PART FOUR: The Route to Compliance: Now That We’ve Arrived, What’s Next?

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EBOOK

PART FOUR

The Route to Compliance: Now That We’ve Arrived, What’s Next? Ensuring Compliance with the Centers for Medicare and Medicaid Services Interoperability and Patient Access Rule Electronic Event Notifications Condition of Participation From the CMS Interoperability and Patient Access Rule Toward a Vision for Interoperability and the Delivery of Whole Person Care

I S N O W B A M B O O H E A LT H © 2021 Bamboo Health. All rights reserved.

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© 2021 Bamboo Health. All rights reserved.


About this eBook As of May 1, 2021, U.S. hospitals must comply with the Centers for Medicare and Medicaid Services (CMS) Interoperability and Patient Access Rule Event Notifications (E-Notifications) Condition of Participation (CoP) requiring hospitals to send Admission, Discharge, and Transfer (ADT) notifications to all requesting post-acute providers, primary care providers (PCPs), and primary care entities. As hospital executives move forward with integrating solutions for sending real-time e-notifications at the point of inpatient admissions, discharges, and transfers, and at emergency department (ED) presentations or discharges, new questions have arisen, including:

• What are the key considerations from CMS’s Interpretive Guidance for the ADT notifications and what does it mean for my hospital?

• How can I prove to CMS that I am compliant to address CMS auditing? • How can we best plan for future compliance requirements? • What can I do to advance my organization’s goals for improving interoperability across the care continuum? Our Route to Compliance eBook series was designed to help hospitals understand the requirements in the CMS E-Notifications CoP. This fourth and final eBook in the series helps organizations of all sizes bridge the gap to ensure that they are in accordance with compliance requirements, and provides clarification of the follow-up interpretative guidance from CMS. This eBook also takes a look as the industry moves toward a greater vision for interoperability and the delivery of whole person care, including what’s next for PatientPing under our new company name—Bamboo Health. This close assessment of the key CoP compliance considerations can help hospital executives, chief information officers (CIOs), and compliance professionals determine their options and make more informed decisions about the best solution for their organization moving forward. This eBook is an interactive publication – simply look for links to navigate, play videos, and more! © 2021 Bamboo Health. All rights reserved.


WHAT’S AHEAD

Now That We’ve Arrived, What’s Next? U.S. Hospitals Continue to Integrate Solutions from PatientPing, now Bamboo Health, for E-Notifications CoP Compliance The deadline for U.S. hospitals to comply with the CMS Interoperability and Patient Access Rule E-Notifications CoP requiring hospitals to send ADT notifications to all requesting post-acute providers, PCPs, and primary care entities, was May 1, 2021. We’re here to help you navigate the road to compliance and beyond. This is part four of a four-part eBook series that features guidance to help hospital executives and CIOs understand compliance requirements and what to expect as the industry moves closer to realizing the promise of interoperable care collaboration. Here’s what this eBook series outlines.

PHASE ONE

Research and Planning Your Trip

PHASE TWO

Getting on the Road

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PHASE THREE

On the Highway to Compliance

WE ARE HERE! PHASE FOUR

Now That We’ve Arrived, What’s Next?

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© 2021 Bamboo Health. All rights reserved.


WHAT’S INCLUDED IN THIS EBOOK

Part Four: Now That We’ve Arrived, What’s Next? SECTION 1:

The Road Ahead: Navigating What’s Next as Hospitals Achieve E-Notifications CoP Compliance................................. 8 SECTION 2:

How We Can Help: A Guide to Route, a Single Solution to Ensure Hospitals Achieve Compliance with the CMS E-Notifications CoP...................................................................... 12 SECTION 3:

Looking Ahead and Planning for Future Compliance Requirements ........................................................ 17 SECTION 4:

The Promise and Vision for Interoperability and the Delivery of Whole Person Care - PatientPing + Appriss Health is now Bamboo Health .................................................. 20

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SECTION 1: THE ROAD AHEAD

Navigating What’s Next as Hospitals Achieve E-Notifications CoP Compliance Summary of the E-Notifications CoP While the deadline for hospitals to comply with the CMS E-Notifications CoP has passed, it does not mean the job is done. Despite the rule now being in effect, many CIOs and compliance executives continue to face challenges with implementation of the requirement, and others have begun to think about the road ahead. Before we jump into what’s next, below is a recap of the E-Notifications CoP that CMS finalized as part of the Interoperability and Patient Access Rule. Designed to help hospitals better serve their patients through improved care coordination and enhanced interoperability among providers, the CoP requires hospitals, psychiatric hospitals, and critical access hospitals to share electronic ADT-based event notifications with other community-based providers and care team members, including post-acutes. Hospitals utilizing an electronic health record (EHR) service provider or other electronic administrative system that is conformant with the content exchange standard HL7 v2.5.1, must make a reasonable effort to send real-time electronic notifications: AT: the point of inpatient and observation admission, discharge, and transfer, and at ED presentation and discharge TO: the patient’s established PCP, established primary care practice group or entity, other practitioners, practice groups or entities identified by the patient as primarily responsible for his or her care, and applicable post-acute providers who need to receive notification for treatment, care coordination, or quality improvement purposes CONTAINING: at minimum the patient’s name, treating practitioner’s name, and sending institution’s name With this in mind, our team sheds light on CMS’s Interpretive Guidance for compliance and how hospitals can prepare for and succeed through an audit.

8 • COP COMPLIANCE

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SECTION 1A

Interpretive Guidance Review What Hospitals Need to Know About “Reasonable Effort” and “Making Every Attempt Possible” to Achieve Compliance Molly Kane, Bamboo Health’s Manager of Government Affairs, takes a closer look at the language CMS used in the final rule and Interpretive Guidance around the provision that hospitals need to make a “reasonable effort” to send ADT e-notifications to applicable providers and entities. On May 7, 2021, CMS published its Interpretive Guidance for the ADT E-Notifications CoP for hospitals from the Interoperability and Patient Access final rule. As part of this guidance, CMS strengthened their previous language around hospitals needing to make a “reasonable effort” to send e-notifications, instead changing it to hospitals needing to make “every attempt” to send these notifications. So, what does this mean? While we still don’t have a true definition of what “reasonable effort” means, we now have a bit more clarity. Hospitals are expected to make every attempt to send ADT e-notifications of the patient’s status to all applicable post-acute providers and suppliers, in addition to the patient’s primary care practitioner, primary care group, or other practitioner or group that is identified by the patient as being responsible for their care. Below are some common questions and guidance for care institutions: Is one attempt at sending an ADT e-notification compliant? No, CMS’s language around hospitals needing to make “every attempt” to send ADT e-notifications to appropriate entities helps clarify that a single effort through a single avenue to send e-notifications will not be sufficient. Hospitals will need to make a valid attempt to send and deliver ADT e-notifications and may need to make multiple attempts to ensure entities are receiving the notifications.

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THE ROUTE TO COMPLIANCE: WHAT’S NEXT • 9


Only the patients need to identify post-acute providers, correct? No, post-acute providers go beyond ones that the patient identifies for themselves. Applicable post-acutes not only include those identified by the patient, but also any postacute with an established care relationship immediately preceding the hospital admission or registration, including post-acute care facilities from which the patient was transferred to the hospital, and post-acutes with which a care relationship is established post-discharge from the hospital. Will direct messaging work? Potentially. It is worth noting that some post-acute providers are not using direct messaging, as many don’t have the technological capabilities. This means that hospitals using direct messaging as their primary means of compliance will need to find another methodology to ensure they are delivering the notifications to these providers.

SECTION 1B

IT Team 101 Preparing and Succeeding Through a CMS E-Notifications CoP Audit Molly Kane shares some answers to commonly asked questions about the audit process and which hospitals qualify. Now that the E-Notifications CoP has taken effect, did you know all hospital surveys conducted by state survey agencies (SAs) are unannounced? To prepare for a CMS E-Notifications CoP audit, it is important to understand the processes that are involved with executing the audit and timing. Below are some common questions about a CoP audit, followed by clarification and guidance to ensure that your organization is prepared. Who conducts the CoP audits for CMS? SAs or Accreditation Organizations (AOs) conduct hospital surveys on behalf of CMS. The SAs are overseen by CMS Regional Offices (ROs) and are required to report findings and deficiencies to their designated RO. 10 •

CoP COMPLIANCE

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Hospitals may choose to be accredited by an approved AO, which exempts the hospital from routine surveys by SAs. Accreditation by an AO is voluntary and not required for Medicare certification; however, AOs need to apply to and be certified by CMS. If my hospital is accredited by an approved AO, how often will audits occur? CMS may direct the SA to conduct a survey of a hospital that uses an AO, but this generally only happens when complaints allege serious deficiencies. Annually, CMS directs the SAs to conduct full surveys of a sample of hospitals that use AOs as part of CMS’s assessment of an AO’s performance. CMS may not release the results of an AO survey unless there are enforcement actions against the hospital. If not accredited by an approved AO, how often can my hospital expect to be audited? A hospital audit is generally conducted every three to four years for compliance with all CoPs; however, if a hospital receives a complaint, a focused survey to investigate the complaint may occur at any time. How much time will my hospital have to prepare for an audit? All hospital surveys conducted by SAs are unannounced. A hospital must be prepared at all times for a CoP audit. What areas and services of my hospital will the audit assess? Surveyors assess the hospital’s compliance with the CoPs for all services, areas, and locations covered by the hospital’s provider agreement under its CMS Certification Number (CCN). Hospitals operate as “one unit” for compliance purposes based on the CCN. Certification is provided to all components that are under the legal control of the hospital governing body and part of the same corporation or governmental administrative entity. The entire hospital is evaluated, even when the components are separately housed. It is not permissible to certify only part of a general hospital. Is there anything that is not included in the evaluation for the audit? Yes, those that are not included in the evaluation are components appropriately certified as other kinds of providers or suppliers – such as distinct part skilled nursing facilities (SNF), distinct part nursing facilities (NF), home health agencies (HHA), rural health centers (RHC), and hospices. Other excluded areas include residential, custodial, and non-service units.

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THE ROUTE TO COMPLIANCE: WHAT’S NEXT • 11


SECTION 2: HOW WE CAN HELP

A Guide to Route, a Single Solution to Ensure Hospitals Achieve Compliance with the CMS E-Notifications CoP Meeting ADT E-Notification Compliance Needs for All Hospitals Regardless of Size or Location Now that the ADT E-Notifications CoP is in place, hospitals must be prepared to deliver transparency, security, and visibility into their data sharing practices. To support hospitals across the nation in identifying a compliance solution for sending electronic e-notifications for inpatient ADTs, as well as ED presentations and discharges, we have developed Route, the single solution that can guarantee full E-Notifications CoP compliance. Route can ensure all hospitals achieve compliance with the CMS E-notifications CoP, regardless of size or location. Built on a trusted national e-notifications network, Route alleviates hospitals’ compliance IT and data-sharing burdens. Route seamlessly delivers e-notifications to providers as identified by patients as well as to requesting community provider groups. The solution manages all of the complexities involved with sending the required e-notifications, from executing data sharing agreements with all e-notification recipients, to managing and executing the frequent, real-time changes to a diverse array of patient roster types to track patient-provider attribution.

CLICK HERE TO LEARN MORE ABOUT ROUTE 12 • CoP COMPLIANCE

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SECTION 2A

How Route Guarantees CMS CoP Compliance Audit Trail and Checklist for Success Route provides a full audit trail of e-notifications receipts for transparency, security, and visibility into data sharing. That way, hospitals only need to maintain one outbound ADT feed. Route handles all outbound ADT data feeds to both providers and Health Information Exchanges (HIE) / intermediaries and all incoming provider requests for e-notifications, which are handled through the Route Requester Portal. Hospitals are further assured to achieve immediate compliance with the post-acute providers and primary care groups who receive our ADT e-notifications. In fact, if a Route customer is ever found to have ADT E-Notification CoP deficiencies during a CMS survey because of Route, we will deploy a compliance expert onsite to help the hospital resolve the issue and develop the required corrective action plan within 10 business days, at no cost. The solution’s audit trail enables hospitals with:

• Searchability by unique patient identifiers to demonstrate compliance during a CMS survey of random patient record reviews • At-a-glance view of data sharing at a national level • Written Route policies and procedures document for use in CMS surveys

Route also ensures complete E-Notifications CoP compliance and offers increased IT operational efficiency. Here’s our checklist for guaranteeing hospital compliance: ▫ E-notifications for requesters on our national network ▫ Requester portal to manage all incoming e-notification requests from community providers ▫ E-notifications to PCPs and other patient-identified practitioners ▫ Audit reporting with policies and procedures documentation ▫ Intermediary ADT data management to increase operational efficiency

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THE ROUTE TO COMPLIANCE: WHAT’S NEXT • 13


SECTION 2B

Route in Action Route Handles All ADT E-Notifications to PatientIdentified Providers The CMS provider agreement is critical for hospitals as it determines whether they can receive Medicare reimbursements, which often make up more than 50% of a hospital’s payer mix. Route supports hospitals across the nation in identifying a compliance solution for sending e-notifications for inpatient admissions, discharges, and transfers, and ED presentations and discharges. Below are some details on how Route works to ensure complete E-Notifications CoP compliance and offer increased IT operational efficiency:

• Providers are identified during the hospital encounter: Patient (or patient record) identifies what provider(s) should be notified in the hospital EHR/registration system • We match the identified provider(s) to our national directory: Patient encounter data, including patient-identified provider (National Provider Identifier + other information), is processed and merged with our national database • Primary care providers and other identified providers receive direct messages: E-notifications are sent to the patient-identified provider(s) in real time and are logged for audit reporting • Recipients of Route e-notifications can choose their desired notification format: web app, SMS alerts, email alerts, HL7 integration, or data download • The numbers:

• 56 Route customers • Since 3/1/2021, Route hospitals have shared data on: • Over 1 million patients • Over 1.5 million encounters (care visits) • Over 3 million encounter events

14 •

CoP COMPLIANCE

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Here’s a closer look at how our interoperability ADT e-notification switchboard works. Route provides a single, centralized solution to guarantee E-Notifications CoP compliance.

HL7 ADT Rosters

Health Systems, Hospitals and EHR Systems Hospital 1 EHR System A Hospital 2 EHR System B Hospital 3 EHR System C Hospital 4 EHR System D

HL7 ADT Feeds

Aggregated HL7 ADT Feed(s)

Route Hospital ADT Consumption

Providers Real-Time Notification Delivery GS

Health System Interface Engine

Attribution Engine (Rosters and ADT Driven) Patient/Provider Matching HL7 Translation to Delivery Format Notification Delivery

PIN

Bamboo Health Network Community Provider Orgs

DIRECT WEB APP

DI

RE CT

ME

SS AG E

Health System HL7 ADT Data

Non-Network Community Provider Orgs Individual PCPs and Practioners CommonWell HIEs

Provider Request Fulfillment Audit Trail

VIEW LARGER

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THE ROUTE TO COMPLIANCE: WHAT’S NEXT • 15


SECTION 2C

Route in the News Want to learn more about how Route is working with healthcare institutions? Check out a recent press release and use case spotlight below.

STAMFORD HEALTH News We announced an expanded partnership with Stamford Health, a non-profit independent healthcare system committed to caring for its community through a wide range of high-quality health and wellness services, and the only hospital in Fairfield County to receive a grade of A from The Leapfrog Group and CMS 5-star ratings. Learn how Route is helping Stamford Health promote the delivery of timely and patient-centered care. Stamford Health Chooses PatientPing’s Route Solution to Achieve E-Notifications CoP Compliance Under CMS’s Interoperability and Patient Access Rule

READ FULL PRESS RELEASE

ELEANOR HEALTH Use Case Spotlight We sat down with Ben Hall, SVP, Head of Product Strategy and Alex Piersiak, Director of Marketing, Member Growth and Engagement from Eleanor Health to discuss how their team approaches care coordination in a value-based care world, challenges they face in this endeavor, and how we help them improve patient outcomes. How Eleanor Health Utilizes our Real-Time ADT Notifications to Proactively and Promptly Engage Members and Coordinate Care

READ FULL SPOTLIGHT 16 • THE ROUTE TO COMPLIANCE: WHAT’S NEXT 16 •

CoP COMPLIANCE

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SECTION 3: LOOKING AHEAD AND PLANNING FOR FUTURE COMPLIANCE REQUIREMENTS

A Stepping Stone for the Future of Care Coordination? Learn What the E-Notifications CoP Rule Signaled About the Future of E-Notifications and How Compliance Requirements May Evolve As a paramount healthcare IT rule, the CMS Interoperability and Patient Access final rule’s ultimate intent is to further overall healthcare interoperability. Among the many provisions focused on achieving this objective, the E-Notifications CoP signals a range of implications for the future of e-notifications and how compliance requirements may evolve. On May 7, 2021, CMS published its Interpretive Guidance for the ADT Notifications for Hospitals CoP from the Interoperability and Patient Access final rule, which included guidance for six provisions within the CoP. The sections below detail some key takeaways from CMS’s Interpretative Guidance to watch out for, and what they may indicate for the future of care coordination.

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THE ROUTE TO COMPLIANCE: WHAT’S NEXT • 17


SECTION 3A

Different Entities of Care Real-Time Data Sharing as Essential Component Care Coordination

As noted in section 1A, CMS’s Interpretative Guidance strengthened their previous language from hospitals needing to make a “reasonable effort” to send notifications to applicable providers and entities, to hospitals needing to make “every attempt” to send notifications: “The hospital is expected to make every attempt to send notifications of the patient’s status to all applicable post-acute providers and suppliers, in addition to the patient’s primary care practitioner, primary care group, or other practitioner or group that is identified by the patient that may be responsible for the patient’s care (pg. 4).” While this provision is focused on hospitals, it subsequently has impact for a variety of providers and ACOs within the healthcare ecosystem. Based on the Interpretive Guidance, hospitals need to ensure that they are making every attempt to successfully send e-notifications to applicable providers and entities that need the information for treatment, care coordination, or quality improvement activities. This indicates a push toward real-time data sharing as an essential component to the successful care coordination of patients.

18 • CoP COMPLIANCE

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SECTION 3B

Accountable Care Organization (ACO) Distribution Lists A Precursor to E-Notifications Sent Based on Attribution Lists?

CMS included language within the Interpretive Guidance that acknowledged ACO attribution lists (i.e. rosters), but did not go so far as to say that hospitals had to send notifications based on them: “This requirement does not limit the hospital’s ability to notify additional entities based on hospital policy, such as ACO attribution lists (pg. 4).” CMS also reiterated in the Interpretive Guidance that nothing in the CoP restricts a hospital’s ability to share information in accordance with its current data sharing policies to anyone else who is permitted legally to receive that information. In line with this, CMS specifically called out the permissibility of including notifications to an ACO via an ACO attribution list, which is essentially a roster. Based on this Interpretive Guidance, CMS has made it very clear that they understand that certain organizations use attribution lists, and that hospitals are permitted to share with these organizations based on the lists. While this represents a starting point, the fact that ACO attribution lists were expressly named in the guidance indicates a clear stepping stone toward the use of attribution lists. As a result, we could likely see a future where e-notifications may be sent based on attribution lists. This trend will likely continue as the need to share information with an increasing number and type of entities and providers expands over time. With our solutions, hospitals and health systems can make sure their organizations are in compliance with the CoP as it stands today, and make sure that they are prepared for and in compliance with future scenarios as well.

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THE ROUTE TO COMPLIANCE: WHAT’S NEXT • 19


SECTION 4: THE PROMISE AND VISION FOR INTEROPERABILITY AND THE DELIVERY OF WHOLE PERSON CARE - PATIENTPING + APPRISS HEALTH IS NOW BAMBOO HEALTH

Introducing New Levels of Visibility with E-Notifications Moving Beyond the E-Notifications CoP Toward Interoperable Care Coordination In recent years, there have been numerous changes to the interoperability and valuebased care landscape, with new rules proposed and finalized, innovation models created and phased out, and directional changes in the industry favoring a focus on care coordination. With rules from Office of the National Coordinator for Health Information Technology (ONC) and CMS, and updates from CMS and the Center for Medicare and Medicaid Innovation (CMMI), the industry continues to rapidly evolve. By requiring hospitals to send real-time e-notifications at the point of inpatient admission, discharge, and transfer, and e-notifications at ED presentations or discharges via the CoP in the Interoperability and Patient Access final rule, CMS took a step forward to ensure that all providers will ultimately have access to timely information to further care coordination. The result is an advancement toward the growth of value-based care delivery models and increased interoperability across the care continuum, with each of the two further driving the other. While much may change in the coming years, care coordination remains at the heart of both sides of this equation. Sharing real-time information via ADT events about patients’ care encounters across providers introduces new levels of visibility for respective care teams, to drive: • Reduced ED utilization • Prevention of hospital readmissions • Avoidance of unnecessary procedures and tests • Elimination of medication errors • Treatment of behavioral health problems holistically • Identification and management of social determinants of health

Watch our webinar on harnessing interoperability for success to learn more! WATCH THE WEBINAR

20 • CoP COMPLIANCE

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SECTION 4A

Why Bamboo Health? How the Combination of Proven Care Collaboration Leaders, PatientPing and Appriss Health, Enables Care Coordination for Whole Person Care Following our May 2021 announcement that PatientPing and Appriss Health would join forces to substantially improve how healthcare is delivered in America, we’re continuing to live up to our promise. As Bamboo Health, we are singularly focused on changing the potential for whole person care into a reality. Technology such as our Route solution for ensuring that hospitals achieve compliance with the CMS E-Notifications CoP is just the beginning. We deliver a wide range of technology solutions that enable the healthcare ecosystem to have insight into and understanding of all the issues that an individual is dealing with to prioritize and coordinate care plans, ensuring health outcomes are the best that they can possibly be. The solutions we are delivering facilitate exactly that. No matter who the provider is, no matter what the care setting is, they can look at the individual as a whole person and uniquely coordinate how they are going to care for that patient. This technology, paired with our expansive national footprint, arms healthcare providers across the country with a greater view into all of the conditions that an individual is managing. Not only does this allow for providers to better prioritize and coordinate care plans, but it also enables improved patient health outcomes—regardless of the provider or care setting. A whole person view that powers whole person care.

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THE ROUTE TO COMPLIANCE: WHAT’S NEXT • 21


ABOUT BAMBOO HEALTH Bamboo Health (formerly known as Appriss Health + Patient Ping) is a healthcare technology solutions company, focused on fostering care collaboration and providing information and actionable insights across the entire continuum of care. As one of the largest, most diverse care collaboration networks in the country, our technology solutions equip healthcare providers and payers with software, information, and insights to facilitate whole person care across the physical and behavioral health spectrums. By serving 2,500 hospitals, 7,800 post-acute facilities, 25,000 pharmacies, 37 health plans, 45 state governments, and over one million acute and ambulatory providers through more than 500 clinical information systems electronically, we impact over 1 billion patient encounters annually in provider workflow. Health systems, payers, providers, pharmacies, governments, individuals, and other organizations rely on Bamboo Health to improve care and reduce cost. Visit www.BambooHealth.com to learn more.

BAMBOOHEALTH.COM • SOLUTIONS@BAMBOOHEALTH.COM

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