Number of For-Profit Hospices Has Grown; Current Measures and Standards Are Not Sufficient to Assess Hospice Quality
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1 January 2010 Report No Number of For-Profit Hospices Has Grown; Current Measures and Standards Are Not Sufficient to Assess Hospice Quality at a glance The 2006 Florida Legislature authorized for-profit entities to operate hospice programs and required the Department of Elder Affairs to develop quality and effectiveness measures for Florida hospices and submit an annual report analyzing these outcome measures. Since that time, six additional for-profit hospices have opened in Florida (current total of 13). While the department has established three outcome measures for evaluating hospice quality, preliminary analyses suggest these measures and their standards may not be sufficient to identify meaningful differences among hospices. The department should consider adopting additional measures to better assess hospice quality and effectiveness and take steps to ensure that data reported by hospices is complete and accurate. Scope As required by Ch , Laws of Florida, this report examines Florida s hospice programs and the Department of Elder Affairs efforts to assess the quality of hospice care. 1 Background Hospice care is an alternative approach to the traditional medical model for end-of-life care. Hospice programs specialize in providing basic medical care, palliation, and pain management, and social, psychological, and spiritual support to 1 OPPAGA initially examined the program in 2006; see Florida s Certificate of Need Process Ensures Qualified Hospice Programs; Performance Reporting Is Important to Assess Hospice Quality, OPPAGA Report No , March terminally ill individuals and their families. 2 Hospice care focuses on providing end-of-life care that allows patients to die with dignity and free of pain. It also provides support to patients families when caring for their loved ones and during the grieving process. In Fiscal Year , Florida hospice programs provided approximately 7.6 million days of patient care to more than 104,000 individuals with terminal illnesses at an estimated cost of $ billion. Eighty-four percent of these admitted patients were age 65 years or older and 35% had a diagnosis of cancer. 4 Hospice programs are largely funded by payments for patient care. The 58 hospice programs that responded to our survey indicated that 97% of their revenues in Fiscal Year came from patient care reimbursement, 2% from charitable contributions, and 1% from other sources. These hospice programs received a total of $1.49 billion in patient care reimbursements, with payments received by individual programs ranging from $1.8 million to $287 million. The programs collectively received $31.1 million in charity contributions, ranging from $0 to $4.3 million. 2 Palliation refers to care that relieves or soothes symptoms of disease. 3 Florida hospice-specific data presented in this report is based on an OPPAGA survey of hospice programs regarding patient days, profit status, revenue sources, and Medicare Quality Assurance and Performance Improvement System implementation. Fifty-eight out of Florida s 64 hospice programs responded to our survey. The hospices that responded represented 98.4% of total hospice admissions for Fiscal Year Demographic information on patient age and diagnoses were reported in the Agency for Health Care Administration s Florida Need Projections for Hospice Programs, October 2009.
2 OPPAGA Report Report No Exhibit 1 Medicare and Medicaid Reimbursed Hospice Programs for 94% of Patient Care in Fiscal Year % 3% 3% Medicare 77% Source: OPPAGA hospice survey. Medicaid Private Insurance and Self Pay Uncompensated Care and Other Hospice reimbursements for patient care are largely from Medicare and Medicaid. As shown in Exhibit 1, in Fiscal Year , Medicare and Medicaid reimbursed approximately 94% of the care provided. Private insurance and patients paid approximately 3% of the total while the remaining 3% of patient care was uncompensated or paid from other sources. Florida s hospice programs provide a variety of services to meet the medical, social, psychological, and spiritual needs of terminally ill patients and their families. Both state and federal law mandate that hospice programs provide specific services including needed medical care, pain management and palliation, and bereavement care and counseling to help patients and families deal with the emotional aspects of dying. 5 Exhibit 2 details these services for Florida hospice programs. Exhibit 2 Florida Law and Federal Medicare and Medicaid Regulations Require Florida Hospices to Deliver Eight Services 5 Hospice care is typically provided to patients in their own homes or residences such as nursing homes or assisted living facilities. Patients can also receive hospice care in a freestanding hospice inpatient facility or residential unit a home-like setting to provide care to patients with no available caregiver or to provide short-term care for pain management, symptom control, or respite care. Service Description Nursing Care Care provided by or under the direction of a registered nurse Medical Social Services Services provided by a social worker under the direction of a physician Physicians' Services Medical care performed by a doctor of medicine or osteopathy Counseling Services Counseling provided to the patient and family members or others caring for the patient at home, including bereavement, dietary, and spiritual counseling Short-Term Inpatient Care Inpatient care provided in a participating hospice inpatient unit, hospital, or skilled nursing facility for pain management and symptom control or a means of providing respite for the patient s family or other persons caring for the patient at home Medical Appliances and Supplies, Medical supplies provided for the care of the patient, which may include durable medical equipment, medical Including Drugs and Biologicals supplies, and other self-help and personal comfort items, as well as drugs and biologicals if they are used primarily for the relief of pain and symptom control related to the illness Home Health Aide Services Home health aide, such as personal care and homemaker services, provided by qualified home health staff Physical Therapy, Occupational Therapy, Therapies provided to enable the patient to maintain activities of daily living and basic functional skills and Speech-Language Pathology Services Source: Center for Medicare and Medicaid Services, The Hospice Manual, Ch. 2, Coverage of Services; s , F.S. 2
3 Report No OPPAGA Report Both the Department of Elder Affairs and the Agency for Health Care Administration (AHCA) have responsibilities for Florida hospice programs. 6 The Department of Elder Affairs establishes rules in consultation with AHCA to guide the provision of hospice care, and AHCA regulates hospice programs through a Certificate of Need process and licensure. To be authorized to operate in Florida, potential hospice programs must apply for a Certificate of Need after AHCA determines that an unmet need exists in one of its 27 designated hospice provider service areas (see Appendix A for a map of these 7, 8 areas). After receiving a Certificate of Need, hospice programs must also apply for and receive state licensure as well as certification from Medicare and Medicaid that they meet minimum standards to ensure safety, staffing qualifications, and level of services. 9 AHCA conducts licensure inspections every year for hospices first three years of operations and every two years thereafter if there are no deficiencies or problems. 10 If AHCA finds deficiencies, the hospice program must develop a corrective action plan to correct the deficiency within a reasonable amount of time. AHCA also conducts federal Medicare and Medicaid certification reviews at least once every six years. The 2006 Florida Legislature authorized for-profit entities to operate hospice programs in Florida providing they meet the state s Certificate of Need 11 provisions. Until that time, Florida law required 6 Sections and (3), F.S.; Ch. 58A-2, F.A.C. 7 The Certificate of Need process regulates the number of hospice programs that can operate in Florida and requires programs to demonstrate their expertise, financial capacity, and commitment to serve terminally ill individuals and their families as well as the community. 8 A hospice program also may submit an application demonstrating a special need for hospice services, such as serving an underserved segment of the population even if AHCA has not projected unmet need. 9 AHCA staff conduct an unannounced inspection of every newly licensed hospice to ensure that the program meets required Medicare and Medicaid certification conditions. 10 In 2008, 16 of Florida s hospice programs reported to the Department of Elder Affairs that they held national accreditation. Several national organizations offer accreditation programs to the hospice industry, including the Accreditation Commission for Health Care, Inc.; the Community Health Accreditation Program; and The Joint Commission. 11 Chapter , Laws of Florida. hospice programs to operate as not-for-profit corporations unless they were incorporated before July 1, In addition, as recommended by OPPAGA, the Legislature directed the Department of Elder Affairs to develop outcome measures to assess the quality and effectiveness of Florida hospice programs and to develop an annual report analyzing these outcome measures as well as other information reported by hospices. Findings The number of for-profit hospices in Florida has increased slightly; hospice growth controlled by Certificate of Need process Since the 2006 legislative changes, the number of hospice programs operating in Florida has increased from 55 to In addition, the number of hospice service areas that have multiple hospice providers increased from 15 to 17 (see Appendix A for a list of the hospice programs by service area). During this period, the number of Florida hospice programs operated by a for-profit company 14 increased from 7 to 13. Four of the six additional for-profit hospices were new programs, while two were formerly not-for-profit programs but changed their status. Of the four new for-profit hospices, one is operated by a company which also operates the seven for-profit programs that existed prior to the 2006 legislative changes; two are operated by companies that did not previously provide hospice services in Florida; and one is operated by a company that recently converted from not-for-profit to for-profit status. While the 2006 Legislature authorized for-profit companies to operate hospice programs in Florida, it maintained the requirement that hospices cannot operate without a Certificate of Need. The Certificate of Need process helps 12 Hospice programs incorporated on or before July 1, 1978, could change their corporate status to a for-profit or not-for-profit entity and transfer licensure to that entity, while programs incorporated after that date were required to operate as not-for-profit organizations. 13 This represents 64 separate programs operating under 41 licensed entities. 14 This represents a slight increase (from 13% to 20%) in the percentage of Florida s hospices that are operated by for-profit companies. 3
4 OPPAGA Report Report No ensure that new hospice programs have the expertise, financial resources, and commitment to meet the needs of their communities. In addition, this process ensures that new programs operate only in areas of the state where existing hospice programs are not meeting current needs. While the department has established measures to assess hospice quality, preliminary analyses suggest these measures and their standards may not be sufficient As required by law, the department has established outcome measures to assess the quality and effectiveness of hospice programs. 15 However, the department did not adopt a rule promulgating the measures until August 2008, seven months after the deadline required by law, and it has not yet produced an annual report analyzing these outcome measures and other information reported by hospices. 16 Due to this delay, the department has not yet collected sufficient data to assess the overall quality of hospice care in Florida or make comparisons among hospices. The department, with input from Florida hospices, established three outcome measures to assess hospice quality. These measures, as shown in Exhibit 3, assess hospices performance in managing pain and providing medication, as well as customer satisfaction with hospice services. The first measure, which was required by Ch , Laws of Florida, assesses hospice performance in managing their patients pain levels. This measure requires hospices to report the number of patients who indicate they are in severe pain (7 or greater on a scale of 0 10) upon admission and the level of pain for these patients 15 Chapter , Laws of Florida. 16 State law required the department to develop measures by December 31, 2007; however, the department did not have a rule in place for promulgating the measures until August 11, The department cited several factors for its delay in establishing the outcome measures in its hospice rule, including that Ch , Laws of Florida, required several changes to the rule, some of which required agreement among different parties; that the department spent extensive time researching outcome measures; and that the rule was challenged before the department reached consensus with the hospice industry. 4 at the end of their fourth day of hospice care. The performance standard for this measure is that at a minimum, 50% of the patients who report severe pain upon admission should report pain levels of 5 or less by the end of their fourth day. The second measure requires hospices to report the percentage of patients or their families who indicated that the patient received the right amount of medicine for his or her pain. The standard for this measure is that at least 50% of respondents should report that patients received appropriate levels of medication. The third measure requires hospices to report the percentage of patients or their family members who responded that they would recommend hospice services to others; at least 50% of these respondents are to give favorable recommendations. 17 Exhibit 3 The Department of Elder Affairs Established Three Hospice Outcome Measures Outcome Measure Patients who report severe pain (7 or greater on a scale of 0-10) must report a reduction to 5 or less by the end of the fourth day of care on the hospice program Patients or their family members should indicate that the patient received the right amount of medication. Patients or their family members should indicate that the patient, family member, or caregiver would recommend hospice services to others Source: Chapter 58A-2.005, Florida Administrative Code. Standard 50% 50% 50% The department has not yet produced the annual hospice report required by law. The 2006 Legislature directed the department to issue an annual report that analyzes and evaluates the established outcome measures as well as other information that it collects from hospices. However, the department has not yet issued this report. The department did not finalize its rule requiring hospices to report the three measures until August As a result, it collected data from hospice programs for the period from August 11, 2008, through December 31, 2008, and 17 The department selected these two measures based on measures from the Family Evaluation of Hospice Care satisfaction survey, which is a national survey developed by the National Hospice and Palliative Care Organization and researchers at Brown University.
5 Report No OPPAGA Report did not produce an annual report for that year. The department anticipates that it will collect 2009 performance data from hospices by March 31, 2010, and will submit an annual report based on this data by September The department s measures and their standards may not be sufficient to assess hospice performance. The three hospice outcome measures capture important information about hospice care, and preliminary results from available 2008 data indicate that the programs generally performed well in meeting established standards. For example, 97% of the hospices that reported outcome data to the department for the period August through December 2008 reported that they met the 50% standard for decreasing pain to a level of 5 or less by the end of the fourth day. In addition, all of the reporting hospices indicated that they had met the standards for the other two measures. Most (94%) of the hospices that submitted reports indicated that 90% or more of their patients received the right amount of pain medication, and 97% of these hospices reported that 90% or more of the patients or their families would recommend hospice services to others. However, these results also indicate that the measures may not allow the department and other stakeholders to detect differences in quality among hospices. Most notably, these preliminary results indicate that the 50% standard for the measures is too low and that the measures themselves may not be sufficient to detect differences among hospices. For example, the measures require only a yes or no response and thus, do not capture the degree of satisfaction that patients and their families may experience. In addition, the selected measures do not cover all domains of care that can contribute to overall quality, with two of the measures focusing on pain management and the third asking families if 18 The department requires Florida hospices to report aggregate calendar year data on the three outcome measures as well as service and demographic data, such as the number of patients served, their ages, and medical diagnoses. Hospices must report these data, to the department by March 31st of the following calendar year. To assist hospices in reporting this information, the department developed a web-based online form and database that became available for hospices in January The department also has tested the online form, developed a user manual, and provided training to the hospice programs in using the online form. 5 they would recommend hospice care to others. While these are important elements of care, additional measures would provide a more complete picture of whether hospices are meeting the overall needs of their patients, including how well hospices tend to patients emotional needs and how well they support patients families in caring for their loved ones and in the grieving process. The department should assess these measures and their standards to determine the degree to which they relate to quality of care. In doing so, the department should examine Florida hospice data as well as research that addresses hospice quality and include this information in its first annual report. Based on this assessment, the department should consider adjusting the current standards and adopting additional measures to better assess hospice quality and effectiveness. For example, the department should consider additional measures from the Family Evaluation of Hospice Care survey or other instruments that have been validated for assessing end-of-life care. 19 The department should also consider measures that the federal Centers for Medicare and Medicaid Services is currently testing and validating for hospice participation in Medicare. 20 (See Appendix B for a list of these measures.) The department needs to ensure the data reported by hospices is complete and accurate. Our review of the information provided by hospices for the period August to December period identified several reporting issues that, if not corrected, could affect the reliability and 19 Many Florida hospices use this national survey and provide the results to the Florida Hospice and Palliative Care Organization and the National Hospice and Palliative Care Organization. The Agency for Health Care Administration posts data for five of the measures from this survey on its website. These measures assess how well the hospice attended to the patient s needs; if the patient was treated with respect; if the family was kept informed of the patient s condition; overall care that the patient received; and how well the hospice responded to patient needs in the evenings and weekends. The agency selected these five measures based on an independent assessment of the Family Evaluation of Hospice Care satisfaction survey. The following is a link to the agency s webpage that shows survey results for hospice programs CFR In order to receive Medicare reimbursement, hospices must develop a Quality Assessment and Performance Improvement System that includes indicators to measure several aspects of hospice care, including indicators of quality, adverse incidents, hospice services, and operations.
6 OPPAGA Report Report No usefulness of reported outcome information. Response rates varied considerably among hospices, with aggregate results based on from 15% to 84% of patients or family members responding. While it is not unusual for survey response rates to be low, the department should ensure responses are representative of patients or family members by working with hospices to increase low return rates. In addition, the data was reported by hospice licensee rather than by hospice program location, which does not enable the department or other stakeholders to assess differences among multiple hospice programs operated by a single company, among hospice programs within a single service area, or among hospice programs based their profit status. Further, the data needed to calculate how a hospice performed on a measure was sometimes incomplete. For example, in instances where the number of respondents answering yes or no to a question did not equal the total number of survey respondents, it was unclear whether respondents did not answer the question or whether data was missing. To address these issues and to ensure that data reported by hospices is complete and accurate, the department should develop edit checks in its automated data collection process and test the reliability of the data. In addition, to facilitate comparing hospice quality, it should require hospices to report data by hospice program location rather than by company or license and work with hospices to ensure that each program achieves a reasonable response rate. Agency Response In accordance with the provisions of s (5), Florida Statutes, a draft of our report was submitted to the Secretary of the Department of Elder Affairs to review and respond. The Secretary s written response has been reproduced in Appendix C. 6
7 Report No OPPAGA Report Appendix A Florida Hospice Programs Deliver Care in 27 Service Areas Covering All 67 Counties The map below shows Florida s 27 geographic service areas for allocation of hospice services. These service areas are established by local area health councils and may include one or more counties. As of December 2009, Florida had 64 hospice programs operating under 41 licensed entities. Ten of the service areas are served by a single hospice program, while the remaining 17 areas are served by multiple programs. Hospice programs may only provide services to residents within the geographic boundaries of their service area. See Table A-1 on the following page for a list of the counties and hospice programs in each service area. The names of hospice programs opened since 2006 are bolded. 1 2A 2B 4A 3A 3C 3D 5A 3B 5B 6A 6C 8D 3E 4B 7C 7B 6B 8A 8C 8B 7A 9A 9B 9C
8 OPPAGA Report Report No Table A-1 Sixty-Four Hospice Programs Serve 27 Geographic Service Areas in Florida Area County Hospice Program 1 Escambia, Okaloosa, Santa Rosa, Walton Covenant Hospice, Inc. Emerald Coast Hospice Regency Hospice of Northwest Florida, Inc. (Licensed June 5, 2009) 2A Bay, Calhoun, Gulf, Holmes, Jackson, Washington Covenant Hospice, Inc. Emerald Coast Hospice 2B Franklin, Gadsden, Jefferson, Leon, Liberty, Madison, Taylor, Wakulla Big Bend Hospice Covenant Hospice, Inc. 3A Alachua, Bradford, Columbia, Dixie, Gilchrist, Hamilton, Lafayette, Levy, Putnam, Suwannee, Union Haven Hospice Hospice of Citrus County, Inc. (Licensed June 1, 2007) 3B Marion Hospice of Marion County 3C Citrus Hospice of Citrus County, Inc. HPH Hospice, Inc. 2 3D Hernando HPH Hospice, Inc. 2 3E Lake, Sumter Cornerstone Hospice and Palliative Care 4A Baker, Clay, Duval, Nassau, St. Johns Community Hospice of Northeast Florida, Inc. Haven Hospice 1 Heartland Home Health Care and Hospice (Licensed September 6, 2007) 4B Flagler, Volusia Florida Hospital HospiceCare Haven Hospice (Licensed10/15/08) Hospice of Volusia - Flagler Odyssey Healthcare 3 5A Pasco Gulfside Regional Hospice, Inc. HPH Hospice, Inc. 2 5B Pinellas Suncoast Hospice 6A Hillsborough LifePath Hospice, Inc. 6B Hardee, Highlands, Polk Cornerstone Hospice and Palliative Care Good Shepherd Hospice, Inc. 4 Hope Hospice and Community Services, Inc. (Licensed June 10, 2006) 6C Manatee TideWell Hospice and Palliative Care, Inc. 7A Brevard Hospice of Health First, Inc. Hospice of St. Francis, Inc. Wuesthoff Brevard Hospice and Palliative Care 7B Orange, Osceola Cornerstone Hospice and Palliative Care Hospice of the Comforter, Inc. Samaritan Care Hospice 5 7C Seminole Hospice of the Comforter, Inc. 8A Charlotte, DeSoto Tidewell Hospice and Palliative Care, Inc. 8B Collier Avow Hospice, Inc. 6 (Licensed May 19, 2008) 8C Glades, Hendry, Lee HOPE Hospice and Community Services 8D Sarasota Tidewell Hospice and Palliative Care, Inc. 9A Indian River VNA Hospice of Indian River County, Inc. 9B Martin, Okeechobee, St. Lucie Hospice of Okeechobee, Inc. Hospice of the Treasure Coast, Inc. The Hospice of Martin and St. Lucie, Inc. 9C Palm Beach Hospice By The Sea, Inc. Hospice of Palm Beach County, Inc. 8
9 Report No OPPAGA Report Area County Hospice Program 10 Broward Catholic Hospice, Inc. (Licensed January 14,2008) HospiceCare of Southeast Florida, Inc. Hospice By The Sea, Inc. Hospice of Gold Coast Home Health Services 11 Dade, Monroe Catholic Hospice, Inc. Douglas Gardens Hospice, Inc. HospiceCare of Southeast Florida, Inc. Hospice Care of South Florida Hospice of the Florida Keys, Inc. Odyssey Healthcare (Licensed March 3, 2006) 1 Hospice of North Central Florida changed its name to Haven Hospice. 2 Hernando-Pasco Hospice, Inc., changed its name to HPH Hospice, Inc. 3 Hospice of the Palm Coast, Inc., changed its name to Odyssey Healthcare. 4 Good Shepherd Hospice of Mid-Florida sold to LIfePath and changed its name to Good Shepherd Hospice, Inc. 5 Hospice of Orange-Osceola changed its name to Samaritan Care Hospice. 6 Hospice of Naples, Inc., changed its name to Avow Hospice, Inc. Source: Florida Agency for Health Care Administration. 9
10 OPPAGA Report Report No Appendix B The Federal Centers for Medicare and Medicaid Services Requires Hospice Programs to Develop Quality Assurance and Performance Improvement Systems In 2008, the federal Centers for Medicare and Medicaid Services issued new Conditions of Participation requirements for hospices that receive Medicare payments. 21 Effective December 2008, these Quality Assurance and Performance Improvement regulations require hospices to develop an outcome-based internal performance improvement system that measures individual patient outcomes in order to continually improve the quality of care provided to patients and their families. In addition, hospices must develop indicators that assess adverse patient events, processes of care, hospice services, and operations. Hospices must use these indicators to identify areas where improvement is needed and measure their progress in these areas. Florida s hospices are currently in the process of complying with these requirements. To assist hospices in developing these indicators, the Centers for Medicare and Medicaid Services began testing the validity of 12 measures that assess various domains of hospice care in August Table B-1 The Centers for Medicare and Medicaid Services Are Testing 12 Measures for Assessing Hospice Quality of Care Quality Domain Measures Structure and process Structure and process Care for physical symptoms: pain Care for physical symptoms: dyspnea Care for physical symptoms: Other conditions Care for physical symptoms: other conditions Care for psychological symptoms Social aspects of care Cultural aspects of care Care of the imminently dying Ethical and legal aspects of care Adverse events Source: Center for Medicare and Medicaid Services. Percentage of patients admitted to hospice or palliative care who have a screening for symptoms during the admission visit Percentage of patients who had a comprehensive assessment completed within five days of admission For patients who screened positive for pain, the percentage whose pain was at a comfortable level within two days of screening For patients who screened positive for dyspnea (difficulty breathing), the percentage who improved within one day of screening For patients who screen positive for constipation, the percentage who receive treatment within one day of screening Percentage of patients on opioids who have a bowel regimen initiated within one day of opioid initiation For patients who screened positive for anxiety, the percentage who receive treatment within two weeks of diagnosis Percentage of families reporting the hospice attended to family needs for information about medication, treatment, and symptoms Provision of interpreter or translator for non-english-speaking or deaf patients Percentage of patients who had moderate to severe pain on a standard rating scale at any time in the last week of life Percentage of patients with chart documentation of an advanced directive or discussion that there is no advanced directive Selected number of occurrences per 100 patient days; four types of issues are tracked: falls, medication errors, durable medical equipment issues (compliant, malfunction or error), and patient / family complaints) CFR
11 Report No OPPAGA Report Appendix C 11
12 OPPAGA Report Report No The Florida Legislature Office of Program Policy Analysis and Government Accountability OPPAGA provides performance and accountability information about Florida government in several ways. Reports deliver program evaluation, policy analysis, and Sunset reviews of state programs to assist the Legislature in overseeing government operations, developing policy choices, and making Florida government better, faster, and cheaper. PolicyCasts, short narrated slide presentations, provide bottom-line briefings of findings and recommendations for select reports. Government Program Summaries (GPS), an online encyclopedia, provides descriptive, evaluative, and performance information on more than 200 Florida state government programs. The Florida Monitor Weekly, an electronic newsletter, delivers brief announcements of research reports, conferences, and other resources of interest for Florida's policy research and program evaluation community. Visit OPPAGA s website at OPPAGA supports the Florida Legislature by providing evaluative research and objective analyses to promote government accountability and the efficient and effective use of public resources. This project was conducted in accordance with applicable evaluation standards. Copies of this report in print or alternate accessible format may be obtained by telephone (850/ ), by FAX (850/ ), in person, or by mail (OPPAGA Report Production, Claude Pepper Building, Room 312, 111 W. Madison St., Tallahassee, FL ). Cover photo by Mark Foley. Project supervised by Yvonne Bigos (850/ ) Project conducted by Jennifer Johnson (850/ ) and Ellyon Bell-Turnquest (850/ ) Becky Vickers, Staff Director, Health and Human Services Gary R. VanLandingham, OPPAGA Director 12
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