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1 Supplemental Materials AGENDA ITEM VII-D Consideration of adopting the Commissioner s recommendations relating to authorization of baccalaureate degree programs at public community colleges (S.B. 414, 83rd Texas Legislature, Regular Session) RECOMMENDATION: Approval Background Information: Staff recommendations were presented for discussion to the Committee on Affordability, Accountability and Planning (CAAP) at the meeting on June 25, At that time, the recommendations had not been distributed for comment from interested stakeholders. After the meeting the staff recommendations, modified to include Committee comments, were distributed to all the public and private institutions within Texas for comment. The comment period ended on July 16, Included in the supplemental material is a summary of the comments grouped by subject with a staff response. A copy of each comment received is also attached along with a presentation on the Commissioner s recommendations relating to authorization of baccalaureate degree programs at public community colleges. 07/14

2 AGENDA ITEM VII-D Page 1 Summary of responses received from stakeholders on staff recommendations related to authorization of Community College Baccalaureates Responses received from: Sam Houston State University (SHSU); Sul Ross University Rio Grande (SRURG); The University of Texas at Dallas (UTD); Texas Tech University Health Sciences Center (TTUHSC); Texas Lutheran University (TLU); Austin Community College (ACC); Brazosport College (BC), The University of Texas System (UTS); Texas A & M System (TAMUS); Alvin College (AC); University of North Texas System (UNTS); South Texas College (STC); Texas Women s University (TWU); and Tarrant County College District (TCCD). Copies of comments received are attached to this summary. Nursing Comments The availability of online RN to BSN programs offered by universities should be considered. Quality of program and faculty are already established at a university level. (SHSU & TWU) In terms of the nursing program, local hospitals need to be surveyed to see if they would support community colleges offering BA degrees. (SHSU) This will not address the nursing faculty shortage. In fact, it will further complicate it as now additional faculty will be needed for the new programs. The criteria of pass rate on the NCLEX is not relevant to the RN to BSN degree. The Community Colleges need to forge partnerships with universities such as Southwest Texas Junior College has done with Sul Ross Rio Grande College to offer a connected, smooth BSN degree for students. (SRURG) The manner for guaranteeing academic rigor should be prescribed through accreditation by the Commission on Collegiate Nursing Education (CCNE) as it is the industry standard for guaranteeing said academic rigor in BSN programs. (TTUHSC) If the recommendation from the Texas Higher Coordinating Board is to authorize only RN to BSN programs at specific community colleges, the Texas Board of Nursing only approves prelicensure programs so there is some concern related to the oversight of the adherence to these standards of quality at the state level. Authorizing community colleges to offer the BSN will only make it more difficult for existing baccalaureate programs to find qualified faculty, and seriously risk damaging the quality of existing programs. (TLU) The use of applied baccalaureate degrees for nursing runs counter to national trends and research on high standards education for the registered nurse practicing in our complex, dynamic healthcare environment. (TLU) Diploma nurses with the RN certification should be included in the RN to BSN proposal. They will have the same requirements to demonstrate the prerequisite course work and therefore should be allowed to apply to the programs. (ACC) RN to BSN programs are an efficient way to manage clinical sites and make best use of existing nursing faculty resources. (BC)

3 AGENDA ITEM VII-D Page 2 Recommend that the THECB require the community college AND program to have an 85% graduation rate and an 85% pass rate on the NCLEX. (UTS) Staff Response to Nursing Comments In response to the concerns for quality, staff is recommending one additional requirements for the approval of proposals for new RN to BSN degree programs. An existing associate degree nursing program must be accredited nationally or be seeking accreditation. The proposals will be evaluated on the same requirements that exist for general academic institutions; including faculty credentials, available resources, duplication of programs, and capacity of existing programs. One of the guiding principles of the recommendation is Provide multiple pathways for a diverse population to earn an academic credential by expanding baccalaureate degree programs offered by public community colleges in a measured way to address workforce needs in a manner that is cost efficient, prevents unnecessary duplication of programs, and prevents undue competition between community colleges and universities. The recommendation for the use of a graduation rate of 85% is a very high standard. Base on the 2012 graduation rates calculated by the THECB only 11 of the 74 programs at public institutions have a graduation rate at or above 85%. The nursing shortage reduction program uses a graduation rate of 70% as a threshold. Forty-two of the 74 programs met that standard. Shortage of Faculty Comments As the Community Colleges increase offerings, there will also be increased competitions for faculty resources. In addition to pass rate criteria, there should be stated criteria for having faculty with terminal degrees. In the past community colleges have reduced costs by heavily relying on adjunct faculty. Adding such programs to community colleges will make it even more difficult for all schools to recruit and maintain qualified faculty. (SHSU) Staff Response to Shortage of Faculty Comments In response to the concerns for faculty shortage, the timeline presented in the recommendation proposes a study of faculty resources to be completed prior the implementation of new program reviews. In addition new program proposals will be evaluated on the same requirements that exist for general academic institutions; including faculty credentials, and available resources. Competition Comments As part of needs assessment, evaluate online options already in place at universities. Overall, numerous universities have invested in quality online programs. This investment is wasted if there is a proliferation of regional programs at Community Colleges. It may be difficult to establish a mechanism to decide on issues related to need and duplications. (SHSU) We do not have any concerns about offering community college baccalaureate degrees that are targeted to fill applied, job-related needs in fields that are not adequately served at present. The concept strikes me as a good thing for Texas, provided the approved degree programs are carefully thought out, well supported, and of high quality. Like all educational issues in Texas, spreading limited resources too thinly can be counterproductive, but so long as the proposed programs are carefully crafted, there may be real value. My only suggestion is to use the word 07/14

4 AGENDA ITEM VII-D Page 3 "applied" to describe the degree programs everywhere. I think this is consistent with the spirit and helps to differentiate these degrees. (UTD) Universities now have bachelor degrees that track students completing an associate of applied science degree. Many of them are on line making them accessible to any Texas residents. Formula funding is not complete, so this will further erode the higher education funding situation. (SRURG) We recommend the Legislature consider incentives such as those created in the 83rd Legislature to promote new and expanded GME programs within the State. These incentives would encourage all public institutions with nursing programs to enter into more articulation agreements with community colleges. (TTUHSC) Staff Response to Competition Comments In response to the concerns for counterproductive competition, we defer to the guiding principle, Before expanding baccalaureate degree programs at public community colleges, ensure that current programs are fully utilizing existing resources. The recommendation also encourages partnership proposals for new applied science degrees. Student and Tax Payer Concerns Comments Funding mechanisms are very different with community colleges who are provided a local property tax base not available to universities. In the long run local tax payers will pay twice to support baccalaureate programs in the State, a disadvantage to those taxpayers. (SHSU) Offering baccalaureate degrees at Community College will increase cost to students and shift state funds away from existing programs. (UNTS) The increased need for qualified faculty may be a hidden cost for community colleges. Nursing and engineering faculty tend to be high-priced professionals. The financial costs to add such faculty may strain the reserves of the community college and necessitate higher tuition rates. (SHSU) Staff Response to Student and Tax Payer Comments In response to the concerns of financial costs for student and taxpayers; the recommendations call for the THECB to develop a basis for determining duplication of programs including factors such as commute time, capacity, delivery method, and hours of operation. In addition, the recommendations states that current rules for new program approval must be met including: unnecessarily program duplication, adequate faculty resources, good curriculum design, demonstrated workforce need, a critical mass of qualified students available, and adequate financing. There is a concern for students having an affordable path to obtain a bachelor degree. Based on the experience of the three colleges currently offering applied bachelor degrees the lower and upper division costs have risen at a comparable rate to other community colleges. The cost to the student for the BAT degrees is significantly less than available at public universities in the state. 07/14

5 AGENDA ITEM VII-D Page 4 Duplication & Inefficiency Comments If community colleges are granted permission for baccalaureate degrees, will the need for associate s degree continue or will there be a more streamlined 4-year route to degree. This may force colleges to create extra courses to satisfy the needs of both associate and baccalaureate degree tracks. (SHSU) THECB s recommendations do not mention the costs of ongoing operational expenses nor does it address costs related to curriculum issues. To address this cost and to avoid exacerbating shortages of faculty with graduate and terminal degrees, we request your recommendations encourage the systematic and concentrated use of articulation agreements to address expansion needs. (TTUHSC) Applied baccalaureate degrees offered at Community Colleges (CC) be required to meet the same accreditation, licensure, certification and financial adequacy requirement as General Academic (GA) institutions must meet. (TAMUS) The expansion of applied baccalaureate programs at community colleges has implications in terms of quality and cost. (UTS) Suggest adding an investigation of equitability when considering duplication of programs. (ACC) The hallmark of community colleges is responsiveness and the ability to do so in response to local and regional workforce demands. If the process is dependent on a biennium study in order for colleges to meet needs, then that changes their ability to respond in a timely manner. If the ability to move forward is built on looking backward to prove need, then that nimbleness will be lost. (BC & STC) Currently it is not necessary to complete an applied associate s degree to pursue the bachelor of applied technology degree. (STC) Staff Response to Duplication & Inefficiency Comments In response to the concerns of duplication and inefficiency, the recommendation states that current rules for new program approval must be met including: unnecessarily program duplication, adequate faculty resources, good curriculum design, demonstrated workforce need, a critical mass of qualified students available, and adequate financing. The RAND study identified the process that THECB is recommending to identify workforce needs and specifically the need for applied baccalaureate degree programs. The process as described in the study will take into consideration statewide, regional and local workforce needs. Staff proposal recommends that the review and approval of applied bachelor degrees be the same for both universities and community colleges. The recommendation in the proposal submitted to CAAP has been modified to not require the student to have completed the applied associate s degree. Other Comments In general agreement with the Staff Recommendations regarding participation and utilization of existing affiliation agreements and partnerships, we currently utilize these extensively, and will 07/14

6 AGENDA ITEM VII-D Page 5 continue to do so as part of a multipronged solution to the need for Bachelors prepared nurses in our region. (ACC) I have just relocated from the state of Florida where all the community colleges were granted the opportunity to offer baccalaureate degrees. There was some concern at first that the role of the community college would be marginalized, the college would lose sight of its mission, and that the college s focus would move to the baccalaureate degree. That did not happen. Another concern was that we would draw students from the area universities. The data did not indicate this. The average age of our baccalaureate students was 37. Additionally, we did not offer programs that competed with the universities. The programs offered were workforce oriented and required the completion of an associate s degree. There were some issues with regard to which associate s degree could be used for admission into any given program so that needs to be spelled out. (AC) Now that the Coordinating Board is preparing to adopt recommendations related to the RAND Study, it may be time to revisit the legislative statute that limits offering no more than five degree programs at any time. I encourage the Coordinating Board to consider a recommendation that permits the Coordinating Board to determine the number of programs offered based on individual program approval. (STC) Nursing has a significant current demand. Expectations for continuing demand and increasing shortages are great. With TCC s current program in nursing and the partnerships with Tarleton State University, Texas Tech and the University of Texas at Arlington, we provide a strong, much needed pipeline to already existing BSN programs. (TCCD) Staff Response to Other Comments There will be additional study and discussion of the finding of the RAND study that will follow the submission of the study to the legislature. The issues of program limitations, university partnerships, duplication and quality criteria are address in the timeline presented with staff recommendations. 07/14

7 Office of the President July 7, 2014 Gary Johnstone Texas Higher Education Coordinating Board Dear Mr. Johnstone: Texas Tech University Health Sciences Center is pleased to have the opportunity to review the Texas Higher Education Coordinating Board (THECB) Committee on Affordability, Accountability and Planning s draft legislative recommendations regarding the potential expansion of community college baccalaureate programs in Texas. Herein below you will find our comments and recommendations: We agree meeting unmet workforce needs should be a priority. In meeting this need, we believe the quality of baccalaureate programs, in this case BSNs, should not be overlooked. It is noted in the THECB s recommended principles that baccalaureate degrees should be expanded in a manner that maintains or increases academic rigor. The manner for guaranteeing academic rigor should be prescribed through accreditation by the Commission on Collegiate Nursing Education (CCNE) as it is the industry standard for guaranteeing said academic rigor in BSN programs. Quality should not be sacrificed in an effort to provide greater access to BSN programs such as RN-to- BSN. To ensure quality, any new nursing baccalaureate program at a community college must be CCNE accredited. This accreditation insures that a BSN program includes all the essential elements of nursing education that distinguish nursing education leading to the BSN degree. Should community colleges be allowed to offer RN-to-BSN programs without accreditation, we believe the BSN degree will be watered-down to the equivalency of an Associate s Degree in Nursing (ADN). The Institute of Medicine (IOM) Future of Nursing report which calls for 80% of nurses to be BSN prepared by 2020 presupposes that the rigor and standards of the BSN remains high. Research which has shown that care outcomes are far better when care is delivered by BSN nurses is also based on those standards which can only be confirmed through CCNE accreditation. Of additional concern is the fact that community college RN-to-BSN programs would not allow for Interprofessional Education (IPE). IPE opportunities are expected in the education of the future healthcare workforce and are required by national accrediting bodies such as Southern Association of Colleges and Schools (SACS). Providing IPE is a key component towards preparing BSNs for the growing role of nursing in the healthcare workforce th Street STOP 6258 Lubbock, Texas T F

8 Mr. Gary Johnstone July 7, 2014 Page 2 of 2 THECB s recommendations do not mention the costs of ongoing operational expenses nor does it address costs related to curriculum issues. To address this cost and to avoid exacerbating shortages of faculty with graduate and terminal degrees, we request your recommendations encourage the systematic and concentrated use of articulation agreements to address expansion needs. TTUHSC has 20 articulation agreements within the state. We particularly recommend the use of concurrent enrollment articulation agreements. TTUHSC was one of the first universities in the state to offer such an agreement whereby TTUHSC guarantees students admission as long as they complete their first two years at the collaborating community college and meet certain requirements. TTUHSC has concurrent articulation agreements with Austin Community College, Collin Community College and McLennan Community College. We recommend your report suggest the use of incentives by the state to encourage the expansion of articulation agreements between universities and community colleges. Incentives would be far less expensive than BSN CCNE accreditation and much higher operational costs for community colleges. Currently TTUHSC has restricted some aspects of its growth due to the limited supply of qualified faculty with graduate and terminal degrees. Consequently, TTUHSC currently undertakes controlled strategic growth within the RN to BSN program. Our strategic growth calls for a 20% increase each year. With this growth pattern TTUHSC can accommodate students more quickly with existing infrastructure and faculty and at a cost that we anticipate would be less than the efforts of community colleges. TTUHSC also does not receive reimbursement for any expansion until after the legislature meets and passes the budget for the next biennium. Universities need upfront funding to hire additional faculty and provide greater capacity to enter into more articulation agreements with community colleges. We recommend the Legislature consider incentives such as those created in the 83rd Legislature to promote new and expanded GME programs within the State. These incentives would encourage all public institutions with nursing programs to enter into more articulation agreements with community colleges. These partnerships are a win-win and will do the following: 1) Increase capacity at nationally accredited baccalaureate programs within the state 2) Save on cost of starting new baccalaureate nursing programs 3) Ensure quality 4) Increase accessibility to BSN programs for first generation, minority and under-served students 5) Promote greater partnerships among universities and community colleges On behalf of TTUHSC, thank you for the opportunity to provide comments. Sincerely, Tedd L. Mitchell, M.D. President Texas Tech University Health Sciences Center cc: Michael L. Evans, Ph.D., RN, FAAN Dean and Professor, School of Nursing

9 Texas Tech University: Comments on Staff Recommendations Related to Authorization of Community College Baccalaureates Key Consideration Texas Tech University has serious reservations about community college delivery of baccalaureate degrees. The primary mission of community colleges is to provide general education for transfer to four year colleges and universities, and to provide workforce training programs that particularly meet local workforce needs. Baccalaureate degrees, whether workforce directed or more general, require faculty prepared above that level for delivery of the full program. It is the mission of four year colleges and universities to prepare these individuals among many other baccalaureate recipients. Four year colleges and universities further help to extend the impact of community colleges through 2+2 articulation agreements and the offering of their degree programs on community college campuses, both approaches providing community college students who need them more ready access to baccalaureate completion opportunities. More universities are beginning to offer more workforce directed baccalaureate degrees such as the Bachelor of Applied Arts and Sciences (BAAS) degree. These programs can expand the partnerships between community colleges and four year institutions that aim to address both local and wider employment opportunities. If community colleges in Texas are to offer baccalaureate degrees, these should be limited to vocational degrees such as the Bachelor of Technology (BAT). The BAT degree can be planned to conform to specific industrial and workforce needs in an area. It is necessary to make sure that there are (remain) clear distinctions between what community colleges do and what universities do. Our stakeholders may want to consider that in order for a community college to offer a baccalaureate degree, the institution must first submit a proposal that includes a documented community or surrounding area workforce need. Because community colleges are expected to reflect and address the workforce needs of their districts, as well as provide lower-division academic transfer-oriented programs, it seems as if any expansion of baccalaureate credentials offered through community college districts should be tied directly to the needs of the taxing district -- combining concern for cost/resourcing with concern for mission disambiguation. Comments Regarding Recommendations are based on the following principles: 1) Regarding the first bulleted principle: Comment: There is little actual data available supporting the cost effectiveness of baccalaureate degrees currently offered at community colleges in comparison with similar programs at public universities. A thorough study should be done to determine how community college baccalaureate degrees compare to university degrees in actual cost, including lost earnings for length of time to degree.

10 TTU Page 2 of 3 2) Regarding the second and third bulleted principle: Comment: Because community colleges are funded in part by local taxing districts, the implementation of any baccalaureate degree at a community college should directly address workforce need in that taxing district, so that taxpayers are not paying for curricular offerings that do not directly benefit their communities. 3) Regarding the fourth bulleted principle: Comment: The shortages of qualified faculty in certain fields are problems that should be solved in advance of the approval of degree program authority, especially considering the earlier principle that seeks to avoid undue competition between community colleges and universities. Ample qualified faculty may be available for current community college baccalaureate degrees, but as the numbers of these degree opportunities increase, so will the need for more qualified faculty. Universities will be providers of these additional faculty, a factor to include in assessment of costs for community college baccalaureates. Comments Regarding Staff Recommendations Related to Authorization of Community College Baccalaureates: Regarding Overall Board Requirements Overall Board Requirement 1: Comment: The phrase appropriate sections of the required SACSCOC level change is unclear. What is meant by appropriate sections and what would be considered sufficient documentation of the approval of a level change? Overall Board Requirement 2: Comment: Community college catalogs routinely display curricular information regarding academic (transfer) degree programs as if they offer discipline-specific majors. A program inventory for academic associate degree programs (AA and AS) similar to those currently used to inventory the AAS offerings at colleges and the programs at all levels for universities should be a requirement prior to any further approval of baccalaureate level degrees at colleges, and colleges should be held accountable for the quality and productivity of those programs, should they be approved in the future, in a manner that is identical to what is currently in place for universities. Comments Regarding Recommendations Specific to Applied Science: Regarding the recommendation Each biennium, conduct a process Comment: Universities have funding streams and missions that are shared statewide, but community college taxing districts impose specific financial obligations upon the taxpayers in the specific district. If need for a baccalaureate program is determined to be statewide rather than local/regional, encourage universities to deliver the baccalaureate program, including transfer partner agreements with regional community colleges, via face-to-face and/or online options, before authorizing delivery of the baccalaureate program at community colleges, in order to

11 TTU Page 3 of 3 spare regional/district taxing districts/taxpayers from bearing the expense of fulfilling statewide needs. Comments Regarding Timeline for Implementation: Comment: Generally agree with the four goals for study during FY 15, but recommend using conclusions from that year of study to supplement and possibly modify recommendations from the RAND study. Comment: Generally agree that study should be restricted to types of applied baccalaureate degrees, and agree that criteria and definitions for BAAS, BAT, and BAS would be useful for further consideration of the issues.

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18 Johnstone, Gary From: Sent: To: Cc: Subject: Liedtke, Amy Wednesday, July 16, :28 PM Johnstone, Gary Neely, Robert Community College Baccalaureate Study Recommendations Mr. Johnstone: From Texas Woman s University regarding Community College Baccalaureate Study Recommendations: The first comment TWU would like to offer is regarding approval of only the RN to BS degree at community colleges. This degree option is widely available at universities across the state in fully online format. We believe there is adequate capacity at existing 4-year institutions, and certainly TWU. Approval of this recommendation would only exacerbate competition among institutions for faculty and clinical placement sites, which is unnecessary given available options already in place. Second, further clarification of the THECB s intentions regarding BAS, BAT, and BAAS degrees seems necessary, and would be helpful to both universities and community colleges. In general, TWU believes that the principles THECB staff enumerate are appropriate for assessing whether a baccalaureate program should be approved at a community college. Thank you. Amy Liedtke Executive Assistant to the Chancellor and President Texas Woman s University Ph: (940) Fx: (940)

19 Gary W. Johnstone Deputy Assistant Commissioner Planning and Accountability Texas Higher Education Coordinating Board 1200 East Anderson Lane Austin, Texas July 8, 2014 Dear Mr. Johnstone: This letter is in response to the Memorandum dated July 1, 2014, related to the Community College Baccalaureate Study Recommendations. Texas Lutheran University supports the concept of creating opportunities to establish appropriate workforces in critical need areas for our diverse populations. The principles that the staff from the Texas Higher Education Coordinating Board based their recommendations to authorize community college baccalaureates are vital to the success of such opportunities. Since Texas Lutheran University is at the forefront of creating innovative strategies to expand the workforce, especially for disadvantaged groups in specified rural areas of our state, we have some concerns related to the authorization of community college baccalaureates specifically for nursing programs. The first concerns the will understood shortages of qualified faculty for BSN programs and the need for adequate clinical experiences for students. There are clear guidelines that must be adhered to by the Texas Board of Nursing and national accrediting agencies related to qualified faculty and type of clinical experiences for baccalaureate nursing education programs. The Texas Board of Nursing through the Differentiated Essential Competencies of Graduates of Texas Nursing Programs (2010) clearly documents the appropriate differentiation for the various types of nurses in Texas with clear guidelines for educational programs for each of these groups. In addition, the Commission on Collegiate Nursing Education has standards for baccalaureate and master education for nursing programs with specific outcome expectations for graduates and faculty of these programs. If the recommendation from the Texas Higher Coordinating Board is to authorize only RN to BSN programs at specific community colleges, the Texas Board of Nursing only approves pre licensure programs so there is some concern related to the oversight of the adherence to these standards of quality at the state level. Authorizing community colleges to offer the BSN will only make it more difficult for existing baccalaureate programs to find qualified faculty, and seriously risk damaging the quality of existing programs.

20 It is vital to ensure that there are appropriate resources to establish RN to BSN programs in the state that meet quality standards. These programs still require qualified faculty and clinical experiences so difficulties may develop related to existing programs that are expanding to meet student demands.. We endorse the stackable credentials model promoted by the American Association of Community Colleges (2014) in their document, Empowering Community Colleges to Build the Nation s Future, works well with specific institutions in our state concentrating on the sequence of multilevel, industryrecognized credentials and/or certification as well as seamless education and career systems. Partnerships between community colleges and universities allow students to stay in one location but obtain the education that is appropriate for students and their identified professional career. These collaborative support structures allow institutional efficiency and strengthen services to students in community colleges and universities while not impinging on available resources. The concept of ensuring the establishment of partnerships with articulation/transfer agreements and distance learning options are vital to the success of the identified recommendations and would allow existing programs that meet appropriate standards to serve geographic areas of highest need. Finally, the use of applied baccalaureate degrees for nursing runs counter to national trends and research on high standards education for the registered nurse practicing in our complex, dynamic healthcare environment. The American Association of Colleges of Nursing Fact Sheets, The Impact of Education on Nursing Practice (2014) and Creating a More Highly Qualified Nursing Workforce (2013), indicate nurse executives, federal agencies, the military, leading nursing organizations, health care foundations, magnet hospitals, and minority nurse advocacy groups all recognize the unique value that baccalaureate prepared nurses bring to the practice setting. The evidence presented in these documents strongly supports the importance of higher level education that promotes effective critical thinking, clinical judgment, and safety and cultural competencies for today s registered nurse. A degree program consisting of liberal arts, academic, and professional coursework provides both the breadth and specialization for students to compete in today s high acuity, complex, and dynamic healthcare environment. Institutions of higher learning that focus on this type of baccalaureate education are built on the foundation of developing well rounded students who are problem solvers, adaptable and able to think outside the box by applying concepts, skills and knowledge in and outside the classroom. For these reasons, we have concerns that the proposed, well intentioned program may have unintended consequences of lowering the quality of nursing education in Texas, and actually exacerbating the shortage of highly skilled nurses available to serve our citizens.

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