March 17, 2006 - British Columbia



March 11, 2014

ATTN: Ministry of Social Development and Social Innovation

RE: Disability White Paper Submission from Together Against Poverty Society (TAPS)

Thank you for initiating and conducting this important discussion on increasing accessibility for persons with disabilities in British Columbia. TAPS has been working with some of the most vulnerable, low-income persons with disabilities in British Columbia for 25 years. As such, you will find our submission is a thorough assessment of the types of legislative and policy changes that would primarily benefit and increase accessibility for the vulnerable individuals we serve. For each issue we described the challenge and offered a potential recommendation. It is important to note that these issues are not listed in order of importance. Please feel free to contact us at any time for further clarification.

Index

• CPP-D/PWD – Disabilities benefits, a two-tiered system

• Definition of Spouse

• Community Volunteer Supplement

• PWD application

• PPMB

• Dental services for people with disabilities

• Hardship/Lifetime Ban

• Monthly Nutritional Supplement

• Asset Exemption

• Reconsideration Supplement

• Family Maintenance Enforcement Payment Clawback

• Shelter Support Minimum

CPP-D/PWD – Disabilities benefits, a two-tiered system

Challenge:

British Columbia has a two-tiered system for persons with disabilities. A person living with disabilities, who applied for and was found eligible to receive a Canada Pension Plan-Disability (CPP-D) amount over the provincial persons with disabilities (PWD) amount before applying for PWD is not eligible for Medical Services Only (MSO). This can cause extreme hardship as it leaves that person without extended health coverage, a vital necessity for persons with disabilities.

CPP-D amounts are based on the amount of contributions one has made to the system through their work in paid employment. The longer you worked, the more you contributed, the bigger the monthly amount you will receive. The current system penalizes those people who worked the longest.

Recommendation:

Medical Services Only (MSO) should be available to both provincial PWD recipients and federal CPP-D recipients.

Definition of Spouse

Challenge:

If a recipient of ministry assistance decides to cohabitate with an individual for 3 months consecutively or 9 of the previous 12 months, and their relationship to the individual with which they reside, demonstrates both social, familial and financial dependence or interdependence consistent with a marriage-like relationship, then ministry staff may determine them to be in a marriage-like relationship, negatively impacting the individual(s) level of status or support.

The effects of this determination can result in several outcomes. Once the ministry determines that two individuals are living in a marriage-like relationship, the income and assets of both individuals must be assessed when determining the level of support that the ministry will provide. If the combined income of the two individuals is beneath the ministry support rate and asset exemptions, then the two will continue to receive ministry support at a reduced amount then they would be eligible for if treated as separate individuals. For example, two individuals receiving basic income assistance would receive $877.22 per month if found to be spouses instead of $610.00 each or $1220.00 for the household. Alternatively, the ministry may determine that the income or assets received by one individual are above the allowable level resulting in the discontinuance of assistance to the individual who was receiving assistance. This essentially forces dependency onto the individual that they would otherwise not choose and can lead to significant exploitation within the home.

Contrasting the ministry definition of spouse with definitions found in other provincial legislation is telling. For example; the Family Act, s. 1, Wills Variation Act, s. 1, Estate Administration Act, s. 1, Family Compensation Act, s. 1, Cremation, Internment and Funeral Services Act, s. 1, Workers Compensation Act, s. 1, Pension Benefits Standards Act, s. 1, Property Transfer Act, s. 1, Home Owner Grant Act, s. 1, Notaries Act, s. 58 and the Forest Act, s. 53(1), all require a 2 year cohabitation period to determine spousal status.

When it comes to those reliant on income support, the time period for determining spousal dependency is in sharp contrast to other areas of law. The three-month requirement in MSDSI’s legislation is highly anomalous and leaves the impression that the inconsistency is designed to target people living in poverty of disadvantageous treatment.

The test of whether or not an individual is financially or socially dependent on their cohabitant, consistent with a marriage like relationship, is often construed by ministry staff in questionable ways. For example, a roommate assisting their co-tenant in and out of a bath tub could serve as evidence of social and familial dependence consistent with a marriage-like relationship. Another not uncommon example is where two roommates share hydro and phone bills, which is then found by ministry staff to be demonstrative of a financial dependence consistent with a marriage-like relationship.

It has been the experience of TAPS advocates that Ministry staff routinely apply the lawful definition of spouse in the strictest of terms failing to allow for discretion, adding to the negative impacts wrought by this discriminatory legislation. The impact can be immediate and dramatic. Clients are forced to depend on past abusive spouses, are cut off assistance when an alleged spouse refuses to be subjected to income testing, are rendered homeless, forced to acknowledge a heterosexual relationship when they identify as homosexual, and lastly make decisions regarding personal relationships based on their need to survive instead of whom they choose to share their lives with. It is against this back drop that TAPS Advocates have assisted a good many individuals to avoid hardship through appeals and direct advocacy.

Recommendation:

Amend the legislation so it matches the BC Family Law Act definition of spouse.

Community Volunteer Supplement:

Challenge:

1. Rates are too low and volunteering costs money. Together Against Poverty Society (TAPS) has long argued that the community volunteer supplement was an extremely important program that directly benefitted persons with disabilities by providing them with the financial means to participate in a meaningful way in their communities. In a time when the PWD rates have not increased since 2007, yet the cost of living continues to grow, the CVS was a targeted way of providing money to persons with disabilities who were contributing to their communities by participating in volunteer work.

2. No ability to appeal. The CVS is now guided by the Supply Act, as a result there is no ability to appeal decision related to their CVS. This is detrimental to those CVS recipients who have been wrongfully cut off or otherwise denied their benefit. Persons with disabilities who continue to receive the CVS

3. Mobility. Currently, a CVS recipient is not permitted to change volunteer positions and continue to receive the CVS. This can result in negative relationships between organizations and volunteers and volunteers who have no flexibility or autonomy with regards to where they volunteer.

Recommendations:

1. Reinstate the CVS.

2. Implement a method of appeal for CVS recipients.

3. Allow CVS recipients to change volunteer positions if they choose.

PWD application:

Challenges:

1. Length. The PWD application is unnecessarily lengthy due to repetition. For instance, at page 11 there is a question about restrictions to basic mobility, at page 10 there is a question about how far the applicant can walk, and at page 15, there is a question about restriction to the applicant’s mobility. Applicants and doctors often express their frustration due to the cumbersome nature of the application.

2. Requirement that a person has to apply for Income Assistance first. The fact that one has to apply for income assistance in order to apply for PWD is cumbersome, unnecessary and often results in confusion and disentitlement for applicants. Furthermore, applicants who are not seeking income assistance are currently waiting months to merely begin the PWD application process.

3. Retroactive payments to date of application. When a person applies for and is approved for PWD, their application reflects their condition at the time they submitted it, i.e. they were disabled on the date of application. PWD benefits should be retroactive to the date of application.

4. The burden on doctors: Sections two and three of the PWD application are to be completed by a doctor with whom that applicant has developed a rapport. This poses a difficulty for many applicants who seek medical assistance at walk-in clinics due to the shortage of general practitioners. Clinic doctors often lack the necessary rapport with applicants to be able to ethically and accurately describe an applicant’s disability. Doctors who have enough of a rapport to represent an applicant often find the form itself to be too lengthy. In fact, certain physicians have asked non-profit organization, including TAPS, to complete a template application which they may use to provide the relevant information in a timelier manner.

5. Unclear language: The use of certain prescribed terms and the different interpretations of these terms by doctors and lay people have complicated how information is presented in the PWD application. Specifically, the use of ‘continuous’ and ‘periodic’ are difficult to distinguish with respect to chronic conditions. For example, certain conditions may be relatively stable for periods of time but become exacerbated unexpectedly for unknown periods, making it difficult to determine when periodic becomes continuous in terms or impairment or disability. Furthermore confusion has arisen from attempting to distinguish ‘needs’ and ‘requires’, with respect to assistance. Many applicants do not have access to the services they require to complete daily activities; however, they manage to barely survive with what is available to them. By barely surviving, these people are considered not to require the services that would allow them to live with fewer daily struggles.

6. Adding ‘Employability’ as a Daily Living Activity: While it is certainly beneficial to maintain a definition of PWD as inclusive of restrictions to performing ADL’s it can become a major barrier to approval of the designation to those most in need when employability is not part of the test. This is most challenging as medical professionals incorrectly believe that PWD is tested on employment, leading applications to be foiled by physicians/assessors who stress employability throughout the application. We believe that if employability were considered as just one of a number of other daily living activities it would give a more fulsome and accurate picture of the applicant.

Recommendations:

1. Length: Remove redundancies within the application.

2. Requirement that a person has to apply for Income Assistance first. A completely separate or expedited assessment of income assistance eligibility for those seeking only PWD could improve the PWD application process tremendously. An expedited process would assist the Ministry as fewer appointments would be required and resources could be directed to those applicants actually seeking income assistance. Reducing the process by months would also be beneficial for the health of those applicants who seek special and immediate medical attention.

3. Retroactive payments to date of application: Provide retroactive payments back to date of application.

4. The burden on doctors and unclear language: Reorganizing the PWD application form with a focus on removing repetitive questions could help clarify discrepancies in language and help make the process less cumbersome for doctors. For instance, the form should consistently use either ‘needs’ or ‘requires’. If both terms need to be used, then they should be clearly defined so that doctors can best express themselves to assist the Ministry.

5. Adding ‘Employability’ as a Daily Living Activity: We recommend the following amendment to The EAPWD Regulation;

Daily living activities

2 (1) For the purposes of the Act and this regulation, "daily living activities",

(a) in relation to a person who has a severe physical impairment or a severe mental impairment, means the following activities:

(i) prepare own meals;

(ii) manage personal finances;

(iii) shop for personal needs;

(iv) use public or personal transportation facilities;

(v) perform housework to maintain the person's place of residence in acceptable sanitary condition;

(vi) move about indoors and outdoors;

(vii) perform personal hygiene and self care;

(viii) manage personal medication, and

(ix) searching for and/or maintaining employment

(b) in relation to a person who has a severe mental impairment, includes the following activities:

(i) make decisions about personal activities, care or finances;

(ii) relate to, communicate or interact with others effectively.

PPMB - Persons’ with Persistent Multiple Barriers to Employment (PPMB)

Challenge: The PPMB category is a category that fails to offer real support for some of the most marginalised ministry clients.

An individual who demonstrates that they are incapable of searching for or maintaining employment can become eligible for PPMB after being in receipt of income assistance for 12 months and demonstrating that they are unemployable. If the individual meets this test they are then able to benefit from an extended employment earnings exemption of $500.00. Proving that the client is completely unemployable nets the client an increased benefit from performing a task that they have demonstrated they are unable to perform.

In addition they receive a modest increase in income support ($610.00 to $657.92).

While it is true that many people do find a modest benefit from this designation it must be said that these clients, in our experience, are often in need of the more substantial support offered by PWD designation. Unfortunately, these clients can be barred from PWD eligibility as they are capable of many ADL’s while incapable of any form of meaningful employment.

In practise, many TAPS clients who are eligible for PPMB are some of the most marginalised clients, often homeless and unsettled with very little connection to social or medical supports. These clients are typically unable to build a long term relationship with medical professionals and can be in self-denial of their level of restriction to independent function. More and different support is required for these clients including a supportive and clear path to PWD.

As of today’s date the ministry has failed to take any documented action on 6 separate adopted recommendations from the Ombudspersons 2009 report.

Recommendations:

To address the challenges with this designation we make the following recommendations;

1. Take immediate steps to implement the recommendations made in the 2009 Ombudspersons Report

Dental services for people with disabilities

Challenges:

Many people with disabilities who are unemployed, or employed at low wage jobs (the “working poor”), neither have money to pay for dental care nor the funds to pay for dental insurance. These adults often struggle just to pay the rent and feed the kids – in this context, regular teeth cleaning or other preventive dental care is an unaffordable luxury item, and so is dental insurance.

This situation is common to all income assistance recipients, but affects people with disabilities more severely due to multiple and reinforcing health challenges.

The current support regime for dental care has significant flaws. It’s clear that the dental benefits provided by the MSDSI are not sufficiently enabling access for this vulnerable population.

A key barrier for PWDs seeking dental care is the discrepancy between fee guides. MSDSI’s fee schedule is approximately 70 percent of the fee guide developed by dentists. While the BC Dental Association’s fee guide is reviewed and increased annually, MSDSI’s fee guide is negotiated with the dental profession but increased less frequently – resulting in increasing discrepancies over time.

The most detrimental outcome of this disparity is dentists in private practice refusing to accept patients who are on welfare due to the reduced fees received for their services. TAPS staff often hears reports that even when dentists accept patients receiving benefits, they make the patient pay the difference between the BC Dental Association fee guide and the amount paid by benefits, referred to as balance billing. In all of these cases, the result is the same: the patient cannot access treatment.

Even where dentists practice “charitable dentistry” and accept PWD patients without demanding that the patient pay the extra costs to match the BCDA fee guide, it’s clear that the charity model is not an acceptable approach to ensuring dental health for people with disabilities in British Columbia. This is another case where denying the benefit now will often lead to much more expensive medical interventions later, thus eliminating any notional cost savings from the restrictive dental coverage offered by MSDSI.

Recommendation:

TAPS urges MSDSI to work with the BCDA to establish a clear and consistent fee guide that ensures that all income assistance recipients get access to quality dental care in every community in British Columbia.

Hardship/Lifetime Ban

Challenge:

Income Assistance is the payer of last resort for those unable to obtain, or who are in-between, other sources of income. This is recognition that in a civil society, ostracizing someone with no means of support is a certain recipe for social disorder and crime. While it may be tempting to consider those who have committed fraud against the income assistance system as undeserving of further assistance, the reality is that these actions may often have been rooted in mental illness, or substance addiction. We have seen cases precisely like this, where a devastating life-time ban has been upheld at tribunal, and vulnerable individuals have been cast adrift by the system in punishment for fraudulent activities that were clearly related to the health conditions noted.

The ministry’s current policies with respect to administering hardship assistance to individuals who have been convicted of fraud, creates a significant threat to the health of some of the most marginalized members of our community. We also suggest that the legislation that provides for Hardship Assistance in these circumstances fails to adequately capture those in desperate need of income support.

Recommendations:

Firstly we recommend that the Life Time ban from income assistance be repealed from the legislation entirely. Failing the adoption of this first recommendation we propose the following;

We recommend that the ministry amend policies and procedures to better accommodate people who have received a criminal conviction, to obtain Hardship Assistance where a lifetime ban has been applied to their eligibility for regular income assistance support. At present ministry staff, in practice, require that an applicant for hardship assistance, under a life time ban for conviction, demonstrate that they are faced with an imminent threat to their physical health that necessitates income support. Section 42.1(2)(b) of the EAPWD Reg. holds that an applicant for HA under a life time ban need only demonstrate that they “will experience undue hardship, and the physical health of a person in the family unit will be in imminent danger” (emphasis TAPS). Where policy and legislation contradict, the regulation must prevail and to this end we suggest that the ministry amend its policy to reflect the intent of the legislation.

By policy, the ministry requires that individuals who qualify for HA with a conviction must verify month-by-month that they continue to face an imminent threat to their ongoing physical health. We suggest that the policy be amended to allow for, at the very least, a six month renewal period. It is our experience that individuals who are living with severe physical and cognitive challenges, face unnecessary and undue hardship re-establishing threat to health, leading to gaps in income support putting health and housing at risk. Physicians and medical professionals have expressed to TAPS advocates that they are often burdened by monthly requests from patients to provide letters to the ministry staff while their patients are under threat of eviction as the ministry withholds support prior to re-confirming the imminent threat criteria.

Lastly we submit that Section 42.1(2)(b) of the regulation be amended as follows;

Family units ineligible or declared ineligible in relation to convictions or judgments

42.1 (1) In the circumstances described in subsection (2), the minister may provide hardship assistance to a family unit that under section 14 (5) (a) [consequences for conviction or judgment in relation to Act] of the Act is not eligible for disability assistance because it includes only

(a) persons convicted of an offence under the Criminal Code, this Act or the Employment and Assistance Act in relation to obtaining money under this Act or the Employment and Assistance Act by fraud or false or misleading representation,

(b) persons convicted of an offence under this Act or the Employment and Assistance Act, or

(c) persons in respect of whom

(i) a court has given judgment in favour of the government in an action for debt for obtaining disability assistance, hardship assistance or a supplement under this Act or income assistance, hardship assistance or a supplement under the Employment and Assistance Act, for which he or she was not eligible, and

(ii) the minister has made a declaration under section 14 (3) of the Act.

(2) The minister may provide hardship assistance to a family unit described in subsection (1) if the minister considers that otherwise

(a) the family unit will experience undue hardship, and

(b) the mental or physical health of a person in the family unit will be in imminent danger.

Monthly Nutritional Supplement

Challenge:

While the Monthly Nutritional Supplement (MNS) does provide a bare minimum of support to those PWDs who qualify for the benefit, there are fundamental design flaws that prevent many of the people who most need this support from receiving it in a timely manner. In practise TAPS advocates rarely witness clients become eligible for this supplement where it is most needed.

In effect, the MNS as currently structured only provides support to those whose life is in imminent danger if they do not increase their caloric intake, and thus often triggers additional health costs which would be preventable if this support was available when the individuals’ health situation is less severe.

The Dieticians of Canada – BC Region found that in 2011, the provincial average cost to feed a family of four was $868.43 per month. Those earning minimum wage, receiving income assistance, or facing other challenges (high rents, child care, or transportation costs, for example) struggle to find ways to purchase food as well as meet their other basic needs.

The connection between hunger and poverty is obvious and requires no explanation. Obviously, families who are struggling to meet core nutritional needs will not have the resources to pursue educational opportunities or pursue gainful employment. To deny critical nutritional support to all but the most severe cases is both cruel and self-defeating; it costs society, government and most important, families in poverty far more than a program based on prevention and keeping poor families well-fed and healthy.

Recommendation:

The MNS program as designed is an affront to the dignity of people with disabilities. It needs to be reformed to be part of a continuum of support for the nutritional health of people with disabilities. Specifically, the MNS should be made available before the dietary condition of the individual becomes life-threatening, and should not be denied if the applicant can demonstrate that her family unit is not willing or able to provide the necessary caloric content. The MNS should be modified to provide for nutritional wholesome foods not simply for additional caloric intake as this is what health professionals are seeking when completing the MNS application.

Asset Exemption

Challenge:

Under section 12 of the Employment and Assistance for Persons’ with Disabilities Regulations, PWD applicants/designates may exempt funds held in trust(s) up to an aggregate value of $200,000 while maintaining income support in consideration of the asset exemption level for the family unit.

This means that families living on as low as $906.42 per month can hold assets in trust for the purposes of increasing independence in the community, paying for disability related upgrades to the home and various other medical treatments/devices.

Without the benefit of a financial vehicle to exempt cash assets, many in need are required to deplete their financial resources to a significant degree resulting in hardship to the individual and their families. TAPS has been successful in providing free, accessible, and effective support to individuals in establishing TFSA accounts as non-discretionary trusts and in doing so has developed policies and procedures to ameliorate some of the challenges presented by ministry policy with respect to asset exemption. Victoria is the first community in BC to establish TFSA accounts as non-discretionary trusts for the purposes of asset exemption and with funding support hopes to expand this service to other communities across BC. Despite our work in this area we continue to experience challenges with frontline ministry staff that could be resolved through simple policy reforms.

TAPS Advocates have long experienced that few clients are able to adequately access the support necessary to make use of trust exemptions for various reasons. Ministry staff cannot provide advice on establishing a trust yet in our experience wrongfully advise clients that certain types of trusts, TFSA Accounts for example, do not meet the definition of a trust. Ministry staff often fail to adequately advise clients that discretionary or non-discretionary trusts may be an effective vehicle for asset exemption with the unfortunate result being that many clients deplete, unnecessarily, life time savings that could be used for disability related costs.

Recommendations:

Establish better training around asset exemption for ministry staff. Much of the challenges around asset exemption could be resolved if ministry staff were more aware of the meaning and effect of trusts as a vehicle for asset exemption.

Establish a policy whereby ministry staff advise clients that they may not require a lawyer in all cases to establish a trust and refer clients to Law Foundation funded community advocacy organizations for assistance.

Reconsideration Supplement

Challenge:

It is the experience of TAPS advocates that persons’ dependent on the reconsideration supplement for survival, face an erosion of statutory entitlement as a result of MSDSI policies and procedures. It is our belief that these policies and procedures create a violation of the basic principle of administrative fairness, adopted by the ministry, that hold that a complainant be given a full and fair opportunity to present their case to the decision-maker.

The ministry may give a reconsideration supplement to a family unit that makes a request for the supplement under Section 79 of the Regulation, How a request to reconsider a decision is made, if the client has received a decision that has resulted in the discontinuation or reduction of income assistance or a supplement. Clients are required to repay the amount of the reconsideration supplement if the reconsideration decision finds against them and must sign a repayment agreement to this affect.

Section 79 also directs that a person requesting a reconsideration supplement must return the reconsideration form to the ministry within 20 business days, in person or by post, and must sign an agreement to repay any support received if the reconsideration determination finds against that person.

The Regulation does not require that the reconsideration form be completed before it is returned to MSDSI. The Regulation does not provide that a requestor must forgo the remaining 20 business days from the date that the form is returned.

Despite the clear direction provided in the Regulation ministry clients requesting a reconsideration supplement are required by ministry staff to forgo the remaining days left in the 20 business day appeal period in order to be deemed eligible for the reconsideration supplement.

It is the experience of TAPS staff that ministry staff typically advise clients requesting a reconsideration supplement that they can request a 10 business day extension period to allow for additional time to submit evidence. However, this action does not remedy time lost in the initial appeal period and gives the effect of limiting the period without legislative authority to do so.

The overall effect of limiting the initial appeal period results in the erosion of the clients’ ability to access a full and fair period to present evidence in support of their position. Further, clients who are dependent on immediate financial support through the reconsideration supplement may be inclined to give up a portion of the appeal period as they are faced with imminent threats to security of the person like shelter and food.

Recommendation:

The ministry procedure states the following with respect to the return of the reconsideration form (HR0100);

“Before issuing the supplement, ensure the recipient has completed and returned the HR0100 (emphasis added).”

We recommend amending the policy to state the following;

“Before issuing the supplement, ensure the recipient has signed and returned the HR0100. Advise the recipient of the outstanding time remaining in the appeal period. Provide a copy of the HR0100 to the recipient when necessary.”

The above recommendation would ameliorate the challenges while allowing for a full and fair opportunity for ministry clients to present their positions. This change would respect the relevant legislation while serving to uphold basic principles of administrative fairness

Family Maintenance Enforcement Payment Clawback

Challenge:

MSDSI requires that all recipients pursue any potential income, this means that parents who are receiving any form of income assistance are required to assign their child support rights over to MSDSI as a condition of welfare eligibility. The result is that the provincial government is depriving children of their right to child support by taking that money away from children who live in low income single parent families – some of the most vulnerable children in the province. In fact, many vulnerable families are getting only minimal or partial financial support for their children via MSDSI, yet the Ministry deducts child support from the benefits it pays out, regardless of the amount of that support. Low-income families are struggling to feed their children and provide the basic necessities and this is one of the reasons why.

Recommendation:

Immediately discontinue the practice of clawing back child support payments from income assistance recipients, as those are the very children that need the support the most.

Shelter Support Minimum

Challenge:

In April of 2010 the Legislature repealed the regulation that provided a $75.00 shelter minimum for homeless income assistance and PWD recipients. The rational provided at the time was that removing the shelter minimum would assist people dependent on ministry support to obtain housing and self-sufficiency. It is our view that this rationale has not been realised by homeless income assistance or PWD recipients.

It has been the experience of TAPS staff that homeless PWD recipients face some of the steepest challenges in the province with respect to finding adequate shelter and employment leading to self-sufficiency. The removal of the $75.00 shelter minimum had the effect of increasing the desperation experienced by homeless and disabled ministry clients and in no discernable way assisted them to find housing or become self -sufficient.

The $75.00 shelter minimum was used by ministry clients to pay for memberships to gym facilities where they could shower and practise basic hygiene, for short accommodation in hotels or hostels to get warm and clean, camping equipment, warm clothing for outdoor sleeping, to pay for couch surfing at the homes of acquaintances, and for food. This money was used to improve the general security of the person which in turn helped keep homeless disabled people closer to improving their life circumstances and moving toward self-sufficiency.

Recommendation:

Restore the $75.00 shelter minimum for all ministry recipients or at the very least restore the shelter minimum to PWD recipients

On behalf of TAPS, board, staff and volunteers, we want to thank you for providing TAPS and people across British Columbia with this formal opportunity to submit their thoughts and recommendations for making British Columbia the most progressive place on earth for all persons with disabilities. We look forward to the summit in June and the release of the White paper which reflect some of these much needed changes.

Sincerely,

Kelly Newhook

Executive Director, TAPS

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