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College
of Charleston
Academic
Affairs
Faculty
and Administration Manual
Policy and Procedures for Application for, Receipt of, and Administration
of Sponsored Project Funds
0.0 CONTENTS
1.0 Purpose
2.0 Definition of Sponsored Projects
3.0 Office of Research & Grants Administration Services
4.0 Principal Investigator Eligibility
5.0 Proposal Development and Submission Procedures
6.0 Award Negotiation, Acceptance, and Processing Procedures
7.0 Administration of Sponsored Projects
8.0 Research Protections & Compliance
9.0 Responsibilities of the Principal Investigator/Project Director
10.0 Responsibilities of the Department Chair/Unit Director
11.0 Responsibilities of the Dean/Cognizant Vice-President
1.0 PURPOSE
Faculty and staff members are encouraged to seek financial
support for research, demonstration/evaluation, curriculum development,
training/professional development, and professional and community
service activities from extramural sources to fulfill the mission of
the institution. The purpose of this policy is to describe the
procedures that a College employee should follow in seeking extramural
support for these types of activities and for administering resulting
grants and contracts through the Office of Research and Grants
Administration (ORGA).
2.0 DEFINITION OF SPONSORED PROJECTS
All grants and subgrants of public funds that support
research, demonstration/evaluation, curriculum development,
training/professional development, and professional and community
service activities are considered sponsored projects and are
administered through the Office of Research & Grants
Administration.
All contracts, cooperative agreements, consortium agreements,
master agreements and task orders, subcontracts, and purchase orders
for these types of services (except those solely for delivery of
Professional Development in Education courses), regardless of funding
source, are also considered sponsored projects subject to ORGA
oversight.
Grants and subgrants of non-governmental funds are considered
sponsored projects if they are awarded based on a competitive
application or bid process; involve the use of human research
participants, animals, radiation hazards, biohazards, or recombinant
DNA; and/or contain certain terms and conditions requiring
implementation and/or monitoring through established university systems
and procedures.
Charitable contributions, in-kind donations, and
non-governmental “bricks and mortar” grants are not considered
sponsored projects and are instead received by the College of
Charleston Foundation and administered through Institutional
Advancement (IA). The Foundation may also receive grants from
individuals and non-governmental funding entities; in certain cases,
funds from these grants must be transferred to the College through ORGA
for implementation and administration as a sponsored project.
Types of grants requiring the transfer of funds from
the Foundation to the College through ORGA include those that provide
compensation of College employees or students through the payroll
system; those intended for acquisition of durable goods or equipment
that should be titled to the College and carried on the College’s
property management system for depreciation and insurance purposes; and
those with complex and/or frequent management and reporting
requirements that may be more easily met through the College’s
established post-award administration and grants and contracts
accounting systems.
Further clarification about the types of funded
projects that are administered by ORGA as opposed to those administered
by IA may be found in the College’s policy entitled “Receipt and
Administration of External Funds: Defining Sponsored Projects and
Charitable Giving” available on the ORGA website at
<http://www.orga.cofc.edu/>.
3.0 OFFICE OF RESEARCH & Grants ADMINISTRATION SERVICES (ORGA)
The Office of Research & Grants Administration
promotes and facilitates externally funded research,
demonstration/evaluation, curriculum development, training/professional
development, and professional and community service activities at the
College of Charleston. ORGA is a central source of information on major
government agencies and non-governmental organizations that support
research, teaching, and scholarship. Staff provide a wide
range of services to faculty members, administrators, and students,
including:
- Assisting in the conceptualization and planning of projects
- Identifying potential extramural funding sources
- Assisting in the development of proposal narratives and project budgets
- Assisting in preparation of standardized application forms
- Assisting in electronic proposal submission and award administration
- Assuring compliance with federal and state regulations and university policies and procedures
- Assisting in the completion of internal requirements
for proposal submission, including coordination of review of research
protocols involving humans and vertebrate animals
- Reviewing and approving proposals for submission to sponsors
- Negotiating grant awards and contractsProviding technical assistance in administration of grants and contracts
- Managing a payroll distribution and effort reporting system for faculty and staff participating in sponsored projects
- Coordinating activities with the Grants Accounting Office and Institutional Advancement as required
- Maintaining a central file and database of all
proposals submitted and awards received and generating reports of
sponsored project activity.
4.0 PRINCIPAL INVESTIGATOR ELIGIBILITY
The Principal Investigator (PI) is the individual
responsible for administration and financial management of the
sponsored project and assures that all sponsor, state, and college
policies and procedures are followed during start-up, operation, and
closeout of the sponsored project. He/she may or may not be the author
of the proposal and may or may not have responsibility for day-to-day
conduct of the project. For internal management purposes,
regardless of what the sponsor may allow, a single PI who will have
programmatic oversight and administrative and financial responsibility
for the project must be named. This does not preclude the naming
of other individuals as Co-Investigators (Co-Is) nor does it prevent
other individuals from serving as signatories on the grant/contract
account. However, naming other individuals as Co-Is and giving
them signatory authority does not absolve the PI from the ultimate
responsibility for the conduct of the project in accordance with all
applicable regulations and policies.
The Principal Investigator must be a roster faculty
member or a full-time permanent employee of the College. A
full-time grant funded employee may serve as PI only with the approval
of the cognizant adminstrator(s) (i.e., department chair/unit director
and/or dean/vice-president). For the purposes of this policy, a
full-time grant funded employee is defined as an individual employed on
a grant or combination of grants in a classified or unclassified
position for 40 hours a week for an anticipated minimum period of one
year and for whom grant administration duties are specifically
identified as job duties. Adjunct faculty (including full-time
adjuncts), temporary employees, part-time employees, and students may
not serve as a PI on funded projects administered through ORGA but may
be named as a Co-I. Any person affiliated with the college who
wishes to pursue a grant or contract but who is not eligible to serve
as a PI must identify a roster faculty member or full-time employee to
serve as PI prior to routing the proposal for internal review.
That roster faculty member or full-time employee must agree to accept
full responsibility for programmatic oversight and administrative and
fiscal management of the project.
5.0 PROCEDURES FOR PROPOSAL DEVELOPMENT AND SUBMISSION
5.1 Proposal Development
A request to an external funding
agency is most commonly made in the form of a formal proposal.
Generally, the Principal Investigator is responsible for preparing the
proposal narrative and project budget. Assistance in proposal
preparation and budget development is available from the Office of
Research & Grants Administration. Faculty and staff members
who are interested in pursuing extramural funding are requested to
consult with ORGA early in the project planning stages.
As the proposal is being drafted,
the PI is encouraged to consult with his/her department chair/unit
director and colleagues as necessary, as well as with ORGA, to ensure
that the project is technically, financially, and administratively
sound. It is particularly important to discuss the need for course
release time and applicant cost-sharing or other matching requirements
with the department chair/unit director. Continuing commitments
after the expiration of the grant may require pre-submission review and
approval by such individuals and units as the dean, provost or
vice-president, Business Affairs, and/or the president.
5.2 Budget Development
5.2.1 Direct Costs
Except when a
sponsor requires institutional cost-sharing or other match commitment,
the Principal Investigator is expected to request sufficient funds from
the sponsor to cover all the direct costs that will be incurred during
the conduct of the project. Direct costs include salaries and
wages for all personnel directly assigned to the project; the
proportionate share of fringe benefits; equipment; travel; supplies and
expenses; consultant services; other contractual services; participant
support costs; and subcontract costs. Allowability of costs is
determined in accordance with OMB Circular A-21 (Cost Principles for
Educational Institutions) and applicable South Carolina regulations.
5.2.2 Proportionate Share of Fringe Benefits
The South
Carolina General Assembly requires that “any Agency of the State
Government whose operations are covered by funds from other than
General Fund Appropriations shall pay from such sources a proportionate
share of the employer costs of retirement, Social Security, workmen’s
compensation insurance, unemployment compensation insurance, health and
other insurance for active and retired employees, and any other
employer contribution provided by the State for the Agency’s employees.”
5.2.3 Cost-Sharing and/or Matching Funds
5.2.3.1 Mandatory Cost-Sharing and/or Matching
Some sponsors require an institutional cost-share
and/or matching funds from other entities (i.e., other sponsors,
collaborators, etc.). As a general rule, the Principal
Investigator should provide as much of any required institutional
cost-share as practicable as “in-kind” (e.g., contributions to
the project that have a quantifiable value but do not require the
institution to commit any “new” cash not otherwise already available
for the purpose stated). Also, cost-share should be provided only
in the amount required by the sponsor. Excess cost-sharing is
discouraged and may not be approved by ORGA.
The most common type of in-kind cost-share is a
contribution of personnel time and the related share of fringe benefits
and associated indirect costs (also called “Facilities and
Administration [F&A] costs” or “overhead”). Other
contributions, such as supplies and materials, photocopying services,
and long-distance telephone charges, may be pledged. However,
these contributions must be directly related to the conduct of the
project, and the PI must keep adequate records (such as copies of
purchase orders, photocopier and telephone logs) to document these
contributions. As the documentation of these kinds of
contributions is tedious, they should not be pledged unless absolutely
necessary to meet the minimum required cost-share imposed by the
sponsor.
When cash not otherwise already available within the
control of the PI is needed to meet the sponsor’s cost share
requirement, the PI should first consult with his/her department
chair/unit director and dean/vice-president to determine the
availability cost-share funds from those sources. If additional
cash cost-share is still needed, the PI may request funds from the
Academic Match account, which is administered by ORGA. The
request should be sent to the Director of Research & Grants
Administration via e-mail and must document sponsor requirements, the
total amount of cash cost-share needed, the amounts pledged by the
department chair/unit director and/or dean/vice-president, and the
amount of request for Academic Match funds. If the proposed
expenditure is for major equipment or instrumentation (excluding
general purpose computers), the PI may request that all of the required
cash cost-share be provided from the Academic Match account.
Academic Match pledges are subject to availability of
funds.
The PI must provide documentation of all
commitments of mandatory cost-share from internal sources and/or match
from external sources to ORGA prior to proposal submission to the
sponsor. Upon receipt of award, the PI will be responsible for
regular and timely documentation and reporting to Grants Accounting of
all pledged cost-share and external match during the conduct of the
sponsored project and through grant closeout.
5.2.3.2 Voluntary Cost-Sharing and/or Matching
Proposing voluntary cost-share or
match when the sponsor is silent on the issue is strongly
discouraged.
If a sponsor encourages, but does
not require, cost-sharing and/or matching, the PI may describe, without
quantifying the value of, institutional or other contributions to the
project in the proposal narrative and/or the budget
justification. However, no dollar value should be assigned to
this cost-share and/or match in the line-item budget or on the proposal
cover sheet.
Any deviation from this policy
prohibiting quantification of voluntary cost-sharing or matching must
be approved by ORGA prior to submission of the proposal to the
sponsoring agency.
5.2.4 Indirect
Costs (also called “Facilities & Administration [F&A] Costs” or
“Overhead”)
Indirect costs
are those costs incurred by the College that are not readily
identifiable with a specific project, program, or activity but which
are necessary to the general operation of the organization. These
are costs of operating the facilities and may include the costs of maintenance, depreciation,
general and departmental administration, utilities, janitorial
services, accounting and purchasing services, research administration
and accounting services, library operations, etc.
5.2.4.1 Waiver of Indirect Costs
The Principal Investigator should
include in the project budget the maximum amount of indirect costs that
the sponsoring agency allows according to the agency’s written policies
and procedures. The PI is not authorized to negotiate
reduced indirect costs or indirect cost waivers with sponsoring
agencies without prior approval of ORGA. Should need for
negotiation be anticipated, the PI should contact ORGA well in advance
of budget development and proposal submission so that the matter may be
addressed. Procedures for requesting a reduction in or waiver of
indirect costs are detailed in College’s “Reduction in or Waiver of
Indirect Costs on Sponsored Projects” policy. In consideration of
requests for reduction in or waiver of indirect costs, ORGA will ensure
compliance with the South Carolina Federal and Other Funds Oversight
Act (SC Act 651).
5.3 South Carolina Federal and Other Funds Oversight Act (SC Act 651) Compliance
5.3.1 General Requirements
The South
Carolina Federal and Other Funds Oversight Act (Chapter 65, Title 2 of
the 1976 Code) states that the College may not receive or expend
federal or other funds unless they are authorized in the annual state
Appropriations Act. The College must include anticipated federal
and other funds in its annual budget submission to the State Budget and
Control Board (SCBCB). This function is carried out by the Grants
Accounting Office with assistance from the Office of Research &
Grants Administration.
The College
may receive and expend unanticipated federal and other funds which are
not included in the Appropriations Act throughout the year, but only if
it submits an expenditure proposal for each project to the SCBCB.
The College must receive authorization from the SCBCB prior to receipt
and expenditure of these grant or contract funds. Turnaround time
for such authorization can take from one week to one month.
The Act
further states that the College “shall recover the maximum allowable
indirect costs on ...[federally funded] projects, subject to applicable
federal laws and regulations” and that “all indirect cost recoveries
must be credited to the general fund of the State, with the exception
of recoveries from research and student aid grants and contracts.”
5.3.2 Exemption of Research Projects
The South
Carolina Federal and Other Funds Oversight Act specifically exempts
research grants from the above prior review provision. (ORGA
reports research awards to the SCBCB after receipt.) A research
grant is defined as "an award of funds from the United States
Government or other entity for the principal purpose of systematic
study and investigation undertaken to discover or establish facts or
principles. The principal purpose of a 'research grant' is not to
provide services to the public or to the employees or clients thereof."
Although
research awards are also exempt from the indirect cost recovery
requirement, the PI is expected to request full indirect costs from the
sponsor in accordance with the sponsor’s normal operating
procedures. Any request for a reduction in, or waiver of,
indirect costs on a research project must be filed in accordance with
the Policy on Reduction and Waiver of Indirect Costs and must be
approved by ORGA. The PI is not authorized to negotiate a reduced
indirect cost rate or an indirect cost waiver with the sponsoring
agency without prior approval of ORGA.
5.3.3 Exemption of Small Projects (Awards of $200,000 or Less per Year)
Awards of
$200,000 or less per year are also exempt from the prior review
provision of Act 651. (ORGA reports these awards to the SCBCB
after receipt.) Although these awards are also exempt from the
indirect cost recovery requirement, the PI is expected to request full
indirect costs from the sponsor in accordance with the sponsor’s normal
operating procedures. Any request for a reduction in, or waiver
of, indirect costs must be filed in accordance with the Policy on
Reduction in and Waiver of Indirect Costs and must be approved by
ORGA. The PI is not authorized to negotiate a reduced indirect
cost rate or an indirect cost waiver with the sponsoring agency without
prior approval of ORGA.
5.3.4 Assurance of Compliance
To ensure
compliance with the South Carolina Federal and Other Funds Oversight
Act, the president has designated the Office of Research & Grants
Administration as the responsible unit within the College for
classifying proposed projects (research or non-research), for obtaining
authorization from the SCBCB for expenditure of grant and contract
funds, for ensuring that full indirect costs are recovered on
non-research awards greater than $200,000 per year in accordance with
state law, and for reviewing and acting on requests for reduction in
or waiver of indirect costs for research projects and for small
non-research projects (awards of $200,000 or less per year).
5.4 Internal Proposal Review
5.4.1 Pre-Award Proposal Routing Process
When the proposal is finalized, a Pre-Award Proposal
Routing Sheet, which is available on-line at
<http://www.orga.cofc.edu/>, must be completed. ORGA staff will
assist as necessary in the completion of the Routing Sheet. The
Routing Sheet must first be signed by the PI and then must be
submitted, along with a copy of the proposal, to the PI’s department
chair/unit director for official approval. After the department
chair reviews and signs the routing sheet, the package is sent to the
dean/cognizant vice-president for review and signature. When both
the department chair/unit director and the dean/cognizant
vice-president have signed the Routing Sheet, the package is forwarded
to the ORGA for final review and approval.
5.5 Proposal Review by the Office of Research & Grants Administration
5.5.1 Required Review Time
The Office of Research &
Grants Administration requests two working days for review and approval
of proposals. When submission deadlines preclude this review
period, the PI is advised to notify the ORGA while the proposal
narrative and budget are under development. ORGA may request a
draft narrative and budget for review prior to proposal completion.
This will facilitate an expedited review of the final proposal.
5.5.2 Authorized Institutional Official Signature
The Authorized Institutional
Officials for all grant and contract proposal submissions are the
Director and Assistant Director of ORGA. Faculty and staff are
not authorized to sign for the institution for any grant or contract
proposal submission. ORGA will not approve proposals for
submission until the department chair/unit director and the
dean/cognizant vice-president have signed the Pre-Award Proposal
Routing Sheet and all commitments of institutional cost-share and
external match have been documented. In some cases, particularly
where the proposed project carries a continuing obligation for the
college beyond the award expiration date, ORGA staff may consult with
institutional vice-presidents and/or the president before approving a
proposal for submission.
5.6 Proposal Submission
Following ORGA approval,
the PI may submit the proposal to the funding agency.
Photocopying and mailing are the responsibility of the
PI.
6.0 AWARD NEGOTIATION, ACCEPTANCE, AND PROCESSING
6.1 Award Negotiation
The sponsor may require
modifications to the proposed scope of work or to the project budget
prior to issuing a grant award or contract. Primary
responsibility for this negotiation rests with the Principal
Investigator, although it is strongly recommended that he/she involve
ORGA in all negotiations. Involvement of ORGA is required when
changes in time and effort commitment, indirect cost rate, or
cost-share or match commitments are considered.
Generally speaking, the rules and
regulations of the sponsoring agency and the policies and procedures of
the college that governed the original proposal submission remain in
effect through negotiations. Any changes in the proposed scope of
work or budget require approval of the Office of Research & Grants
Administration prior to submission to the sponsoring agency. Such
approval will be based on careful analysis of the proposed changes and
the anticipated impact on both the project and the institution.
ORGA may consult with the PI’s department chair/unit director and/or
dean/cognizant vice-president before approving modifications to the
scope of work or revisions to the project budget.
6.2 Award Acceptance
All official notices of grant award and contracts should be forwarded
immediately to the Office of Research & Grants
Administration. ORGA staff will review the award documents to
ensure that the interests of the institution and the Principal
Investigator are protected. ORGA may negotiate the terms and
conditions of the award with the sponsor. When an agreement with
the sponsor is reached, ORGA will officially accept the award.
The PI is not authorized to accept a grant award or sign a sponsored
project contract on behalf of the institution. The Director and
Assistant Director of ORGA are the Authorized Institutional Officials
for grant award acceptance and sponsored project contracting.
6.3 Post-Award Processing
Upon acceptance of the award or execution of the
contract, ORGA will complete a Post-Award Data Collector which
summarizes information about the project, the budget, and the terms and
conditions of award. All pertinent project information will then
be forwarded to the Grants Accounting Office in the Office of the
Controller. Grants Accounting will open a new unique account for
the project.
6.4 Grants Accounting Orientation
The PI is expected to participate
in an orientation provided by the Grants Accounting Office prior to
expenditure of project funds. During this orientation, the terms
and conditions of the award will be reviewed, instructions for viewing
account information on-line will be provided, and any questions the PI
has regarding fiscal management of the project will be answered by
Grants Accounting staff. An authorized signature form for the
grant account will also be completed at that time.
6.5 Risk Accounts
Occasionally, a PI will be
notified that a proposal has been recommended for funding but funding
has not yet been officially approved or funding has been approved but
the official award paperwork is delayed. In such cases, with
proper documentation of the anticipated award, the PI may request
establishment of a “risk account” so that work on the project may
begin. PIs who wish to request a risk account should consult with
ORGA. If ORGA determines that a risk account is necessary or
desirable, the department chair/unit director must first agree to
accept responsibility for any expenditures incurred and/or any
uncancellable obligations if for any reason funding does not
materialize.
7.0 ADMINISTRATION OF SPONSORED PROJECTS
7.1 Project Administration and Fiscal Management
The PI has primary responsibility
for the technical conduct of the funded project and for the management
of all project funds. He/she is responsible for completing and
filing all technical reports, including required interim progress
reports and the final project report.
7.2 Grants Accounting
The Grants Accounting Office
provides all financial accounting and fiscal reporting and invoicing
services. The PI is not authorized to submit invoices or fiscal
reports to the sponsoring agency. If a combined technical and
fiscal report is required, the PI should coordinate submission with the
Grants Accounting Office.
The Grants Accounting Office also
maintains the official institutional records for grants and contracts
and provides such information for reporting proposes as requested by
College officials, sponsors, and auditors.
8.0 Research Protections & Compliance
The PI is responsible for complying with all
institutional policies and procedures related to research ethics
(including the use of human participants in research, the care and use
of animals in research and instruction, and misconduct in research and
scholarship), conflict of interest, and intellectual property.
These policies are available on the ORGA website at
<http://www.orga.cofc.edu/
>.
9.0 RESPONSIBILITIES OF THE PRINCIPAL INVESTIGATOR
The PI has primary responsibility for the following tasks:
- Conceptualizing the project
- Selecting an appropriate sponsor for the proposed project
- Developing the proposal narrative and project budget
- Identifying the source(s) of any required cost-share
or matching funds and securing approval for those funds from the
department chair/unit director, dean/vice-president, ORGA, or external
sources
- Completing a Pre-Award Proposal Routing Sheet to accompany the proposal for the internal review process
- Securing all necessary institutional approvals prior to submission of the proposal to the funding agency
- Participating in negotiation of the grant award or contract with ORGA Administration
- Maintaining satisfactory progress in the technical conduct of the project
- Complying with ORGA policies and procedures including
conflict of interest; misconduct in research and scholarship; the use
of human participants in research; the care and use of animals used in
research and instruction; and intellectual property
- Complying with state regulations and institutional
policies and procedures including those related to human resource
management, procurement, travel, and research safety
- Responsibly managing project funds, including
expending funds within the project period and within designated budget
categories Requesting budget modifications and no-cost extensions
through ORGA Completing and submitting technical reports according to
established time schedules Certifying time and effort to ORGA in a
timely manner Providing documentation of grant/contract expenditures and
cost-share and external matching contributions to the Grants Accounting
Office in a timely manner
- Assisting Grants Accounting in account closeout
10.0 RESPONSIBILITIES OF THE DEPARTMENT CHAIR/UNIT DIRECTOR
The department
chair/unit director has primary responsibility for the following tasks:
- Encouraging faculty and staff to seek external
funding for research, curriculum development, training, and community
service projects
- Serving as a mentor for junior faculty and faculty
and staff members who have not had extensive experience in seeking and
managing external funds
- Assisting the PI as necessary in preparing the
proposal, with particular emphasis on technical aspects of the project
and with special attention to proposed protocols involving human
research participants or use of animals Assessing departmental personnel
needs in light of grant and contract activity and approving faculty and
staff effort proposed for the project
- Assisting the PI in identifying source(s) of required
institutional cost-share and external matching funds (cash and in-kind)
if required by the sponsor and certifying the availability of such
funds via signature on the Pre-Award Proposal Routing Sheet
- Approving the PI’s request to the sponsoring agency via signature on the Pre-Award Proposal Routing Sheet
- As necessary, participating in negotiation of a grant or contract
- Consulting with the PI as necessary to ensure that work on the sponsored project is progressing satisfactorily
- For sponsored projects involving human research
participants, animals, or biohazards, providing sufficient oversight to
ensure compliance with governmental regulations and institutional and
professional standards
- Assisting the PI as necessary in solving technical problems with the conduct of the sponsored project
- To the extent necessary, assisting the PI in completing and submitting technical reports on time
- Assisting the PI as necessary in managing project funds
- Monitoring as necessary to ensure that funds are
expended within the project period and that budget categories are not
excessively overspent In the event of audit exceptions, disallowances,
or over-expenditures, providing funds from departmental sources (or
securing them from some other source) to correct negative sponsored
project account balances
11.0 RESPONSIBILITIES OF THE DEAN/COGNIZANT VICE-PRESIDENT
The dean/cognizant vice-president has general
sponsored project oversight responsibilities. His/her signature
on the Pre-Award Proposal Routing Sheet indicates that the sponsored
project will aid in the transmission of new knowledge to society, will
train individuals for participating in complex technologies, will
provide support for building and expansion of specialized facilities
and equipment, or will otherwise provide some benefit to the
institution in keeping with its mission. The signature of the
dean/cognizant vice-president also indicates approval of time
commitments and institutional in-kind and cash cost-share. and
acceptance of responsibility for match commitments made by external
parties. In the event of audit exceptions, disallowances, or
over-expenditures that cannot be covered with departmental/unit funds,
the dean is responsible for identifying funds to correct negative
sponsored project account balances.
Proposed Revision:
ORGA
12-07-2002
Review:
Academic Affairs and
Deans 01-22-2003
Review:
Faculty R&D
Committee
02-20-2003
Effective Date:
02-20-2003
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