The administration of examinations for 15-19 year olds in England: Responses from the Government and Ofqual to the First Report of the Committee, Session 2012-13 - Education Committee Contents


Appendix 1


Government response

Government's response to the administration of examinations for 15-19 year olds in England—Education Committee

Introduction

We would like to thank the Committee for their thoughtful contribution on the vital and necessary issue of qualification reform. It is reassuring to see that we agree about the need to strengthen the rigour and standards in our current Key Stage 4 qualifications and are all committed to the need for fundamental reform of our exam system.

English Baccalaureate Certificates

GCSEs were designed with the well intentioned aim of providing a universal qualification for students of all abilities. We are determined to maintain that principle of universality. In the years since GCSEs were introduced there have been improvements in our education system as a result of the hard work of teachers and students, but there has been growing concern that the increase in the numbers of higher grade GCSEs awarded has not been matched by higher levels of attainment. There is evidence that the standards of our examinations have fallen over time, and that the expectations they set for our students are now below those of our international competitors.

The Royal Society of Chemistry and the University of Durham have both found that students are being awarded higher grades than their counterparts of similar ability in the past. Evidence from Ofqual has shown that GCSE demand in mathematics and science has lessened and employers tell us they remain dissatisfied with school leavers' literacy and numeracy. Universities and colleges tell us that they need to provide remedial classes for apparently well qualified new students. As a result public confidence in GCSEs is damaged.

The root cause of these failures is the interaction of the current school accountability and examination system at Key Stage 4. Schools can seek to raise their apparent performance by choosing the courses and examinations that offer the highest grades. This in turn creates an incentive on the competing Awarding Organisations to defend, or build, their market share by providing less demanding qualifications. Recent concerns about the effect on standards of modularisation and controlled assessment reinforce the need for reform.

We must replace the current perverse incentives for Awarding Organisations and schools to develop and seek out less demanding qualifications, with a system where Awarding Organisations compete to show that their qualifications are the most ambitious. As announced in the House of Commons on 17 September, we intend to hold a competition to identify the single, best qualification, offered by a single Awarding Organisation, to be adopted in each of the core academic subjects that make up the English Baccalaureate—English, mathematics, sciences, history, geography and languages, for a period of five years. The new qualifications will be called "English Baccalaureate Certificates" (EBCs).

We have considered the risks of moving to a single Awarding Organisation, as highlighted in the Committee's report, and will ensure that we put in place measures to manage those risks. It is worth noting that many other countries rely on single Awarding Organisations. Internationally, it is the UK's competing Awarding Organisation model that is unusual.

Our proposals for EBCs are set out in the consultation document 'Reforming Key Stage 4 Qualifications' launched on 17 September 2012. The consultation seeks views on what makes a qualification world class, and how we can use these qualifications to support all young people to have high aspirations and the best possible opportunities to progress to further and higher education and into employment. It runs until 10 December.

As set out in that consultation, we anticipate that EBCs should include:

·  Rigorous demands for assessment and challenging requirements for content to ensure students will be studying a world class syllabus.

·  A qualification design that means that the vast majority of students can be entered, as is the case with current GCSEs.

·  High expectations of the performance students need to demonstrate- so that the qualifications are more rigorous and better prepare students for further study (and later for employment).

We must, of course, have robust arrangements in place for the small group of students who will find it difficult to sit EBCs, in the same way that some students do not currently sit GCSE at age 16. We are proposing that all students who are not entered for the qualification should be provided with a "Statement of Achievement" by their school, which sets out their strengths and weaknesses in each subject and which will help their future school or college understand what additional teaching and support they will need to be able to enter and achieve an EBC post-16.

We will refocus the Government's floor standard measures that identify underperforming secondary schools, and the minimum standards for post-16 institutions, to take account of performance in our new English, mathematics and science qualifications from 2017. Later this year we will launch a full consultation on how to improve the accountability system for secondary schools in England, building on these changes.

We expect that the best qualifications in English, mathematics and sciences will be identified in 2013 so that schools will have more than 18 months to prepare for the first teaching of the new qualifications in September 2015. The timetable for the implementation of history, geography and languages EBCs will be determined by the response to the consultation. We will work with Ofqual and Awarding Organisations to ensure that schools are provided with appropriate guidance and support as they prepare to deliver these reformed, more rigorous qualifications.

We recognise that our intentions go further than the Committee's recommendations suggest, but believe these steps are absolutely necessary to restore confidence in our exams by tackling the problems created by our current GCSEs.

A levels

We set out our commitment in the White Paper 'The Importance of Teaching' to engage universities and learned societies more fully in A level design and development. Our aim is to ensure that those with the strongest interest in maintaining standards in A levels have the greatest say over their future direction. In line with this, we have proposed that we should step back from A level development, leaving universities and Awarding Organisations to work together on content of the new qualifications.

Ofqual published its consultation on A level reform on 19 June. It sought views on proposals to change their regulatory approach in order to strengthen university involvement in A level development and subject content, setting out a small number of core 'design rules' to underpin new A levels. The consultation ended on 11 September.

To secure accreditation for A levels, Awarding Organisations will be expected to show evidence of the engagement by universities in the development of the qualification, with an emphasis on our best universities such as those represented by the Russell Group. We have also asked Ofqual to lead annual post-examination meetings of Awarding Organisations and universities to ensure that lessons are learnt to inform future qualification development.

In a letter to the chief regulator in May 2012, the Secretary of State stated that the timetable for reform should be ambitious. We recognise that this will require our leading universities to make a strong commitment to the A level system: it is in their interest to do so and we are confident that they will.

Conclusions and Recommendations

In the response below, the Committee's specific conclusions and recommendations are in bold text and the Government's responses are in plain text.

There a number of recommendations that relate to Ofqual and the way it carries out its role of independent regulator for qualifications. In line with the separation of responsibility between DfE and Ofqual, and as Ofqual are fully independent, Ofqual has responded separately to those recommendations.

Fundamental reform of the exam system

1.  Overall, we conclude that the costs, heightened risk and disruption likely to be generated by moving to a single board outweigh the potential benefits. Furthermore, evidence suggests that some key issues identified with the current system, such as comparability of standards over time and across subjects and the role of examiners in training and textbooks, would remain. New problems, such as a lack of incentive to innovate, the risk of higher fees and a reduced quality of service to schools, may be generated. There may also be the potential for increased political interference, as well as the issue of whether to limit schools' choice of exams to those offered by the single board. (Paragraph 55)

2.  If the system of multiple exam boards is retained, substantial improvements are needed in order to increase confidence in the system and maintain its credibility. We have serious concerns about the incentives in the current system for exam boards to compete on standards, in particular on content standards. We think that significant changes are needed to alter these incentives. (Paragraph 60)

We agree with the Committee that significant changes are needed in order to restore the rigour of qualifications taken at the end of Key Stage 4 and to overcome the perverse incentives that our examination and accountability systems currently create.

As we have outlined, we believe that we need to move away from the existing Awarding Organisation competition that leads to downward pressure on standards. We have announced our intention to hold a competition to identify the single, best qualification offered by a single Awarding Organisation which could be adopted in each of the core academic subjects that make up the English Baccalaureate. The consultation on our proposals, 'Reforming Key Stage 4 Qualifications', opened on 17 September 2012 and we would be grateful for views.

We recognise that we need to think about how to encourage innovation and quality, as well as high standards of service and value for money for schools. We do not believe that qualifications are best designed by Government. Awarding Organisations, drawing on the expertise of universities and learned societies, and schools and colleges, need to have the freedom to develop qualifications based on what is working well in the highest performing jurisdictions around the world. This Government does not intend to repeat previous attempts to underpin the quality of our qualifications by setting ever more restrictive central requirements. Further detail on the process by which we intend to select new qualifications is set out in the consultation document. During the consultation, we are undertaking detailed discussions with Awarding Organisations, school leaders and others, which will assist us in ensuring that the requirements we set out for the new EBCs will promote positive innovation, and secure value for money.

It will be essential to the success of the new arrangements that Ofqual, as the independent regulator, continues to secure standards, confidence and efficiency. Ofqual will be considering the arrangements that it will need to put in place to regulate the new qualifications effectively, and will be consulting as necessary.

The way forward

Syllabus content

3.  We believe that the current system incentivises downward competition on content standards and we recommend that the Government act immediately to change these incentives. We consider that national syllabuses would offer a way of addressing downward competition on content and provide reassurance on standards, without the risks, lost benefits and disruption involved in moving to a single board. The Government should begin by piloting a national syllabus in one large entry subject as part of the forthcoming A level reforms. Ofqual should review the effectiveness of the pilot, with a view to extending the approach across GCSE and A levels if appropriate. We believe that national syllabuses, coupled with a stronger Ofqual and greater involvement of subject communities in GCSEs and A levels, should help to maximise the benefits of having multiple competing exam boards while minimising the shortcomings. (Paragraph 81)

4.  While we can see that the second option we outline—franchising of subjects to exam boards—offers a way to address downward competition on content, we have concerns about the long-term impact and suggest that there may be serious downsides to such a change that need to be better understood before it can be recommended. (Paragraph 82)

We strongly agree with the Committee on their findings that the current system incentivises downward competition but we find it difficult to see how a national syllabus would sufficiently and fully address the problem.

The Committee's proposal could ensure tighter control of the content of the 'national syllabus' than currently exists for GCSE subject criteria. However, it would be likely that differences in the design of assessments between Awarding Organisations, and consequently the perceived and actual demand of different exams, would remain. By ending the competition between Awarding Organisations to sell their qualifications in the English Baccalaureate subjects we will remove the temptation to offer less demanding qualifications in order to try and protect their market share.

Grading standards and grade inflation

5.  Ofqual should continue to investigate grading issues as part of its programme of standards reviews and to engage publicly with debate on exam standards. Ofqual needs to be able to account for what AQA's Andrew Hall described as the "creep in grading standards", particularly in the commercially significant large entry subjects at GCSE, which are key to schools' performance in league tables and also in large entry A level subjects, commonly used for university entrance. (Paragraph 91)

6.  We welcome Ofqual's recent action to regulate grading standards and recommend that it continue with this approach for A level and, from summer 2012, for GCSE. The effect of this action is twofold: first it helps to control grade inflation and second it provides reassurance that the exam boards are not competing on grading standards. We recognise that the effect will take time to filter through the system and to help increase public confidence. (Paragraph 95)

Recommendations 5 and 6 are a matter for Ofqual.

The role of Ofqual

Ofqual's regulation of standards

7.  We recommend that Ofqual seek to build its assessment expertise and finds the resources to do so. We further recommend that Ofqual appoint an assessment expert to its board as soon as possible. (Paragraph 102)

This recommendation is primarily a matter for Ofqual. However, appointments to the Ofqual Board are made by the Secretary of State on the advice of the Ofqual Chair. We would listen carefully to a recommendation from Ofqual that the expertise of the Board should be strengthened in the way the Committee proposes, when further vacancies arise.

Ofqual's international standards objective and Government policy changes

8.  We are concerned that the amendment to Ofqual's qualification standards objective could over a period of time pull it simultaneously in different directions and recommend that the Government give a clear indication to Ofqual about which should be the priority: the comparability of standards over time in England or benchmarking against the standards of qualifications in other countries. (Paragraph 104)

9.  We recommend that the Government make its priorities clear to Ofqual, whether these are the maintenance of standards over time or making exams tougher, and that both the Government and Ofqual be open about the consequences of these policies for young people. (Paragraph 105)

In March 2012, we wrote to Ofqual to set out the purposes of the international standards objective. Our ambition is to have a qualifications system in England that stands up to the best in the world, an ambition driven by the need to secure our future competitiveness and equip young people for the global stage.  This requires a step change from the current GCSEs to ensure that we have qualifications that offer sufficient rigour and challenge to students. We intend the move to English Baccalaureate Certificates to secure that step change. Longer term, ensuring that the quality of the new qualifications is maintained over time will remain important to avoid any resumption of the downward drift in standards that we have seen with GCSEs.

We recognise that there can be, at times, a tension between keeping pace internationally and maintaining standards year on year. That is not a tension created by Ofqual's new objectives. It reflects the fact that changes in the standards expected overseas may demand comparable changes in England if we are to remain competitive. Now that Ofqual has a new objective relating to international comparability it is able to strike a proper balance between these two imperatives, in the light of the priorities we have set out.

10.  If A levels are going to become more varied in structure, Ofqual needs to ensure that its collection of evidence and monitoring of standards are sufficiently robust to provide convincing reassurance that content standards are being maintained. (Paragraph 106)

This recommendation is a matter for Ofqual.

GCSE changes and devolution

11.  We recommend that Ofqual review its arrangements for ensuring comparability of standards between England, Wales and Northern Ireland, and that it continue to monitor standards in GCSE and A level examinations offered by WJEC and CCEA, as well as the English providers as part of its ongoing regulation of standards. We also believe that a debate is needed on the importance of standards comparability between the home nations, with a Ministerial conference to decide whether and what action is necessary. (Paragraph 107)

We note that Ministers in Wales have been consulting on 14-19 qualifications, which may lead to changes to qualifications taken at 16 and at 18 in Wales. Northern Irish Ministers are also considering what changes may be necessary to qualifications taken in Northern Ireland. The changes we are proposing will have effect only in England, although we acknowledge the importance of those qualifications for students in Wales and Northern Ireland, particularly in relation to university entry. Representatives from England, Wales and Northern Ireland meet regularly to discuss qualifications reform.   

Accreditation

12. We recommend that individual accreditation of all new syllabuses, including our recommended national syllabuses, remain a part of Ofqual's continuing regulation of GCSEs and A-levels and, indeed, of any qualifications that are deemed equivalent to GCSEs and A-levels. With this in mind, Ofqual needs to demonstrate that its accreditation procedures are rigorous and transparent, and that it draws on appropriate respected subject and assessment expertise when reviewing draft syllabuses and their associated materials. We recommend that Ofqual review and strengthen its regulation of content standards, including accreditation procedures, seeking and acting upon advice from its standards advisory group as appropriate. (Paragraph 110)

Ofqual and subject expertise

13. While we accept Ofqual's rationale for its lack of in-house subject expertise, criticisms from the subject communities lead us to conclude that Ofqual needs to be more transparent about its consultation with and use of external subject experts. (Paragraph 112)

National subject committees

14. We recommend that Ofqual convene national subject committees in large entry GCSE and A level subjects, drawing their membership from learned societies, subject associations, higher education and employers. Such committees should include in their remit syllabus development and accreditation, as well as on-going monitoring of question papers and mark schemes, and oversight of comparable qualifications offered in the devolved nations. (Paragraph 115)

Ofqual and the Joint Council for Qualifications

15. Ofqual should instigate discussions with the JCQ to clarify roles and responsibilities in areas where there is a joint interest and publish information about this to schools and colleges as appropriate. (Paragraph 117)

Conclusion

16. It is clear from the issues raised with us that further improvements are needed if Ofqual is to be a stronger, more challenging and more effective regulator. As AQA's Andrew Hall put it "Ofqual is, in fairness, on a journey". We believe that there is a strong argument in favour of allowing time for a strengthened Ofqual to take effect, as the changes it is making will take time to settle and bear fruit. But Ofqual must demonstrate that it is collecting the right sort of qualitative and quantitative evidence and using robust methodology to regulate effectively. Details of the evidence used by Ofqual in the regulation of standards, and any specific findings and regulatory action on standards, should be set out clearly in annexes to Ofqual's annual report to Parliament. Ofqual must continue to show that it is prepared to take vigorous action when needed, in order to help increase public confidence in the exam system.(Paragraph 119)

Recommendations 12-16 are a matter for Ofqual.

Forthcoming A level reform

17.  We recommend that the Government and Ofqual seek to increase the involvement of learned bodies as well as universities in the content of A levels, while allowing exam boards to retain control of question papers and examination design to ensure best assessment practice. The Government and Ofqual must also ensure that the whole of the university sector is consulted on the proposed A level reforms, as well as schools, colleges, learned bodies and employers. (Paragraph 128)

It is in the interests of students that A levels command the confidence of our universities and so the Government is committed to increasing the role of our top research intensive universities in the development of these qualifications. Ofqual has consulted on new conditions for A levels which will allow universities and learned bodies to take a leading role in the design and development of A levels in the future. Awarding Organisations will continue to retain control of question papers and will need to ensure that the assessment in place for the new A levels is fit for purpose. Ofqual's consultation, which concluded on 11 September, sought the views of all universities, schools, colleges and employers on the structure and design of future A levels.

18.  We recommend that Ofqual involve national subject committees in the development of criteria for and accreditation of new A levels. (Paragraph 130)

We have no plans to ask Ofqual to convene national subject committees for large entry GCSE or A level subjects. For A levels, we think that matters relating to subject content should be for universities, working with learned bodies where appropriate, to advise Awarding Organisations. The details of that engagement are, we think, rightly for universities and learned bodies to agree with Awarding Organisations, rather than for Government or the regulator to determine.

Market share and price

Changes in market share

19.  We are pleased that Ofqual has recognised the need for closer monitoring of changes in market share between exam boards and recommend that it prioritise this work, in order to establish the reasons for changes at individual qualification level and whether there is any link to standards. (Paragraph 135).

This recommendation is a matter for Ofqual.

Examination fees

20.  The area of pricing is complex and Ofqual studies so far in this area have been limited. This hinders Ofqual from making a robust public critique of the high costs to schools. We agree with the Government that reassurance is needed that fees are set at an appropriate level. Ofqual also needs to demonstrate that overall the charges made to the public purse by the exam system are fair and appropriate. We also stress that any changes to the system, in particular a move to franchising, will need close attention to pricing by Ofqual. (Paragraph 141)

Exam fees are a significant call on school and college budgets. We must therefore reassure ourselves that fees are at an appropriate level and schools and colleges are able to purchase qualifications efficiently. Ofqual's healthy markets initiative offers the prospect for reducing the costs to the public purse of qualifications.

Ofqual has responded on the detail of the recommendation.

Support: training and textbooks

Training

21.   We welcome Ofqual's decision to end exam boards training on specific qualifications. Ofqual needs to monitor the impact of its decision and the activities and materials produced by exam boards to replace their seminars. We also recommend that Ofqual monitor other training offered by Awarding Organisations, such as marketing events to promote new syllabuses, and more general training, for example on improving results, taking further action if needed. Ofqual must ensure that a school's loyalty to a particular exam boards cannot be rewarded with access to information not available to others. (Paragraph 149)

We have serious concerns about aspects of how Awarding Organisations have been providing training to teachers, including through seminars. Too much information about future examinations has been shared at some of these events. Ofqual has conducted a review of these arrangements and has set out its intention to strengthen the relevant controls and to look in more depth at wider aspects of training provided by Awarding Organisations.

Ofqual has responded on the detail of the recommendation.

Textbooks

22.  We are concerned that there is a potential conflict of interest for examiners involved in question paper setting also writing textbooks that are linked closely to the same syllabus. We welcome indications that exam boards may place tighter restrictions on the role of examiners in textbook authorship. We recommend that Ofqual make clear the expected future role of examiners in textbook authorship, in order to ensure a consistent industry-wide approach. (Paragraph 154)

23.  We recommend that Ofqual consider restricting exclusive endorsement arrangements between exam boards and publishers in future. (Paragraph 156)

24.  Ofqual needs to be satisfied that Pearson has sufficient firewalls in place to ensure that its publishing and examining activities are separate, including syllabus development, and to say so publicly. (Paragraph 157)

25.  We have serious misgivings about the language used to market some endorsed textbooks and would urge exam boards and publishers to move away from marketing textbooks in this way. (Paragraph 158)

Recommendations 22-25 are a matter for Ofqual.

26.  We welcome Pearson's statement that it is moving away from a shared design between Edexcel syllabus materials and Pearson textbooks, as we agree that this can unhelpfully overstate the link between the two. Pearson should give even-handed treatment to Edexcel Own and endorsed resources from other publishers on the Edexcel website. (Paragraph 159)

We agree with the Committee on this recommendation.

27.  In order to strengthen the links between textbooks and the curriculum, as well as assessment, we recommend that in future A level textbooks be endorsed by the universities involved in developing a particular syllabus rather than by the exam boards. At GCSE much will depend on the outcomes of the National Curriculum review and the ensuing reforms to GCSE, but a possible way forward might involve learned bodies endorsing textbooks instead of exam boards. (Paragraph 167)

Like the Committee, we have concerns about the links between Awarding Organisations and the publication of textbooks. There are, for example, conflicts of interest inherent in the current arrangements and textbooks can encourage teaching to the test. These are complex issues which have both a regulatory and policy dimension.  We look forward to the outcome of Ofqual's review of these issues.

Ofqual's regulation of exam board support

28.   We agree with Ofqual that the market has not been regulated tightly enough with regard to training and textbooks and we believe that this has allowed conflicts of interest to arise. Ofqual's healthy markets work is welcome, if overdue, as it is clear that many of the issues raised with us have gone unchecked for some time. We welcome Ofqual's recent report on exam board seminars and look forward to its publication of an action plan relating to textbooks and study aids in September 2012. Proper regulatory control and scrutiny of these issues will help to increase public confidence in the exam system.(Paragraph 169)

29. We recommend that Ofqual, as part of its healthy markets work, take a clear view on the broader question about how much exam boards should be involved in helping to improve results as well as in the impartial assessment of attainment. (Paragraph 170)

Recommendations 28 and 29 are a matter for Ofqual.

Service: question papers and marking

Question paper errors in summer 2011

30.  We welcome the findings of Ofqual's investigation into the errors in summer 2011. It is vital that Ofqual acts swiftly and robustly (including, where appropriate, using its power to fine) in the event of errors in order to protect the integrity of the system and the interests of young people. (Paragraph 172)

31.  Ofqual must investigate allegations of improper conduct by exam boards thoroughly, taking vigorous action if necessary, to ensure that candidates are awarded the grades they deserve and to protect the integrity of the exam system. (Paragraph 177)

Ofqual conducted an investigation into the unacceptable errors in live papers last summer and has taken action to require Awarding Organisations to tighten up their systems and controls.

Ofqual must continue to regulate standards and delivery rigorously to rebuild confidence in the qualifications system. To equip Ofqual to do so, we have legislated to give it extra powers to sanction Awarding Organisations, including a power to fine. We would expect Ofqual to use these powers whenever an Awarding Organisation has fallen significantly short of the standards that the public would expect.

Ofqual has responded on the detail of the recommendation.

Reliability of marking

32.  We welcome Ofqual's work to agree a common approach across exam boards to deal with concerns about marking and to ensure students are treated fairly across the system. (Paragraph 178)

Online standardisation

33. We accept that there is some research evidence to show that online standardisation is as effective as (but, if our reading of the research is correct, not necessarily more effective than) face-to-face standardisation. We can also see that it brings other benefits, such as reduced costs, an accelerated marking process and real-time monitoring of marking. We believe, however, that exam boards should continue to monitor the effectiveness of online standardisation and should consider offering opportunities for face-to-face discussion between examiners. (Paragraph 181)

Recommendations 32 and 33 are a matter for Ofqual.

Exams and school accountability

The burden of assessment

34. We have seen no evidence to suggest that having competing exam boards has contributed to the burden of assessment. The number of exams taken by young people is linked to Government policy and to decisions made by schools responding to pressures from the accountability system. (Paragraph 185)

Together with Ofqual, the Government has already begun to make changes by ensuring that external assessment across the subject is taken at the end of the course rather than in modules, as well as tackling resits in GCSEs and A Levels. Steps are also being taken to address concerns on controlled assessment in GCSEs and improve the clarity of guidance. 

In addition to this, as a result of the conclusions of the Wolf Review, performance tables now focus on the qualifications which benefit students' prospects. All of these measures should reduce the exam burden on students and will also free up time for a more balanced curriculum.

More generally, we agree with the Committee that schools, and students, must not be faced by perverse incentives to take excessive numbers of examinations, or routinely to retake examinations. Our review of the school accountability system will provide an opportunity to ensure that any such incentives can be removed.

Early and multiple entries to GCSE examinations

35.  We recommend that the Government ask Ofqual to gather data from the exam boards to enable it to identify the extent of multiple entry and then offer advice on whether, and what, action is needed to limit the practice (Paragraph 188)

We agree that further data on multiple entry would be helpful. The Department holds such information and is currently undertaking an analysis of the data.  We will make the results of that work available to the Committee.

Wider changes

36. The Government should not underestimate the extent to which the accountability system incentivises schools to act in certain ways with regard to exams. Sometimes these may be in students' interests; sometimes, however, they are not. We recommend that the Government look afresh at current accountability measures, with a view to reducing the dominant influence of the measure of 5 GCSE A*-C or equivalent including English and mathematics and to increasing the credit given to schools for the progress made by all children across the ability range. (Paragraph 192)

Strong accountability, including the publication of key performance measures and wider data, is vitally important.  We agree that the current system should be looked at again to make sure that it encourages schools to focus on all students across the ability range. We are planning to launch a wider ranging consultation on secondary school accountability later this year.


 
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