Inspection on 15/08/05 for Thorntree Farm Nursing Home

This inspection was carried out on 15th August 2005.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Good. The way we rate inspection reports is consistent for all houses, though please be aware that this may be different from an official CSCI judgement.

The inspector found there to be outstanding requirements from the previous inspection report. These are things the inspector asked to be changed, but found they had not done. The inspector also made 1 statutory requirements (actions the home must comply with) as a result of this inspection.

Other inspections for this house

Thorntree Farm Nursing Home 12/06/07

Thorntree Farm Nursing Home 10/05/06

Thorntree Farm Nursing Home 14/02/06

Thorntree Farm Nursing Home 16/02/05

Thorntree Farm Nursing Home 10/08/04

Thorntree Farm Nursing Home 24/02/04

Similar services:

Whiteley House

Tyndale Avenue

2-10 Norfolk Road

Bennfield House Nursing Home

Eastfield Residential Home

Sign Health

Springwood

Fairburn Mews

Extracts from inspection reports are licensed from CQC, this page was updated on 09/07/2008.

CARE HOME ADULTS 18-65 Thorntree Farm Nursing Home Low Lane Clayton Bradford BD14 6QA Lead Inspector Sue Dunn Announced 15 August 2005. 9:30am The Commission for Social Care Inspection aims to: • • • • Put the people who use social care first Improve services and stamp out bad practice Be an expert voice on social care Practise what we preach in our own organisation Reader Information Document Purpose Author Audience Further copies from Copyright Inspection Report CSCI General Public 0870 240 7535 (telephone order line) This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI www.csci.org.uk Internet address This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Adults 18-65. They can be found at www.dh.gov.uk or obtained from The Stationary Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering: www.tso.co.uk/bookshop This report is a public document. Extracts may not be used or reproduced without the prior permission of the Commission for Social Care Inspection. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 3 SERVICE INFORMATION Name of service Thorntree Farm Nursing Home Address Low Lane, Clayton, Bradford, West Yorkshire, BD14 6QA 01274 817523 Telephone number Fax number Email address Name of registered provider(s)/company (if applicable) Name of registered manager (if applicable) Type of registration No. of places registered (if applicable) Mr Sikandar Divan Mrs Sheila Divan Mr Sikandar Divan Care Home 20 Category(ies) of Mental disorder, excluding learning disability or registration, with number dementia (20) of places Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 4 SERVICE INFORMATION Conditions of registration: None Date of last inspection 16/02/05 Brief Description of the Service: Thorntree Farm provides 24 hour nursing care for people of a mixed age range whose prime need is because they have mental health problems. The home is located in a rural position between the villages of Clayton and Thornton and, for people with reasonable mobility, is within walking distance of bus routes. The home uses the community transport bus, and its own vehicle for transport for service users as required. The accommodation, some in shared rooms, is in a renovated farmhouse, with an extension (known in the home as the cottage), and a recently renovated farm building, which provides a three bedroom bungalow. Accommodation is on different levels with some ground floor bedroom accommodation for the less mobile. Communal space in the home includes four lounges, dining/kitchen areas, a designated smoking lounge and a games room. The garden has a greenhouse and sitting areas. The main entrance gate can be locked for security if required. Some off road parking space is available. The joint proprietor/ managers are qualified psychiatric nurses and Mr Divan is also a qualified Social Worker. The home provides a structured daily programme which promotes domestic skills and activities of daily living. Participation is expected and encouraged. Healthy eating and exercise are seen as an important part of this. Service users are only admitted following a social worker assessment. This, followed by a trial period, is used as a basis on which the home establishes if needs can be met. The home does not accept service users whose needs they feel they cannot meet. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. The inspection, which was announced, was undertaken by one inspector from 9.50am - 6.15pm, joined by a second inspector from 2.45pm – 6.15pm. The purpose of the inspection was to make sure the home was operating and being managed for the benefit and well being of the residents. Evidence for this report was obtained from a pre inspection questionnaire completed by the proprietors, examination of a selection of records and care plans and a brief tour of the building. Discussions were held with the managers/proprietors, a care worker and several residents. Comment cards, allowing any resident who wished to remain anonymous to express their views had not been returned at the time of writing. What the service does well: What has improved since the last inspection? The terms and conditions of occupancy, agreed with new residents, now includes the number of the room to be occupied. New bedroom door locks have been fitted which allow the door to be locked but accessed by staff in an emergency. The care plans have improved since the last inspection. They have now been written in a way that clearly shows what each resident is aiming to achieve. The refurbishment of the kitchen and some items of dining room furniture have improved the standards in these areas. The level of lighting on the stairwell to the ‘cottage’ has been improved. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 6 The proprietors have made a start towards producing written evidence of the expenditure. They have tried to work cooperatively with the inspectors to meet any shortfalls to the standards. What they could do better: Please contact the provider for advice of actions taken in response to this inspection. The report of this inspection is available from enquiries@csci.gsi.gov.uk or by contacting your local CSCI office. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–5) Individual Needs and Choices (Standards 6-10) Lifestyle (Standards 11-17) Personal and Healthcare Support (Standards 18-21) Concerns, Complaints and Protection (Standards 22-23) Environment (Standards 24-30) Staffing (Standards 31-36) Conduct and Management of the Home (Standards 37 – 43) Scoring of Standards Statutory Requirements Identified During the Inspection Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 8 Choice of Home The intended outcomes for Standards 1 – 5 are: 1. 2. 3. 4. 5. Prospective service users have the information they need to make an informed choice about where to live. Prospective users’ individual aspirations and needs are assessed. Prospective service users’ know that the home that they will choose will meet their needs and aspirations. Prospective service users have an opportunity to visit and to “test drive” the home. Each service user has an individual written contract or statement of terms and conditions with the home. The Commission consider Standard 2 the key standard to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 4,5 The home’s terms and conditions of occupancy do not accurately reflect the service that is on offer. The home pre admission assessment does not show how judgements are made before admission therefore people are not assured that their needs, including social and recreational needs, can be met. Future residents are given the opportunity to visit the home before making a decision regarding admission. EVIDENCE: The contracts for people recently admitted to the home now include the number of the room to be occupied. This must be shown on all contracts and be consistent with the room occupied. All bedroom door locks have been changed so staff can now access rooms in an emergency. The wording of the contracts should be amended accordingly. A person admitted to the home since the last inspection confirmed she had the opportunity to visit and had made an active choice to move into the home for the security of having psychiatric nursing staff available. The proprietors described the difficulty of offering a trial visit for people who have been in hospital as the hospital will not readmit a person if the home Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 9 finds they cannot meet their needs. The home must carry out their own pre admission assessment to determine, before admission, if and how they can meet needs. The inspector advised on a format that could be used for this. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 10 Individual Needs and Choices The intended outcomes for Standards 6 – 10 are: 6. 7. 8. 9. 10. Service users know their assessed and changing needs and personal goals are reflected in their individual Plan. Service users make decisions about their lives with assistance as needed. Service users are consulted on, and participate, in all aspects of life in the home. Service users are supported to take risks as part of an independent lifestyle. Service users know that information about them is handled appropriately, and that their confidences are kept The Commission considers Standards 6, 7 and 9 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 6,7,8,9 Care plans have improved but further development is needed to make sure that all of the information required by the standards is recorded. Residents make decisions and are supported to take risks as part of an independent lifestyle, but this is not always recorded. EVIDENCE: There has been a great improvement in the content of the care plans since the last inspection. The home has always kept well detailed records of daily events but the agreed goals and action plans are now documented in a way which gives a measure of what people hope to achieve. A resident was able to describe her expectations in terms of the information seen in the care plan. There must be evidence to show that each care plan has been discussed and agreed with the person concerned. The background history in some care files was better than others in giving information, which supported a ‘person centred’ approach to meeting care needs. Photographs were missing from some files. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 11 The progress of a person who receives periodic respite care in the home was reviewed on each admission. A outcome of a formal review involving other professionals was not documented as the home was waiting for a copy of the report from the social worker. It is recommended that the home take notes during a review, to be able to give continuity of support to the resident. The degree of independence and motivation varied within the group. Some people make decisions about activities and outings; the staff adopt a more directive approach with others. It was clear that judgments were made about managing risk, which were linked to each person’s activity but this was not documented in the care files. Residents who spoke with the inspector said they felt secure and were satisfied with their lifestyle. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 12 Lifestyle The intended outcomes for Standards 11 - 17 are: 11. 12. 13. 14. 15. 16. 17. Service users have opportunities for personal development. Service users are able to take part in age, peer and culturally appropriate activities. Service users are part of the local community. Service users engage in appropriate leisure activities. Service users have appropriate personal, family and sexual relationships. Service users’ rights are respected and responsibilities recognised in their daily lives. Service users are offered a healthy diet and enjoy their meals and mealtimes. The Commission considers Standards 12, 13, 15, 16 and 17 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 11,12,14,17 Residents have opportunities for personal development and are able to join in activities appropriate to their age and ability. Residents are encouraged to follow a healthy eating programme, and according to ability are encouraged to carry out some domestic tasks with support. EVIDENCE: The home has a regular programme of activities which residents are expected to attend. The emphasis is on activities that develop life skills and provide exercise. Examples of these were a college course for cooking, weekly supermarket shopping, voluntary work in charity shops, domestic tasks within the home, attendance at a leisure centre and activities such as bingo in the local community. One person has made progress whilst in the home to a level where he was discharged home to his family. This is commendable. Some people organise their own outings. Three people who regularly go out together had arranged a day trip to Wales and another person regularly takes Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 13 a bus to Keighley because he said he enjoyed the bus route through the countryside. Staff organise quizzes and word games in the house and take people out in the car to places of interest. There was a snack lunch followed by a good selection of fresh fruit at midday. The dining tables were laid with clean and neat tablecloths. Residents said they were satisfied with the food, which was described as ‘good’ and said they were having chicken pie for the main meal at the end of the day. One person had made great progress in losing weight through being supported to follow a moderate diet and was now able to have the occasional treat. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 14 Personal and Healthcare Support The intended outcomes for Standards 18 - 21 are: 18. 19. 20. 21. Service users receive personal support in the way they prefer and require. Service users’ physical and emotional health needs are met. Service users retain, administer and control their own medication where appropriate, and are protected by the home’s policies and procedures for dealing with medicines. The ageing, illness and death of a service user are handled with respect and as the individual would wish. The Commission considers Standards 18, 19, and 20 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 18,19,20,21 Healthcare support is satisfactory and illness and death is handled with sensitivity. The home’s policy and procedure relating to medication does not follow guidelines from The Royal Pharmaceutical Society, therefore there is no guarantee that correct procedures will be followed. EVIDENCE: Residents are supported and prompted to maintain a satisfactory level of personal hygiene. A healthy diet, which includes plenty of fruit and vegetables, is encouraged. Files showed regular visits for healthcare checks. Three people went to the hospital for routine checks on the day of the inspection. Psychiatrists and psychiatric social workers, as required, support people. The home now has a copy of the guidelines from the Royal Pharmaceutical Society, but the home’s policy and procedure document does not cross reference to the guidelines, and does not cover ordering, storage, administration, record keeping and disposal of medication, in the level of detail recommended in the guidelines. The proprietor/manager takes responsibility for ordering medication. It is recommended that this task be shared with at least one other qualified member of staff. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 15 A more active resident had visited a friend from the home who was in hospital and residents were given the opportunity to go to the funeral when he died. It is recommended that staff have some bereavement and loss training. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 16 Concerns, Complaints and Protection The intended outcomes for Standards 22 – 23 are: 22. 23. Service users feel their views are listened to and acted on. Service users are protected from abuse, neglect and self-harm. The Commission considers Standards 22, and 23 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 22,23 Complaints are dealt with properly. The home’s adult protection procedure does not refer to the multi-agency adult protection procedures, therefore there is no guarantee that the correct procedures will be followed. EVIDENCE: A service user said that she felt confident she could voice an opinion even when there were differences of opinion with the staff. The home has a copy of the ‘No Secrets’ adult protection policy and procedures, but the home’s policy document does not direct staff towards the guidance in these procedures in the event of any suspicion or allegation of abuse. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 17 Environment The intended outcomes for Standards 24 – 30 are: 24. 25. 26. 27. 28. 29. 30. Service users live in a homely, comfortable and safe environment. Service users’ bedrooms suit their needs and lifestyles. Service users’ bedrooms promote their independence. Service users’ toilets and bathrooms provide sufficient privacy and meet their individual needs. Shared spaces complement and supplement service users’ individual rooms. Service users have the specialist equipment they require to maximise their independence. The home is clean and hygienic. The Commission considers Standards 24, and 30 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 24,25,26,28,30 Some work on the environment has taken place but ongoing work is required, to maintain a satisfactory standard. EVIDENCE: The proprietors have made some improvements inside the building since the last inspection. The kitchen in the main house has been refurbished, which has greatly improved the appearance. The appearance of the smoking room has also benefited from redecoration. Locks have been fitted to bedroom doors. This allows the doors to be locked but staff to access the rooms in an emergency. Some residents had locked their bedroom doors. Some bedrooms contained personal belongings to reflect the lifestyle of the occupants. An additional light has been fitted at the top of the staircase to the ‘cottage’, improving safety for anyone using the stairway. It was agreed that the first floor corridor requires better illumination to reduce the risk of people tripping over the step halfway along its length. Some areas of the home felt cold but assurances were given that residents could adjust the heating if required. The bedroom adjoining the pool room is currently unoccupied as there are problems with the floor. The natural lighting Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 18 and ventilation for this room would not meet current standards and its future use as a bedroom should be reconsidered. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 19 Staffing The intended outcomes for Standards 31 – 36 are: 31. 32. 33. 34. 35. 36. Service users benefit from clarity of staff roles and responsibilities. Service users are supported by competent and qualified staff. Service users are supported by an effective staff team. Service users are supported and protected by the home’s recruitment policy and practices. Service users’ individual and joint needs are met by appropriately trained staff. Service users benefit from well supported and supervised staff. The Commission considers Standards 35 the key standard to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 31,32,33,34,35 Selection processes needs to be more rigorous if residents are to be protected by the home’s recruitment procedures. Staffing numbers and skills ensure that residents’ needs are met. Induction records do not evidence that new workers understand all of the induction standards. EVIDENCE: The care workers on duty at the time of the inspection had been employed in the home for several years and were able to talk about the way they worked with different service users. A member of staff said that she was well supported by the assessor, and the residents, as she works towards an NVQ (National Vocational Qualification) award. She said it had helped her to improve her caring skills. She felt that there was good communication within the team which led to consistency for the service users. There is a copy of the TOPSS (Training Organisation for Personal Social Services) induction standards in the home. The manager said that he discussed these standards with a new worker, but there was no evidence to support the fact that this person had achieved the required outcomes of the standards. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 20 The recruitment and selection records were examined and provided evidence that the home applied for references and CRB checks, there were two interviewers and notes of the interview. However, there was only one set of interview notes. It was not clear who had provided the reference response for one employee and the employment history only went back to the time the employee entered the country Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 21 Conduct and Management of the Home The intended outcomes for Standards 37 – 43 are: 37. 38. 39. 40. 41. 42. 43. Service users benefit from a well run home. Service users benefit from the ethos, leadership and management approach of the home. Service users are confident their views underpin all self-monitoring, review and development by the home. Service users’ rights and best interests are safeguarded by the home’s policies and procedures. Service users’ rights and best interests are safeguarded by the home’s record keeping policies and procedures. The health, safety and welfare of service users are promoted and protected. Service users benefit from competent and accountable management of the service. The Commission considers Standards 39, and 42 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 37,38,39,41,42,43 There is a system of joint decision making in the home, but the home must continue to seek the views of residents so that their best interests are safeguarded. The health and safety of residents is compromised by the lack of risk assessments. EVIDENCE: Mr Divan has a social work qualification in addition to his nursing qualification which is an accepted qualification for the role he performs. It is important that he separates his role as a social worker from his responsibilities as a registered manager. The proprietors have produced a business plan of sorts, which gives a record of expenditure. This must be developed further to show the planned expenditure for the coming 12 months. The plan should include budgeting for training, maintenance and refurbishment. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 22 A member of staff said that there are monthly meetings to discuss the progress of the service users. A member of staff was confident that service users views are considered at this time, however, it was apparent that some service users lacked the motivation to express their views due to their mental health. The content of records had improved to show what had been discussed with service users. One recommendation by the fire safety officer is outstanding as the managers are seeking clarification. Other work in his report has been completed. The Health and Safety records seen were up to date. However as some potential areas of risk have been identified during inspections it is recommended that the manager should appoint a health and safety officer for the home to identify areas of potential risk. Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 23 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Adults 18-65 have been met and uses the following scale. The scale ranges from: 4 Standard Exceeded 2 Standard Almost Met (Commendable) (Minor Shortfalls) 3 Standard Met 1 Standard Not Met (No Shortfalls) (Major Shortfalls) “X” in the standard met box denotes standard not assessed on this occasion “N/A” in the standard met box denotes standard not applicable CHOICE OF HOME CONCERNS AND COMPLAINTS Standard No 1 2 3 4 5 Score x x x 2 2 Standard No 22 23 ENVIRONMENT Score 3 2 INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 LIFESTYLES Score 3 3 3 2 x Score Standard No 24 25 26 27 28 29 30 STAFFING Score 3 3 3 x 3 x 3 Standard No 11 12 13 14 15 16 17 3 3 x 3 x x 3 Standard No 31 32 33 34 35 36 Score 3 3 3 2 3 x CONDUCT AND MANAGEMENT OF THE HOME PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Thorntree Farm Nursing Home Score 3 3 2 3 Standard No 37 38 39 40 41 42 43 Score 3 3 3 x 2 3 2 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 24 yes Are there any outstanding requirements from the last inspection? STATUTORY REQUIREMENTS This section sets out the actions which must be taken so that the registered person/s meets the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The Registered Provider(s) must comply with the given timescales. No. 1. Standard YA20 Regulation 13 Requirement The content of the policy and procedure relating to medication must set out the specific instructions for staff that incorporates: · · · · · 2. 35 18 Ordering Storage Administration Record keeping Disposal. Timescale for action 30.11.05 This is outstanding from 16.2.05. 30.11.05 The managers must provide evidence to show that all new staff complete an induction programme that meets the requirements of the TOPSS (Training Organisation for Personal Social Services) within the first 6 weeks of employment. This is outstanding from 16.2.05. 3. 43 25 The proprietors must be able to provide a formalised business plan. 31.03.06 4. 4 14 This is outstanding from 16.2.05. The home must assess,before a 30.11.05 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 25 Thorntree Farm Nursing Home 5. 6. 5 9 5 13 7. 23 13 8. 34,41 13,18 person is admitted, how their needs are to be met All residents must have a contract which shows the room they are to occupy The home must provide a written risk management plan which all staff are aware of to reduce the possibility of any identified risks The homes adult protection procedure must follow the step by step guidance in the No Secrets document The homes recruitment and selection procedure must be sufficiently rigorous to make sure residents are protected 31.11.05 31.11.05 31.11.05 31.11.05 9. RECOMMENDATIONS These recommendations relate to National Minimum Standards and are seen as good practice for the Registered Provider/s to consider carrying out. No. 1. 2. Refer to Standard 6 42 Good Practice Recommendations The home should take notes during reviews for their own and the residents information The proprietors are advised to appoint a person to carry out regular risk assessments on the premises Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 26 Commission for Social Care Inspection Aire House Town Street Rodley LS13 1HP National Enquiry Line: 0845 015 0120 Email: enquiries@csci.gsi.gov.uk Web: www.csci.org.uk © This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI Thorntree Farm Nursing Home 20050815 Thorntree Farm AN Stage 4 J52 V188364 S19903.doc Version 1.40 Page 27 - Please note that this information is included on www.bestcarehome.co.uk under license from the regulator. Re-publishing this information is in breach of the terms of use of that website. 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