accounts Management’s Response and Corrective Action Plan: The College agrees with the finding and recommendation. The College ran a report of Direct Loan disbursements made during fiscal year 2024, noting that the required communications had not timely been sent out for 43 Direct Loan disbursements that took place from May 31, 2024 through June 30, 2024. Upon discovery of the change in criteria, management identified the students that had been impacted and sent disbursement notifications to students the next day, on July 31, 2024. Management has implemented in their control process an additional step to compare reports of Direct Loan disbursements between the Student Information and Financial Aid systems to identify any discrepancies going forward. The above procedures have already been implemented.

View Audit 327903

Finding 505267 (2024-001)

Material Weakness 2024

Birmingham Public Schools

MI

Reporting School Nutrition Programs Internal Control / Segregation of Duties

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School ...

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School District is required to have controls in place to ensure the accuracy of the request for reimbursement. For certain periods during the year the School District asserts there was a review process in place over the reimbursement requests; however, the review was not documented, and therefore we were not able to verify if the control was in place and operating effectively. For other periods during the year, the School District did not have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the School District being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The School District's business office performed a detailed review of all meal claim submissions for the 2023-2024 fiscal year. Ultimately, the lack of a review control during the 2023-2024 fiscal year did not result in inaccurate reporting or incorrect amount of reimbursement paid by the Michigan Department of Education. The Business Office has since implemented a formalized internal control procedure beginning in July 2024, whereby a formal documented review of the meal claim submission is performed. Contact person responsible for corrective action: Kevin Taratuta, Chief Financial and Operations Officer Anticipated Completion Date: August 1, 2024

View Audit 327892

Finding 505240 (2024-002)

Significant Deficiency 2024

Bellevue Independent School District

KY

Subrecipient Monitoring Special Tests & Provisions

Additional care will be taken in the future to ensure compliance with prevailing wage requirements.

View Audit 327857

Finding 505081 (2024-001)

Significant Deficiency 2024

Elkton Pigeon Bay Port Laker Schools

MI

Subrecipient Monitoring School Nutrition Programs

District responsible individual to implement this plan: Mike Klosowski, CFO The findings from the June 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding – Federal Award Finding Finding 2024...

District responsible individual to implement this plan: Mike Klosowski, CFO The findings from the June 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding – Federal Award Finding Finding 2024-001: Considered a significant deficiency in internal control over compliance. Recommendation: The District should perform annual on-site reviews of buildings where breakfast and lunch are served prior to February 1st each year as required by Michigan Department of Education. This should be documented by using the Michigan Department of Education’s School Nutrition Program On-Site Review Form. Action to be Taken: Management agrees with the finding and has implemented procedures to make sure the on-site reviews are completed annually by the due date.

View Audit 327758

Finding 505078 (2024-001)

Material Weakness 2024

Mary Lee Flagship

TX

Subrecipient Monitoring

Action taken: Management agrees with the finding and commits to following the provided recommendations.

View Audit 327746

Finding 505052 (2024-001)

Significant Deficiency 2024

National Arbor Day Foundation

NE

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

A plan has been put in place that involves the Accounting Director monitoring the FFATA reporting activity monthly to ensure that the Foundation meets the reporting requirements of the program. Each month, the Accounting Director contacts the Grant Administrator to determine if any new first-tier s...

A plan has been put in place that involves the Accounting Director monitoring the FFATA reporting activity monthly to ensure that the Foundation meets the reporting requirements of the program. Each month, the Accounting Director contacts the Grant Administrator to determine if any new first-tier subaward contracts have been signed during the last 30 days. If any contracts have been signed, the Accounting Director obtains a copy of the FFATA report that the Grant Administrator filed during the month to verify that it contains those subaward contracts and that they have been reported on a timely basis and in the correct amount. In addition, the Accounting Director compares information on the monthly FFATA reports to a master list of approved sub awardees to verify contract amounts and to ensure that all contracts are being reported.

View Audit 327737

Finding 504946 (2024-002)

Material Weakness 2024

Oak Park School District

MI

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Finding 2024-002 - Material Weakness and Material Non-Compliance: Special Test and Provisions related to the Education Stabilization Fund, Assistance Listing Number, 84.425U, Award Number 213713/2122 Corrective Action: Both Finance and Operations Department will work simultaneously on preparing bid...

Finding 2024-002 - Material Weakness and Material Non-Compliance: Special Test and Provisions related to the Education Stabilization Fund, Assistance Listing Number, 84.425U, Award Number 213713/2122 Corrective Action: Both Finance and Operations Department will work simultaneously on preparing bid offers associated to all grant funding. Department of Operations will provide the Finance with copies of all grant funded bid projects and review for approval prior to engagement. In addition, we will seek legal guidance regarding contractual terms. Corrective Action Date of Completion: Beginning October 2024 and ongoing Responsible Party: Executive Director of Finance and Director of Operations

View Audit 327697 Questioned Costs: $1

Finding 504796 (2024-001)

Significant Deficiency 2024

Habitat for Humanity of the Charlotte Region, Inc. and Subsidiaries

NC

Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management

Habitat for Humanity of the Charlotte Region (HCR) verifies suspension and debarment status through SAM.gov. This was an isolated incident. Of the 19 items reviewed, only one verification was not completed. This specific contractor self-certified that they were not suspended or debarred from workin...

Habitat for Humanity of the Charlotte Region (HCR) verifies suspension and debarment status through SAM.gov. This was an isolated incident. Of the 19 items reviewed, only one verification was not completed. This specific contractor self-certified that they were not suspended or debarred from working on government contracts before the contract was awarded. The ARPA contract that governs this grant allows contractor self-certification to meet compliance requirements. The validation was not done prior to grant award, but it was subsequently validated on SAM.gov that the contractor is not debarred or suspended. We are updating our process documentation to ensure that verification of self-certification is completed prior to contract award.

View Audit 327465

Finding 504683 (2024-001)

Material Weakness 2024

Lake Land College

IL

Subrecipient Monitoring Procurement, Suspension & Debarment Reporting

Recommendation - The College should implement a procedure to timely complete and file the FFATA reporting required by Title 2 CFR Part 70, Subpart A. Action Taken: Based on the auditor's recommendation the College will implement a procedure to timely complete and file the FFATA reporting required by...

Recommendation - The College should implement a procedure to timely complete and file the FFATA reporting required by Title 2 CFR Part 70, Subpart A. Action Taken: Based on the auditor's recommendation the College will implement a procedure to timely complete and file the FFATA reporting required by Title 2 CFR Part 70, Subpart A.

View Audit 327282

Finding 504672 (2024-002)

None 2024

Rhodes College

TN

Student Financial Aid Subrecipient Monitoring Special Tests & Provisions

Finding No. 2024-002 ...

Finding No. 2024-002 Recommendation: The College should develop a Title IV monitoring system to ensure timely return of funds. Management Response: The College concurs with the finding. College Corrective Plan: The Office of Financial Aid has met with the Bursars Office to develop a multi-pronged approach to track withdrawal of studens and the return of Title IV funds. The office will add to the Withdrawal Process currently implemented in WorkDay to include a confirmation funds were returned. In addition to the update in the WorkDay process, a return deadline will be stored and monitored in PowerFAIDS as a scheduled task for the Associate Director and Director of Financial Aid, to insure funds are returned and confirmed prior to thirty days of the determined withdrawal. We believe this delay in the return of funds to be an isolated issue. But the additional notification and tasks will insure that it does not happen in the future.

View Audit 327263

Finding 504647 (2024-001)

Material Weakness 2024

Life Pacific University

CA

Subrecipient Monitoring Material Weakness

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Life Pacific University has engaged in a contractual partnership with Vertical Computers to accurately address and proactively mitigate audit findings and deficiencies, thereby ensuring sustained adherence to regulatory standards an...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Life Pacific University has engaged in a contractual partnership with Vertical Computers to accurately address and proactively mitigate audit findings and deficiencies, thereby ensuring sustained adherence to regulatory standards and operational excellence. Vertical Computers specializes in Voice over IP (VoIP), networking, virtualization, open-source integration, IT management, project management, data backup solutions, cloud services, remote monitoring, and offsite backup. Below will address all findings and deficiencies outlined by the Gramm-Leach-Bliley Act (GLBA). Person Responsible for Corrective Action Plan: George Bostanic - COO and Vice President of Student Life, Alex Wright — Director of Audio, Visual, and Technology, Service Provider Vertical Computers Anticipated Date of Completion: All areas of findings and deficiencies outlined by the Gramm- Leach-Bliley Act (GLBA) are being actively addressed

View Audit 327230

Finding 504609 (2024-002)

Significant Deficiency 2024

Charlton Heston Academy

MI

Subrecipient Monitoring School Nutrition Programs Significant Deficiency

Charlton Heston Academy respectfully submits the following corrective action plan for the year ended June 30, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2024 Academy Contact Person: Frank Patterson, Chief Financial Officer F...

Charlton Heston Academy respectfully submits the following corrective action plan for the year ended June 30, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2024 Academy Contact Person: Frank Patterson, Chief Financial Officer Finding 2024-001 – Significant deficiency Recommendation: We recommend the Academy establish improved controls for preparing and reviewing year-end reconciliations. The Academy should ensure that reconciliations are completed in a timely manner and agree to the general ledger. Actions to be taken: The Academy concurs with the facts of this finding and are in the process of adding human capital/capacity, developing a revised formal timeline, and checklist of year-end procedures as recommended. Finding 2024-002 – Significant deficiency Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: The Academy concurs with the facts of this finding and has implemented procedures to prevent this in the future.

View Audit 327194

Finding 504488 (2024-001)

Significant Deficiency 2024

North Muskegon Public Schools

MI

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2024-001: Internal Controls Over the Federal Expenditure Report Type of Finding: Control U.S. Department of Education Pass-through Entity: Michigan Department of Education Assistance Listing Number: 84.425D Award Numbers: COVID-19 213712-2021, COVID-19 213782-2223 Award Year End: Sep...

Finding 2024-001: Internal Controls Over the Federal Expenditure Report Type of Finding: Control U.S. Department of Education Pass-through Entity: Michigan Department of Education Assistance Listing Number: 84.425D Award Numbers: COVID-19 213712-2021, COVID-19 213782-2223 Award Year End: September 30, 2023 Recommendation: The School District should establish procedures to require the documented review and approval of all reports by an individual with adequate skills, knowledge, and experience prior to submission. Action Taken: The School District has implemented a new procedure requiring that all reports be reviewed and approved by a designated reviewer before submission. The reviewer, who must possess the appropriate skills, knowledge, and experience relevant to the report's content, will ensure that the information is accurate, complete, and compliant with organizational standards and regulatory requirements. Responsible Person and Anticipated Completion Date: Director of Business Services, September 2024. If the Michigan Department of Education has questions regarding this plan, please call Mark Mesbergen at (231) 719-4102.

View Audit 327050

Finding 504485 (2024-003)

Material Weakness 2024

Ecorse Public Schools

MI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Issue: Material Weakness in Internal Controls Over Financial Reporting and Material Noncompliance - Allowable Activities and Chart of Accounts and Budget Monitoring Corrective Action Plan: The district is updating and correcting all accounts in accordance with the 1022 manuals.

View Audit 327038 Questioned Costs: $1

Finding 504474 (2024-002)

Significant Deficiency 2024

Bellevue Fire Control Board

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

Management is in the process of drafting an updated procurement policy to comply with the requirements of the Uniform Guidance.

View Audit 327007

Finding 504421 (2024-002)

Significant Deficiency 2024

Missouri Baptist University

MO

Student Financial Aid Subrecipient Monitoring Reporting

Student Status Changes The process of reporting enrollment to the NSLDS has historically been housed within the Student Financial Services department. The compliance issues with enrollment reporting during the prior award year were a result of having only one individual trained in transmitting our m...

Student Status Changes The process of reporting enrollment to the NSLDS has historically been housed within the Student Financial Services department. The compliance issues with enrollment reporting during the prior award year were a result of having only one individual trained in transmitting our monthly file to the National Student Clearinghouse. Over the past few months, staff from our Records Office have been receiving training on preparing enrollment reporting files for transmission to the National Student Clearinghouse. During the current award year, collaborative meetings have been scheduled to have the principal agent from the Records Office and the principal agent from the Student Financial Services department meet to transmit data files to the Clearinghouse. Subsequent meetings are scheduled within 24-48 hours of each file transmission date to ensure error reports posted to the Clearinghouse are resolved in a timely manner. Zach Greenlee Director, Student Financial Services Phone: 314-392-2398 Email: zach.greenlee@mobap.edu

View Audit 326979

Finding 504417 (2024-001)

Material Weakness 2024

Missouri Baptist University

MO

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking

Return of Title IV Funds (R2T4) Due to the specialized skills and knowledge required for processing returning funds through the R2T4 process, Missouri Baptist University will be reassigning the responsibility for reviewing withdrawals within the Student Financial Services department to the Director ...

Return of Title IV Funds (R2T4) Due to the specialized skills and knowledge required for processing returning funds through the R2T4 process, Missouri Baptist University will be reassigning the responsibility for reviewing withdrawals within the Student Financial Services department to the Director of Student Financial Services. All withdrawals will be evaluated by the Director and all calculations using the R2T4 calculator available on the Common Origination and Disbursement (COD) system will be performed by the Director. Additional staff within the department will be tasked with verifying accuracy of returns to help provide exposure to the highly technical work of R2T4, thus providing training that will enable broader sharing of the responsibility in the future. An internal report has been created to give a daily summary of students who have withdrawn since the following day. This will complement the existing reporting structure which consists of individual withdrawal paperwork processed by our Records Department. Bi-weekly reports will be given to the Senior Vice President for Business Affairs to monitor compliance. Zach Greenlee Director, Student Financial Services Phone: 314-392-2398 Email: zach.greenlee@mobap.edu

View Audit 326979

Finding 504254 (2024-002)

None 2024

Watertown City School District

NY

Questioned Costs Allowable Costs / Cost Principles Period of Performance

Planned Corrective Actions The District has experienced a large amount of turnover in various administrative positions. These positions include grant directors, business official, and superintendent. With new perman...

Planned Corrective Actions The District has experienced a large amount of turnover in various administrative positions. These positions include grant directors, business official, and superintendent. With new permanent staff in place, the business official (Assistant Superintendent for Operations and Finance) will be working closely with the grant director (Assistant Superintendent for Instruction) to ensure all expenses being reported are allowable. Those procedures were implemented on July 8, 2024 with immediate effect.

View Audit 326752 Questioned Costs: $1

Finding 504241 (2024-002)

Significant Deficiency 2024

South Dakota Housing Development Authority

SD

Special Tests & Provisions Subrecipient Monitoring Allowable Costs / Cost Principles

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name and FALN #: FALN # 14.231 COVID-19 Emergency Solutions Grant Program (ESG – CV) and Emergency Solutions Grant Program (ESG) Finding Summary: For the special tests and provisions compliance requirement testing, of the ...

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name and FALN #: FALN # 14.231 COVID-19 Emergency Solutions Grant Program (ESG – CV) and Emergency Solutions Grant Program (ESG) Finding Summary: For the special tests and provisions compliance requirement testing, of the 49 disbursements tested, eleven payments were made outside of the 30-day requirement. Responsible Individuals: Denise Albertson, ESG Administrator Amy Eldridge – Director of Rental Housing Development Corrective Action Plan: The ESG Administrator will track the days between receipt and disbursement to be able to meet the 30-day requirement. Anticipated Completion Date: September 30, 2024

View Audit 326747

Finding 504240 (2024-001)

Significant Deficiency 2024

South Dakota Housing Development Authority

SD

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name and FALN #: FALN # 14.231 COVID-19 Emergency Solutions Grant Program (ESG – CV) and Emergency Solutions Grant Program (ESG) Finding Summary: In three instances, the amount reimbursed to subrecipients were paid out bas...

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name and FALN #: FALN # 14.231 COVID-19 Emergency Solutions Grant Program (ESG – CV) and Emergency Solutions Grant Program (ESG) Finding Summary: In three instances, the amount reimbursed to subrecipients were paid out based on the persons paycheck stub showing allocation of hours which did not match backup provided for hours worked under the program, Responsible Individuals: Denise Albertson, ESG Administrator Amy Eldridge – Director of Rental Housing Development Corrective Action Plan: The ESG Administrator will review the timesheet information to ensure the hours and amounts for payroll costs are correctly allocated by the subrecipient to the program. Any differences in the allocation between the timesheets and paycheck stubs will be reviewed prior to disbursements. Anticipated Completion Date: September 30, 2024

View Audit 326747

Corrective Action Plans

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