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For a good laugh, send in your vendor’s HRA for review and grading

For some reason in the last few months I’ve been deluged with requests to review health risk assessments (HRAs). Optum and Cerner top the list with multiple requests for review, while Wellsource, Redbrick, Healthmine and of course Interactive Health are also represented.  Virgin Pulse too, but since it was only once and since it was with an NDA, I can’t review it except to say that any company that wants a leg up in its own marketplace should urge its closest competitors to use Virgin Pulse and insist that their employees take all the advice.

Among these HRAs, one stands out as worthwhile…and as we get into the reviews over the next month, you’ll see which one.  The others shouldn’t be used, or perhaps, since for some reason employers refuse to stop using them, they carry a warning label advising employees to ignore most of the advice. The good news is that, even absent a warning label, most employees are possessed of enough common sense not to take advice from HRAs.

In other cases the advice would be straightforward and correct, like telling heavy drinkers to “cut down on your drinking,” except that virtually no heavy drinker actually admits it on an HRA.  (And that particular advice, repeatedly many different ways, is about as useful as telling a depressed person to cheer up.)

You may recall that Wellsteps–the self-proclaimed “best” (meaning “worst”) program in the industry, reported only 20% of employees as drinking (meaning “70%,” the US average), and none to excess (meaning “10%,” the US average).

The self-reported smoking rate? 3%…and most smokers only smoke 3-4 days a week. How silly is that! Everyone knows smokers smoke 5 days a week, with time off for weekends, major holidays, and Beethoven’s Birthday.

In the Soviet Union, workers had a saying: “We pretend to work. They pretend to pay us.” In HRAs, it’s: “We pretend to tell the truth. They pretend to believe us.”

Your mission, should you choose to accept it

If you are an HRA user, you can have your vendor’s HRA reviewed just by giving me a username (maybe your username — you can always go in and change the answers back later if you like) and password.

If you are a vendor and want your HRA reviewed with an eye towards improving it, I can review it privately for a fee.  We would then both agree whether the review can be placed publicly. You would also have the opportunity to say publicly what improvements you are planning on, based on the review.

What would be an example of a question that truly epitomizes what an HRA is all about, that will put a smile on our face?

Well, since you asked…

Um, who isn’t going to say they are a good person?  Think this over a bit harder than Optum did before they decided to highlight this question as an example of their very stable geniusness:

  1. If you are a good person, then by definition, you will answer that you are a good person
  2. If you are not a good person, then by definition, you will answer that you are a good person

Example: Walter White thinks he’s a good person.

Even outcomes-based wellness vendors think they are good people, though not so good that they are willing to have me review their offerings. That’s why it’s up to you.


Candidate running against forced wellness programs…WINS!

Paul Kramschuster, as mentioned last month on this website, launched a single-issue campaign for school board in Kansas City. Needless to say, that issue was: wellness.  Blue Cross of Kansas City, CBIZ and Healthmine all had their hands in this cookie jar, at the expense of taxpayers and teachers.

He took them on…and won, becoming the second candidate (out of two in total) to win an election on a single-issue anti-“pry, poke and prod” platform.

In this hyperpartisan political environment, isn’t it reassuring that there is an issue that can unite both liberals and conservatives?


A look back on the 5 years since Cracking Health Costs

Five years ago this month Tom Emerick and I sent out our first advance copies of Cracking Health Costs, never guessing that the book would itself “crack” the 10,000-copy plateau despite Wiley’s insistence on pricing it to make themselves a profit rather than for us to sell lots of copies. (Though if you haven’t got a copy yet, there is good news: Amazon now says “you can save an extra $2.18 at checkout.”)

Cracking attacked much of the industry power structure, way before it was fashionable to do so. (Today, of course, thanks to Dave Chase and a host of others that I dare not name due to the risk of leaving someone out, attacking the power structure has itself become a thing.)  As a result, the book wasn’t terribly popular in many quarters. The Wellness Ignorati, for example, want nothing to do with it. Cracking, by the way, was the book that coined the term “Wellness Ignorati,” to describe wellness vendors and consultants who chose to ignore the fact that none of their numbers add up. Not in 2013, not now, not ever.

Some have said to call someone a member of the Wellness Ignorati was an insult. But it’s actually quite the compliment. With the exception of Wellsteps’ Steve Aldana, who has finally learned to shut up – and HERO’s Ron Goetzel and Paul Terry, who for some reason thought they could circulate a poison-pen letter to the media and not have it end up in my hands – these people have figured out that the only way to win a news cycle with us is not to participate in one.

Otherwise, here is the litany of what happens when they do create one.

A good way to see how the book has aged is to dissect the most critical review it received on Amazon, to see how it held up. This review was written by Keith McNeil, whom I have subsequently met online. He obviously put a lot of thought into it, and it deserves an equally thoughtful response. And he does have good points. (Keith, if you’re reading this, the good points come later…)

Oh, yeah—and he managed to accomplish something that none of the very stable geniuses at HERO have ever done, which is catch me with my finger on the scale.

Customer Review

2.0 out of 5 stars

A missed opportunity

By Keith McNeil on October 3, 2013

Format: Hardcover |Verified Purchase

This book has some valuable information, worthy of the two stars that I give it, but I believe it has flaws that are structural and not incidental. In the world of workplace wellness, Al Lewis and Tom Emerick (along with Vik Khanna) have created somewhat of a cottage industry by being contrarians and iconoclasts.

As is often the case with “contrarians and iconoclasts,” we are now the majority view in most of the sentiments in that book. (Not that it matters whether we are the majority, since math is not a popularity contest.)

There is nothing wrong with that to the extent that they are right and consistent in their approach, but I don’t believe that is always the case. As a matter of style, I think the book is diminished by its apparent attitude that while most of the consulting, brokerage, and wellness industry is driven by know-nothing, commission-grabbing individuals who think only of themselves and not the client, Emerick and Lewis are to be considered unbiased and pure as the wind-driven snow– while they actively sell their books and promote their consulting practices, speaking engagements, etc.

Yep, this is the case. Many wellness vendors are lying – just plug the name of your vendor into the “search” box.  PBMs were another target of the book…and one just recently had to disclose in court that they were taking money under the table. Patient-centered medical homes turned out to be a scam as well.

And in terms of our being “unbiased and pure as the wind-driven snow…”  We are indeed biased – biased in favor of what works.  We ask everyone, if you think we are wrong in our bias, point it out. Tom and I between us have maybe 500,000 words in print at this point. However, there is an exception below—that Mr. McNeil insightfully called us out on. He was the only one to catch it.

I give it at least two stars because I think their books (which includes the book by Al Lewis, Why Nobody Believes the Numbers) do contain valuable information, as I said above, the industry is served by such contrarians who second guess the assumptions and numbers often given out (some of which they show are clearly wrong).

(Blushing) Thank you.

Nonetheless I have found a different book–by John Torinus, Jr., “The Company that Solved Health Care”–more valuable for most employers below the Fortune 1000 level and more filled with valuable ideas on how to get employees engaged and bend the cost curve. (For the record, I have no financial interest in that book and have no personal or business connection with its author.)

It turned out that Mr. Torinus “solved” healthcare by shifting a large chunk of the cost to his employees. He claimed large reductions through wellness, but when I asked him, in a conference, what reduction he got in actual wellness-sensitive medical events to support that claim. He replied that he didn’t know, but that his company’s annual death rate was “only 3%.”

“3%?” I asked. “What does your company make? Asbestos?”  He immediately lost all credibility with everyone in the room. The actual death rate in the workplace is not 30 per 1000, but rather 30 per 1,000,000. In wellness, though, as I’ve subsequently observed, mistakes of three orders of magnitude are quite common. This was just the first such mistake I had ever heard.

As a broadbrush review, the Emerick|Lewis book can generally be categorized as one that believes the traditional wellness programs, health risk assessments, and biometric screenings are at best generally worthless and at worst actually harm people.

Yep. At least for outcomes-based programs. Participation-based programs don’t encourage cheating, so they are likely harmless. And if done according to guidelines, beneficial albeit unprofitable.

After beating up on most of the industry, Emerick then tries to come up with initiatives and programs that do in fact work. One of them, using Centers of Excellence, is hardly new, but Emerick tweaks it by using the term “Company-Sponsored Centers of Excellence.” (I presume that Emerick did a fine job of selecting his network and went well beyond just going with whatever organizations called themselves a Center of Excellence, which he points out can be quite deceiving.)

Yep. Tom was way ahead of his time on this one. It is fairly common among very large companies to direct employees. Walmart, for example, now considers claims for certain procedures to be out of network if they are not done at a “company-sponsored center of excellence.”

Then, after trashing most wellness plans, he heavily promotes what they consider to be wellness that works, which focuses on the employee’s “well-being.” In so doing Emerick touts, for example, the wellness vendor Healthways in its efforts along those lines. He cites studies that correlate the perception of an employee’s well-being to actual healthcare costs, with a higher sense of well-being leading to lower healthcare costs. Other than a reference to having a beautiful cafeteria and cleaning the bathrooms, the advice on how to actually increase the perceived well-being of the employees is conspicuously absent.

Mr. McNeil is completely right about this. It was a correlation, not causation, and Healthways never delivered any evidence of causation. To be perfectly honest – and at the risk of admitting that we were not “pure as the wind-driven snow”– Healthways did offer to buy a large number of books in advance if we added this chapter. The information in the chapter is correct (we can’t be “bought” to lie), but it is correlation, not causation.

He is also spot-on about our not having any “What should you do instead?” advice to “actually increase the perceived well-being of the employees.”  It took another couple of years before the Quizzify lightbulb went off in my head. (Tom did indeed segue into medical travel, and is now CEO of Edison Health.)

The authors pillory most wellness vendors when, after performing their own analysis, they conclude the cost for those programs will not be returned in plan savings; but nowhere do they discuss the obvious issue of the cost to increase employee well-being. For that, their analytical skills suddenly are either turned off, or in the case of Lincoln Industries, one of the book’s real well-being success stories, the book is egregiously awry. (Emerick in the book gave fantastic well-being success rates for Lincoln Industries, but added that “resident outcomes expert Al” had not yet reviewed their findings–but he had. The Emerick book was written in early 2013, as is clear by its 2013 cited sources, but in mid-2012 Lewis posted on the Web an attack on the supposed wellness gains at Lincoln Industries–note, he made no reference to “well-being” at Lincoln Industries–and said instead of having great savings they in fact really gained nothing according to his analysis. So how did Lincoln Industries end up as a wild well-being success story in the book?)

Touche!  Mr. McNeil is completely right about this too. Here is the back story. Lincoln’s information was obviously wrong, and I presented it on my previous website as such, as Mr. McNeil notes. I then got a cease-and-desist letter from them, so I took it down. That’s when I had the insight that the way that the way to “attack” people who make up numbers is with satire (which the Wellness Ignorati refer to as “sarcasm – in addition to lacking access to the internet they apparently lack access to a dictionary). Since then, I haven’t been able to beg a lawsuit out of anyone in the industry.

AARP v. EEOC update: March 30 “progress report” issued by EEOC

In December, Judge Bates’ ruling in AARP v. EEOC (all the background is here) required the first progress report on the drafting of new incentive/penalty rules to be issued in March. We predicted there wouldn’t be any progress to report, and we were right.

A more passive-aggressive response from EEOC, submitted an hour before the deadline no less, could scarcely be imagined:

[We do] not currently have plans to issue a notice of proposed rulemaking addressing incentives for participation in employee wellness programs by a particular date certain, but [we] also have not ruled out the possibility that [we] may issue such a notice in the future.

They also noted that the top two positions at the agency remain unfilled, with nominees awaiting Senate confirmation, which makes major policy-making difficult.

The EEOC also said, according to the article linked above, that they haven’t decided whether “to float a new rule or leave its regulations as they are.”

Imagine if you are Judge Bates and you’ve told the EEOC to deep-six their old regulations. Three months later the EEOC comes back and says: “Maybe we will and maybe we won’t.”  Either the EEOC didn’t run this by an attorney before they sent it out, or they are deliberately trying to antagonize the judge. Either way, they aren’t doing themselves or the wellness industry any favors.

Meanwhile, the folks at Quizzify, having completed their celebration of the pending demise of punitive “wellness or else” programs, have moved onto drafting a new HRA that will be, uniquely, compatible with the new rules, but still be NCQA-accreditable.  And most importantly actually not be full of nonsense, like most of the others.

An announcement should be forthcoming within a month. Ping them if you’d like the early bird price on this.





New data shows that “outcomes-based” (health-contingent) wellness may save money

April fools!

What follows is an analysis of all hospitalizations in the US from 2001 to 2014.  Wellness–punitive, health-contingent wellness in particular–has apparently harmed more employees than it has benefited.  Here’s the story in one simple graph, comparing the percentage of the hospital admissions that are wellness-sensitive (diabetes, heart attacks) to all hospital admissions. The blue line reflects that calculation for admissions covered by private (commercial) insurance, while the orange line combines Medicaid, Medicare and uninsured. They will have higher absolute rates of these events but it’s the difference of differences that matters:

What can we learn from this analysis?

  • The point-to-point change is -.3% in the non-exposed population (orange) vs. +.1% in the exposed population (blue).
  • The difference of differences should be going in the opposite direction, since essentially every known major factor that could impact this blue line more than the orange line is held constant, other than an increasing penetration of workplace wellness into the blue-line population. Spending about $6 billion more on wellness services in 2014 (vs. 2001) should have made a huge favorable impact on the blue line, given that the total spent on inpatient wellness-sensitive medical events in 2014 was roughly $7 billion, applying the Health Enhancement Research Organization’s estimate of $25,000/admission to the 285,000 relevant 2014 admissions.
  • It’s actually worse.  Only about half the employed population has access to screening and risk assessments, meaning that the size of the industry overwhelms the size of the addressable events even if one assumes that all the diagnoses leading to the events were found in screenings.
  • It might seem absurd to assert that the wellness industry in total (almost $8 billion today) is double the size of the healthcare spending it is supposed to address, but a “bottoms-up” analysis gives the same answer: In the privately insured population, 4.1% of admissions were wellness-sensitive in 2014. Figure half these events take place in people who already know they are at risk or have the diagnosis. So 2% of all admissions involved employees who did not know they had the diagnosis when they had the event — and hence could conceivably have learned about it and avoided it through a wellness program.  Admissions are about half of all costs, meaning 2% of admissions would consume 1% of costs. 1% of a typical $6000/individual employee spend is $60/employee/year. A wellness program, including the screening, likely costs $150. That means even a perfect program — one that finds every employee with a hidden diagnosis, avoids all false positives, and prevents every event without any added cost of prevention therapy– would lose money. Alas, as lovingly documented on this website through the years, a beam of light leaving “perfect” wouldn’t reach the “pry, poke and prod” industry for several seconds.
  • The fairly dramatic upswing starting in events in the exposed population (the blue line) starting in 2012, even as the rest of the country was almost leveling off, correlates quite closely with the move towards health-contingent, or “outcomes-based” wellness, in which employees who don’t crash-diet hard enough before the final weigh-in get fined. So while a study by Redbrick showed no benefit to health-contingent programs, the truth is likely worse: many health-contingent programs actually do harm, as Interactive Health recently demonstrated and for which Wellsteps won a “best-in-industry” award. Much is this harm is visited upon employees with eating disorders.

In case you don’t believe punitive wellness programs could be this bad…

You can ask me for the raw data, and/or replicate this exact analysis, using ingredients you already have in your kitchen — an internet connection (which perhaps even Bravo has acquired by now) and the links below.

It happens that the nation’s hospital admissions data (through 2014) is all publicly available online.  You can see for yourself how badly wellness has failed. First, go to the admissions database. Then under “Analysis setup” go “Trend>yes>yes.” That will bring you to a dropdown menu asking you to “choose how you want to classify the diagnoses or procedures.” Pick “Diagnosis ICD-9-CM codes.”

It will ask you to “Choose your diagnosis.” This is where it gets slightly labor-intensive. You’re gonna want to pick all the heart attack and uncomplicated diabetes codes, since those two categories represent by far the lion’s share of wellness-sensitive medical events (WSMEs), events that can be theoretically avoided through screening the stuffing out of employees. You might ask: “Why not include complications of diabetes, and heart failure etc.? Why just these two?”

That’s because we aren’t testing disease management. We’re testing to see if “playing doctor” to try to hunt for disease is worthwhile. Anyone with complications of diabetes, or a more serious condition like heart failure or COPD, obviously already knows they have it. No screen needed. We also can’t test stroke because the HCUP data prior to 2012 has some squirelliness in it. (In any event, there are far fewer strokes in the working age population than heart attacks, especially if one excludes those where atrial fibrillation was the likely cause.)

Diabetes and heart attack ICD9s begin with 250 and 410 respectively. Once you enter one of those 3-digit codes into the field, a ton of 5-digit codes will show up. Just keep hitting “CTRL click” until they all show up in the field. Then, hit “combine all codes.” Here is what the screen will look like before you do that:

After you enter these diagnoses, choose “Combine all codes” and then “Create analysis.”  You’ll get a screen that looks like this. Do not attempt to adjust your TV set. I am just showing you this so you know you’re in the right place, not to try to see the results:

Once you’ve gotten to this point, you need to split the analysis into payer category and then pick multiple years, to show a trend. To find the payer, use the left-hand navigation bar and go to Patient Characteristics>Payer.  You’ll want to do multiple years, and farther down that toolbar you’ll see “years.” You just check all the years from 2014 back to 2001 and hit “submit.” (There is some squirreliness in the years before 2001.)

Doing this by payer is critical.  Almost every employee with access to workplace wellness will be commercially insured — or as HCUP puts it, privately insured.

You’ll then get a screen that looks like this:

It will give you all the admissions, by payer, for all the years.  You are then given an option to drop this into Excel, an option you should take. (This is the definition of “voluntary,” by the way. Your employer won’t fine you if you don’t.) Once it is in Excel, you can copy-and-paste the actual year-by-year data into an easy-to-use format, like this little snippet that lists stroke-hypertension and then repeats the format for all admissions:”All admissions” becomes the denominator for those 15 years, split into “private insurance” (where over those 15 years members had gained increasing access to wellness programs) vs. the other five categories combined, which did not have wellness access.

After you complete this analysis, you will find that the reason I offered a $3 million reward to show wellness saves money is because there is no chance of anyone ever being able to claim it.

In Kansas City, yet another candidate runs against forced wellness

No sooner did I post Congressional Candidate Runs Hard Against Forced Wellness than I found another candidate doing exactly the same thing.

This candidate, Paul Kramschuster, is running for a school board in Kansas City.  Here is his website.  Teachers in that city’s Center School District have been harassed and forced into wellness, at considerable expense to their school district — which has nothing to show for it other than bills and annoyed employees. Neither Blue Cross of Kansas City nor Healthmine nor their broker, CBIZ, has been able to demonstrate any outcomes.

While a Republican won an election running against wellness in Pennsylvania and a Democrat is running against it in North Carolina, this Kansas City election is nonpartisan. No party affiliations involved. It appears that independents feel the same way about wellness as Democrats and Republicans.

Here are some tidbits from Mr. Kramschuster’s website:

Another argument made by the district’s insurance broker, which is accepted uncritically by the district, is the recommendation that the district purchase a $70,000 wellness program for the district.  The main feature of this program is a blood test and questionnaire asking employees about their drinking habits, their history of disease and what medical tests they have had or plan to have.  Most employees do not want this program and would prefer not to have it. 

The broker, CBIZ, is collecting a nice fee from the district’s taxpayers, who might have otherwise assumed that their school taxes were being spent on educating their children:

In the early years of this program, employees did not participate, and so in order to induce more employees to participate (by giving up their medical privacy), so as to increase the broker’s profit, the broker recommended the district to pay each employee that gives up her medical privacy 

Even the prospect of a bribe doesn’t excite the teachers…

The amount of the payment is $600.  In order to receive this payment, many more employees do participate, but they are very unhappy about it.  It feels mandatory/coercive, and it feels morally wrong.

…and of course the school board has been completely unaccountable:

No one on the board, or in central office, is asking the critically important question: “How does paying teachers to give up their medical privacy serve students?”  The answer, of course, is that it doesn’t — the district is serving its broker, rather than expecting its broker to serve it. 

The school board was given the option of swapping out this onerous program for Quizzify, which teachers love (and they would still earn their $600 by learning how to purchase healthcare more wisely) because of its Q&A format.

However, because it would have cost the District only about 1/7th of what the Healthmine program costs, the broker would have made much less money. It was turned down. Taxpayers are now on the hook for the full $70,000, plus the cost of potential lawsuits…

…I did do some checking: the CBIZ/Healthmine program is not validated by the Validation Institute, neither Healthmine nor CBIZ has signed the Ethical Wellness Code of Conduct, and no member of the school board seems the slightest bit aware that this is exactly the type of program that has been proven to be a complete waste of money.

Or that this is exactly the type of program which, on January 2nd, will be disallowed…and will open up the district and its taxpayers to lawsuits from these very same harassed and demoralized teachers.

Congressional candidate running hard against forced wellness

In this hyperpartisan era, conservatives and liberals agree on only one thing: forcing employees into outcomes-based wellness programs is one of the worst ideas in the history of ideas. If you scroll down our feature In The News, you’ll see wellness gets equal treatment by right-wing publications like Newsmax and The Federalist as well as left-wing publications like Slate and Mother Jones.

Opposing forced wellness has already propelled one candidate into elective office: Matthew Woessner, whose leadership in Penn State’s faculty revolt against the punitive “pry, poke and prod” plan proposed by Highmark and Ron Goetzel, was elected President of the university’s faculty senate. Matthew is a self-described Republican libertarian.

In keeping with the bipartisan nature of wellness, it is fitting that the first Congressional candidate to take on the wellness industry is, conversely, a Democrat, Jenny Marshall. Jenny (as she likes to be called) is running against Virginia Foxx (R-NC5), who chairs the House Committee on Education and the Workforce. A powerful combination of this lucrative committee chairmanship, lack of ethics and a gerrymandered “safe” district (at least until voters find out about this bill), allows Foxx to “represent” the American Benefits Council rather than voters in her district. Indeed, I suspect she has nary a single constituent who supports employees being pried, poked and prodded into submission. It is not at all clear how this bill would benefit her district.

Any controversy over whether forced wellness saves a nickel or even improves health has long since been laid to rest. Hence, the American Benefits Council’s enthusiasm for forced wellness is all about making programs so onerous and unappealing that employees prefer to pay the $1000 fines rather than be subjected to the indignity and potential harms of being pried, poked and prodded by unlicensed, unregulated wellness vendors.

On the other hand, these programs can be very lucrative for employers, who can claw back large chunks of their insurance premiums forfeited by non-compliant employees. Vendors have already figured out how to offer “immediate savings” for employers through collecting these fines from employees.

Unless Foxx’s bill becomes law, this lucrative, misanthropic, anti-employee loophole will be closed December 31, thanks to the ruling in AARP v. EEOC, which will prevent employers from forcing employees into “voluntary” wellness programs.

Foxx’s HR1313, known colloquially as the Employee DNA Full Disclosure Act, would override this common-sense federal court decision.  Worse, it would allow employers to force not only employees but their children into these programs. And not just prying, poking and prodding them, but collecting their DNA as well. Yep, your children’s DNA is fair game if this bill passes.  It is so onerous that even much of the wellness industry opposes it, though they stand to benefit from it.

It is headed for a floor vote sometime this spring, having been voted out of her committee on — get ready — a straight party-line vote.  (So much for the GOP standing for individual rights.)

Jenny Marshall fights back

Jenny has posted a summary of this bill right on her campaign website.  Asked for a comment, she replied: “Foxx’s bill could very well be the worst proposed legislation in the history of Congress. Its intrusiveness would make Orwell blush. I can’t figure out why she would want to invade the privacy of her constituents like this, other than raking in big dollars from lobbyists. For too long now, Foxx has turned a deaf ear to the wants and needs of the people of our district, and for that betrayal should be voted out of her seat.”

You can donate to her campaign

If this bill passes, the very stable geniuses at “outcomes-based” wellness vendors like Bravo, Interactive Health, Wellsteps, Corporate Wellness Solutions, and Staywell will be able to trample employee rights to privacy, fine them and harm them — for no reason other than to enrich their own coffers, and those of their corporate overlords. Absent this legislation, millions will be thrilled to be freed from their anti-employee jihads on December 31 — and employers can find kinder, gentler conventional programs, a la Redbrick or unconventional ones like Limeade (and/or Quizzify, of course) instead.

The way to keep this bill from passing? Vote Foxx out of office.  Shed no tears for her. She will get a lucrative job, possibly representing the American Benefits Council in their quest to collect fines from employees — just like she does now.

Only starting in 2019 her paycheck will come directly from them, as opposed to indirectly, as it does now.

The donation link to Jenny Marshall is here.

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