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Office of Developmental Programs QA&I for HCBS Services PROVIDER SESSION July 19, 2017 Farm Show Complex, Harrisburg PA 7/17/2017 1

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Page 1: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

Office of Developmental Programs

QA&I for HCBS Services

PROVIDER SESSION

July 19, 2017

Farm Show Complex, Harrisburg PA

7/17/2017 1

Page 2: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

Self Assessment

• Opportunity for entities to evaluate their own

performance each year

• The focus is “Everyday Lives: Values in Action”

• The self-assessment tool will mirror the QA&I

tool

• Self-assessment will be used to inform and

build quality improvement activities for the

remainder of the QA&I cycle

• All entities are expected to remediate issues

discovered during the self assessment process

7/17/2017 2

Page 3: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

Brief Review of Self-Assessment Tools

• Individual’s experience of the system through

interviews

• Provider Tool– 49 Questions

– Focus areas: Quality Improvement; Person Centered Planning,

Service Delivery & Outcomes; Health & Safety

• Example Questions

– The Provider develops and implements a process that ensures

that the QMP is revised and analyzed within the specified

timeframes.

– Staff receive training to meet the needs of the individual they

support as identified in the current, approved Individual Support

Plan (ISP) before providing services to the individual.

– If an event occurred requiring the implementation of the back-up,

plan, the Provider implemented the individual’s back-up plan as

designed.

7/17/2017 3

Page 4: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

AE and SCO Annual Sample

7/17/2017 4

• Selected alphabetically with representation from each region

• Separate number of individuals selected to capture Level of Care performance

AE

• Identified based on individuals selected in the core sample

• The SCO that is authorized in the individual’s ISP

SCO

Page 5: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

QA&I Sampling – Provider Selection

7/17/2017 5

• For onsite review, Providers selected using last digit of MPI #

• New providers will be assigned onsite review

• AEs conduct the review using their own selection of individuals

• Provider qualification is aligned with onsite year

Provider

Page 6: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

QA&I Annual Timeline

7/17/2017 6

Onsite

Selections

Announced

June 15

June 30

ODP Issues

Statewide

QA&I Report

• Self

Assessments

Begin

• AE& SCO

Desk Reviews

Begin

July 1

July 15• ODP Notifies

AEs of

Provider Pool;

• Provider Desk

Reviews

Begin

Self

Assessments

Deadline

August 1*(8/31 for 2017)

August 31*(9/30 for 2017)

ODP Issues Self

Assessment

Statewide

Aggregate

Report

All Onsite

Reviews Begin

September 1

November 30Finalize All

Desk Reviews

All Onsite

Reviews

Completed

December 31

January 31All

Comprehensive

Reports Issued

Comp Report

Responses

Complete

including

Corrective Action

& Quality

Improvement

February 28

April 30All

Updated

QM Plans are

Submitted

Page 7: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

Annual Timeline – Providers

• All self-assessments begin July 1 and are

due on August 1 each year

– EXCEPTION! Self-assessments are due August

31 for 2017

• Dates in timeline are targets for entire

process

– Each Provider will have specific deadlines

depending on:

1. Scheduling of the onsite review, and

2. Completion and closure of the QA&I Comprehensive

Report

7/17/2017 7

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Annual Timeline – Providers (continued)

7/17/2017 8

Comprehensive Report Issued Electronically

[30 Days Following Onsite Visit]

Entity Responds with Proof of Remediation

and PPRs

[30 Days Following Comprehensive Report]

Closure of Comprehensive

Report with Approval of Remediation & PPR

[20 Days Following Entity Response]

QM Plan Submission & PPR Update

[30 Days After

Comprehensive Report Closure]

QA&I Team Review & Informal Feedback of

QM Plan and PPR Update

[30 Days of QM Plan Submission]

Submission of Evidence for Extended

Timeline PPRs

ODP Communication that All Improvement is Completed/Acceptable

Self Assessment Document of

Improvement Impact; QM Plan Adjustment

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7/17/2017 9

QUESTIONS

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Desk Review Process – Providers

• A review of available documentation by the

Assigned AE prior to the onsite review to:

– inform the overall QA&I process

– determine focus areas for the onsite review

• The desk review will use all available data

sources

• Findings from the QA&I desk review may

identify areas that will require additional

follow-up before or during the onsite review

7/17/2017 10

Page 11: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

QA&I Individual Interviews – Providers

7/17/2017 11

• Individual interviews are considered a critical component of the QA&I

process.

• ODP or its designee will conduct interviews for the sample prior to, during,

or after the onsite review.

• AEs will conduct individual interviews as part of onsite review.

• Where appropriate, a person familiar with the individual will be asked to

assist in the interview. The individual may choose who is present during

the interview.

• There will be a period of the interview where paid supports will not be

present.

• In keeping with person-centered practices, the individual may choose not

to participate in the interview or can opt to discuss their experience by

phone.

• Any person conducting an interview must ensure follow-up and reporting,

as appropriate, of any issue related to health and safety or service quality.

Page 12: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

Onsite Review Process – Providers

7/17/2017 12

• Onsite visits begin September 1 and are completed by

December 31.

• Assigned AE designation to conduct Provider onsite review is

determined by ODP and is the AE with the most individuals

authorized with the Provider.

• By December 31, 2018, at least one member of the AE QA&I

team will possess QM Certification

• Visits will occur over a 2-day period.

• A confirmation letter of the onsite review will be sent to

Providers two weeks prior to the visit.

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Onsite Review Process – Providers (continued)

7/17/2017 13

• Entrance Conference

– Overview of QA&I Process & Timelines

– Opportunity for Provider to Share Organizational Overview

– Onsite Visit Expectations

• Onsite visit will consist of record reviews, individual

interviews and discussions with Provider staff

• Exit Conference

– Onsite Review Overall Experience & Impressions

– Highlights of Best or Promising Practices

– Highlights of Remediation and Improvement Identified

– Expectations for Corrective Action and Final QA&I

Comprehensive Report

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QA&I Comprehensive Report – Providers

7/17/2017 14

• A written report issued for each reviewed entity in no more

than 30 calendar days of the onsite review completion

• AEs will share a copy of each Provider report with ODP upon

finalization and approval of the Corrective Action Plan

• The compilation of official findings from:

– Desk review

– Onsite review

– Face-to-face interviews with individuals and staff

– Self-assessments

• Overall contains positive performance points and

opportunities for improvement, not just presentation of raw

results

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QA&I Comprehensive Report – Providers (continued)

7/17/2017 15

• Providers will have 30 calendar days to review and

respond, including:

– Evidence of remediation completed within 30 days of

discovery, and Plans to Prevent Recurrence

– Any points of disagreement with the report findings

including appropriate evidence justifying the disagreement

• AEs will close or request further clarification within 20

calendar days of receipt of the Provider’s response

• Providers will have 30 calendar days from the date of

closure to submit the QM Plan and/or Action Plan,

updated as a result of the QA&I review.

• Main body of the reports will be posted on MyODP.org

Page 16: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

QA&I Questions – Providers

7/17/2017 16

• Focused more on Everyday Lives: Values in Action

• Emphasis on gathering information about the

individual’s experience

• Questions are more consistent across Providers,

SCOs and AEs

• QuestionPro is the platform for data entry

• Questions include both scored and non-scored

questions. Non-scored questions are identified on

the tools.

Page 17: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

QA&I Guidance – Providers

• Question tools all contain guidance for how

the question is to be interpreted

• QA&I Tool also:

– point to source documents pertaining to each

question

– specify those questions that are considered

exploratory

7/17/2017 17

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QA&I Guidance Example – Providers

• Question/Outcome #31 The Provider provides communication

assistance as indicated in the ISP.

• Guidance:

– For the sample selected, the reviewer determines if the ISP identifies any

communication assistance.

– The reviewer determines if daily documentation and progress notes

reflect that the communication assistance identified in the ISP is being

provided to the individual.

• Mark YES if the daily documentation and progress notes reflect how

the Provider implemented the communication assistance that was

identified in the individual’s ISP.

• Mark NO if the daily documentation and progress notes did not reflect

how the Provider implemented the communication assistance or if

the Provider did not implement communication assistance as

prescribed in the ISP.

• Mark NA if the ISP does not have any communication assistance

identified for the individual.

7/17/2017 18

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Corrective Action Plan – Providers

• A catalog of those instances requiring remediation, as

well as a PPR including a QM Plan and/or Action Plan,

where necessary.

• An attachment to the QA&I Comprehensive Report, on

an ODP approved template.

• If the QA&I Comprehensive Report includes instances of

not meeting the standard, the entity must remediate each

one and develop a PPR, if applicable.

– Proof of remediation and a Plan to Prevent Recurrence,

including where QM Plans and/or Action Plans will be

developed, must be submitted within 30 calendar days of

receipt of the QA&I Comprehensive Report.

7/17/2017 19

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Remediation – Providers

7/17/2017 20

• Instances in which an entity has not met the standard of

a particular QA&I question or series of questions

• These instances must be corrected, either upon

discovery or within 30 days of discovery

– There will be occasions when remediation must occur

immediately due to concerns for health and safety.

– Otherwise, remediation must occur within 30 days

following electronic issuance of the Comprehensive Report

by the AE.

• The instances for remediation will be:

– Summarized within the QA&I Comprehensive Report

– Specified in the accompanying Corrective Action Plan

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Remediation – Providers (continued)

7/17/2017 21

• Each entity is required to include in its response to the

QA&I Comprehensive Report

– Proof of remediation already completed, including the date

of completion - and/or -

– A Plan to Prevent Recurrence (PPR) for each instance

noted in the Corrective Action Plan

– Identification of areas in which a QM Plan and/or Action

Plan will be developed

• Any exceptions to completion of remediation within 30

days of discovery must be negotiated with ODP or the

AE, as appropriate

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Plans to Prevent Recurrence (PPR) - Providers

• PPR outlines actions that will be taken to ensure

future instances of non-compliance do not occur.

• A PPR is required when

– the compliance score for the requirement falls below 86%

OR

– 9 or fewer records were reviewed and there are 2 or more

instances of non-compliance.

• For any PPR activity requiring longer than 3 months

to implement, the entity is responsible to provide an

update on the progress of such activity(s) within 30

days of the QA&I Comprehensive Report to the AE

Onsite Review Team.

7/17/2017 22

Page 23: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

Validation - Providers

• Providers are responsible for submitting evidence

of remediation and implementation of PPRs.

• ODP or the AE will review and approve all

remediation and PPR activities in order to close the

QA&I Comprehensive Report.

• Each year in the self-assessment process,

Providers are expected to address the impact of

PPR activities completed within the past year.

7/17/2017 23

Page 24: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

Directed Corrective Action Plan (DCAP) - Providers

• May be required for ongoing engagement with ODP

or the AE, as appropriate, until such issues

identified in the DCAP are resolved to the

satisfaction of the QA&I Review Team.

• A DCAP through mandatory technical assistance

may be required, at a minimum, when:

– The entity fails to respond to imminent risk for one or more

individuals;

– The entity demonstrates repeated non-compliance in one

or more areas;

– The entity’s performance is below 86% for 5 or more

designated questions, if the sample is greater than 10; or

– Performance for one or more designated questions is

below 50% performance.

7/17/2017 24

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7/17/2017 25

BREAK

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7/17/2017 26

Quality Improvement & QM Plans

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Quality Improvement & QM Plans - Key Points

• How QA&I Process enhances and supports ODP’s

system-wide Quality Strategy – Everyday Lives:

Values in Action

• Using QA&I Process and Results to develop QM

Plans and Action Plans

– What’s the same?

– What’s new?

7/17/2017 27

Page 28: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

ODP Goals for QA&I

7/17/2017 28

• Measure progress toward systems

improvement based on Everyday

Lives: Values in Action ISAC

recommendations

• Gather timely & useable data to

manage the ODP system performance

• Use data to manage the service

delivery system with a continuous

quality approach

• Demonstrate AE outcomes with

operating agreement

• Collect data for Waiver performance

measures

• Verify that SCOs and Providers comply

with 6100 regulations

Page 29: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

Purpose of Revised QA&I Process

7/17/2017 29

• Eliminate multi-layered

process and unnecessary

duplication

• Create more time to focus on

quality improvement and the

experience of individuals

• Desire to move away from

hierarchical compliance and

remediation toward

collaborative partnerships that

foster technical assistance and

shared learning

• Improve methods for collecting

and using data in a timely way

Quality of

the

Individual’s

Experience

Compliance

Page 30: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

How QA&I Process enhances ODP’s Quality Strategy

• QA&I Questions will inform QM Planning:

– Tied to Everyday Lives: Values in Action

• Assuring Effective Communication

• Promoting Self-Direction, Choice and Control

• Increasing Employment

• Supporting Families

• Promoting Health, Wellness, and Safety

• Supporting People with Complex Needs

• Increasing Community Participation

– Focus on determining the individual’s experience with

services and supports

– Emphasize:

• Person-centered practices

• Service delivery

• Health & safety

7/17/2017 30

Page 31: Office of Developmental Programs - s3-us-west-2.amazonaws.com · • By December 31, 2018, at least one member of the AE QA&I team will possess QM Certification • Visits will occur

How QA&I Process enhances ODP’s Quality Strategy

• QA&I Questions will inform QM Planning:

– Tied to Everyday Lives: Values in Action

• Develop and Support Qualified Staff

• Improve Quality

• Performance results will assist ODP, AEs, SCOs, and

Providers:

– Determine priorities for improvement

– Develop baselines and target objectives for QM Plans

7/17/2017 31

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How QA&I Process enhances ODP’s Quality Strategy

7/17/2017 32

• At least one ODP team member will possess QM

Certification

• By December 31, 2018, at least one member of the AE

onsite review team will possess ODP QM Certification

• Entrance Conference offers:

– Opportunity for entity leadership to share mission, vision,

successful and in-process quality improvement projects,

discuss challenges and identify areas for technical assistance

• Exit Conference offers:

– Highlights of best or promising practices

– Highlights of remediation and improvement identified

– Expectations for corrective action, quality improvement, and

Final QA&I Comprehensive Report

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Program

Design..Discovery..Remediation..Improvement

(DDRI)

DESIGN

Plan for and set stage for

achieving positive outcomes

DISCOVERY

Find positive and negative

outcomes in a systematic,

timely manner

REMEDIATION

Address negative outcomes

in a timely manner

IMPROVEMENT

Improve quality via systemic

changes

CONTINUOUS CYCLE

This is

where

data

analysis

comes in

33

QM Planning: What’s the same?

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7/17/2017 34

QM Plan Template Year:

Entity Name: Focus Area:

Goal Outcome Target Objective Performance Measure/

Data Source/Responsible

Person

QM Planning: What’s the same?

MyODP @ https://www.myodp.org/course/index.php?categoryid=264

Click on: Quality Management Planning and Implementation Documents

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7/17/2017 35

Action Plan Template

Entity Name: Focus Area:

Desired Outcome:

Target Objective:

Performance Measure (s):

Data Source (s):

Responsible Person:

Action Item Responsible

Person (Name)

Target

Date

Status Completion Date

QM Planning: What’s the same?

MyODP @ https://www.myodp.org/course/index.php?categoryid=264

Click on: Quality Management Planning and Implementation Documents

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Recommended QM Plan Components:

– Goals

– Desired Outcomes

– Target Objectives and Baselines

– Performance Measures

– Data sources used to measure performance

– Person Responsible for the QM Plan

Recommended QM Action Plan Components:

– Action Item

– Responsible Person

– Target Date

– Status

– Completion Date

7/17/2017 36

QM Planning: What’s the same?

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QM Planning: What’s new?

Identifying Opportunities for Improvement

• Choose Focus Areas and Goals considering:

– ODP’s Everyday Lives priorities

– your mission, role, and the services and

supports you offer in light of Everyday Lives

priorities

– input and feedback offered by ODP and/or

the AE in identifying systemic opportunities

for improvement

• Everyday Lives Publications support the QM

Planning process:

– Everyday Lives: Values in Action

– Recommendations, Strategies, and

Performance Measures

7/17/2017 37

MyODP @ https://www.myodp.org/mod/page/view.php?id=7775

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QM Planning: What’s new?

Identifying Opportunities for Improvement

• QA&I Results will be available to each entity

– Performance data in areas supported by exploratory

questions will support QM Planning

– Plans to Prevent Recurrence (PPRs) will foster prioritization of

focus areas

• When performance falls below the threshold of 86%, evaluate

whether the cause for poor performance represents a systemic

problem in need of a quality improvement project supported by a QM

Plan and Action Plan

– Review of QA&I data will allow for development of baselines and

realistic target objectives

7/17/2017 38

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• QM Plans will be submitted and reviewed as part of the QA&I Process.

• If you have a QM Plan and accompanying QM Action Plan already in place and findings from the QA&I Process prompt you to update these documents,

– Update your existing Action Plan until it’s time to develop your new Fiscal Year QM Plan and Action Plan

– Update your QM Plan and Action Plan to begin July 1

• If you discover an area where you need to develop a new QM Plan and accompanying Action Plan,

– Add a new Focus Area, Goal and Target Objective to the existing QM Plan that will carry you to June 30th of the following fiscal year

– Add Action Plan steps to achieve the Target Objective– Implement the new work immediately with continuation in the following

fiscal year

7/17/2017 39

QM Planning: What’s new?

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• Using the QA&I tool, AEs, SCOs and Providers are expected

to conduct a self-assessment of their performance annually to

inform and build quality improvement activities, evaluate

progress on implementing the QM Plan and determine the

effectiveness and impact of action steps.

• Organizations not slated for onsite QA&I review until years 2

and 3 are expected to use their self-assessment results to

prioritize and engage in improvement activities while awaiting

the onsite review.

• It is the intention that AEs, SCOs and Providers will continue

to engage in quality improvement activities during the two-

year period between formal QA&I onsite reviews.

7/17/2017 40

QM Planning: What’s new?

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• ODP and AEs will follow up with the entity on progress

in implementing QM Plans and provide technical

assistance as needed during the course of the QA&I

Cycle.

• Technical assistance by either ODP or AEs will focus on

quality improvement.

7/17/2017 41

QM Planning: What’s new?

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• Statewide Reports

– Self-Assessments

• Annually, at the completion of the self-assessment

process for all entities, ODP will issue an aggregate

report of self-assessment results and analysis

statewide. This report will be used to inform the QA&I

process throughout the year and technical assistance

targeted to AEs, SCOs and Providers.

– Annual QA&I Report

• Annually, ODP will compile all data collected from the

QA&I process into a report that represents statewide

performance of AEs, SCOs and Providers and the

overall system as it relates to quality of services and

supports and person-centered best practices.

7/17/2017 42

QM Planning: What’s new?

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• Requirements for ODP QM Certification

– At least one ODP team member will possess QM

Certification

– By December 31, 2018, at least one member of the AE

onsite review team will possess ODP QM Certification

• ODP QM Certification

– Complete prerequisites

– Application and registration process

– In-person class:

• September 13 and 14, 2017 in Ebensburg

• October 11 and 12, 2017 in Chester County

• October 31 and November 1, 2017 in Mechanicsburg

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QM Planning: What’s new?

MyODP @ https://www.myodp.org/course/index.php?categoryid=214

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QM Planning: What’s new?

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QM Planning: What’s new?

7/17/2017 45

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QUESTIONS

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ODP Contact Information

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ODP QA&I Process Mailbox:

[email protected]

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THANK YOU!