Programs (PGM)

As of April 1, 2024

The pending summarized recommendations listed below reflect the most current information and actions taken since the previous Board Study Session.  Summarized recommendations marked as audited or pending review have been updated for the May 7, 2024 Board Study Session.​​​

There are 27 recommendations in the category of Programs that are included in the Summarized Recommendations below.

    Steps Taken: The Sheriff’s Office has assigned Multi Support deputies and Custody Health Services has provided multi-disciplinary healthcare staff for a team approach to provide more programming for inmates with mental-health needs. The Sheriff’s Office provides journaling and support groups currently. Custody Health provides discharge planning for inmates who require more complex case management. Both departments work with the Re-entry Resource Center for discharge planning of mental health inmates.

    Custody Health Services (CHS) currently has 10 Behavioral Health Teams working at the Main Jail and Elmwood Complex—including the Correctional Center for Women.  They continue to provide crisis intervention, psychiatric assessment, medication management, case management, discharge planning and individual/group therapy.

    With the ongoing construction and subsequent housing changes at the Main Jail and Elmwood Complex, CHS continues to collaborate with the Sheriff’s Office to optimize supervision and use of existing space for groups.  There are approximately 40 group treatment sessions conducted weekly by CHS clinicians and STEP (Supportive Transitional Empowerment Program) counselors. The increase is due to a concerted effort to provide additional group treatment in various housing units at the Main Jail and Elmwood facilities.

    In addition, CHS staff attend the weekly Community Awaiting Placement Supervision (CAPS) meeting with a multi-departmental team that plans for and arranges program releases for inmates who have been ordered to participate in programs that address their treatment and/or recovery needs.  CHS also continues to meet with the Behavioral Health Services Leadership to improve patient transition into the community.

    The CHS component of this Summarized Recommendation has been completed.  However, CHS will continue to monitor services to adapt to the evolving needs of inmates.

    The Sheriff’s Office has been utilizing staff on an “on-loan” basis and has increased the number of Multi Support-Deputies to 22 deputies, with 10 Behavioral Health Teams.  Additionally, 5 additional Rehabilitation Officers are completing the hiring process and will begin in August 2017.

    The Sheriff's Office Programs Unit and Custody Behavioral Health have worked together to provide structured programming to Special Management Units at both facilities.

    The Sheriff’s Office component of this recommendation has been completed to the extent possible with current staffing.  In addition to the other positions added for this function, the Sheriff’s Office has four deputies on loan as Multi Support deputies to assist with the medical and mental health needs, and additional staffing needs will be reviewed as part of the staffing study.

    The Sheriff’s Office indicates they remain committed to supporting the mental health needs of inmates in the jails. The County’s current budget crisis has impacted the level of staffing within the Sheriff’s Office. All Multi-Support Deputies codes were deleted, and the number of Rehabilitation Officers in the Programs Unit was reduced to 14. A high level preliminary staffing report will be presented to PSJC in April 2021.

    On March 8, 2022, the Board approved adding 43.0 FTE Correctional Deputy positions in the Sheriff’s Office. These positions will be filled incrementally as staffing and hiring permit.

    Custody Health Services has initiated a Discharge Unit Clerk program with trained Medical Unit Clerks that are co-located with the Release Deputies and work in tandem as patients are released to assure that patients leave with their discharge plan and 30-day medication prescriptions necessary for the patient’s continuity of care with community healthcare and behavioral health services.

    Custody Health Services is currently reviewing the potential for hiring in-reach mental health peer support personnel with lived-experience to assist with patient support, to increase patient participation in their healthcare services, and to assist patients upon release.

    For the FY 2023 Adopted Budget, the Board approved 4.0 FTE Medical Assistant positions for telepsychiatry services.  The proposed Telepsychiatry Program for ambulatory psychiatric services will provide greater access and treatment of patients by psychiatrics and patient treatment teams leading towards improved patient outcomes and potentially smoother transitions to continued care in the community.  Additionally, the Board approved 1.0 FTE Medical Social Worker II to work with an approved 1.0 FTE Attorney under County Counsel for a Jail Population Team that will work with justice system partners to expedite treatment placements from jail and reduce wait times in jail. The Board also approved the purchase of High Security Group Therapy Chairs that will enable targeted group psychotherapy treatment time in dedicated spaces while ensuring safety standards. Lastly, the Board approved 6.0 FTE Recreation Therapist II positions to establish a Recreational Therapy Services team for the provision of evidence-based therapeutic recreational activities for patients.

    The Discharge Clerk program continues to advance at both Main Jail and Elmwood with Medical Unit Clerks covering various 24-hour shifts Monday through Friday with resource packets and After Visit Summary packets being prepared for weekend releases. The Discharge Clerk will also be instrumental as CHS begins to operationalize the CalAIM 1115 Demonstration Waiver as part of the Whole Person Care and Continuity of Care to support reintegration and improve access to care upon release.

    The Medical Assistant, Medial Social Worker II, and Recreation Therapist positions are in various stages of posting and hiring with expected placements by early summer.

    CHS has conducted market research on various High Security Therapy Chairs with a prospective vendor in mind and have installed 3 High Security Chairs to date. CHS and Sheriff’s Office Custody Bureau are currently considering logistical and operational needs for placement and integration of additional chairs.

    Custody Health Services is currently designing two patient surveys to be administered on the patient tablets:  Patient Satisfaction / Experiential Survey and a Patient Refusal Survey to garner opportunities to improve patient care and outcomes. CHS is working with the Office of Learning and Organization Development and Custody Bureau on this endeavor – projected for late Spring 2023.

    Custody Health secured two Peer Support Worker codes in FY 2024 with the objective of enhancing patient care and support within the facility. Peer Support Workers play a crucial role in fostering a supportive and understanding environment, as they have personal experience with mental health challenges and the criminal justice system. Their unique perspective allows them to connect with patients on a deeper level and provide empathetic, non-judgmental support. 

     

    Budget Status: The Board approved the following:

    • December 2015: 59 positions in Custody Health Services to provide multi-disciplinary healthcare staff and support staff ($16.6 million) for mentally ill inmates for behavioral health services during incarceration and re-integration into the community.
    • FY 2017 Adopted Budget: 10 Sheriff’s Correctional Deputy positions and 1 Sheriff’s Correctional Sergeant position ($1.6 million) were added as Multi Support Deputies to support the teams noted above.
    • FY 2017 Adopted Budget: 6 Rehabilitation Officer positions and 1 Senior Management Analyst ($1.1 million) for programming and discharge planning.
    • FY 2018 Adopted Budget: Added new Psychiatrist position to provide on-site clinical oversight of behavioral health services, and Hospital Services Assistant position, 2 Clinical Nurse III positions, and one Staff Developer position to support jail reform efforts ($1.4 million).
    • January 23, 2018: Added new Director, Custody Behavioral Services Positions, in Custody Health Services to provide oversight of all Custody Health behavioral health staff and services.
    • FY 2019 Adopted Budget: Added 8 Sheriff Correctional Deputy positions to be assigned as part of the Behavioral Health Team in the Multi Support Unit and 1 Sheriff Correctional Sergeant position to be assigned to oversee facility-wide out-of-cell time and restrictive housing for Main Jail administration. ($1,454,527).
    • FY 2019 Adopted Budget: Added 2 Sr. Psychologist positions ($494,908), 4 Clinical Nurse III positions ($791,976), 1 Administrative Assistant position and 1 Administrative Nurse II position ($351,137) to assist with providing comprehensive ambulatory medical, mental health and pharmacy services to inmates at the Main Jail and Elmwood facilities.
    • FY 2019 Adopted Budget: Approved $317,622 in funding for 3 Custody Health positions to maintain services for inmates diagnosed with a serious mental illness in need of intensive post-custody services. These positions were previously funded through the Mentally Ill Offenders Crime Reduction grant.
    • FY 2019 Adopted Budget: Approved an adjustment to the funding for the Custody Behavioral Health Teams by increasing Salaries and Benefits budget by $2.6 million.
    • February 12, 2019:  Funded 2.6 Clinical Nurse III positions in the Main Jail (1.3 FTE) and Elmwood (1.3 FTE) Medical Services unit for the Custody Health Services Department to meet the increased demands for care, backfill for nursing staff attending trainings or taking time off, meet other needs ($595,788).
    • FY 2020 Adopted Budget: The Board approved the addition of three Assistant Nurse Manager positions to ensure coverage on every shift at the Main Jail facility on the acute psychiatric unit 8A ($662,704) and one Quality Improvement Coordinator position that will provide training on mental health focused topics ($155,605).
    • FY 2020 Adopted Budget: The Board approved funding 3.5 Medical Unit Clerk positions to support the Intake Booking area to ensure proper and timely processing and scheduling of dental, medical, and behavioral health appointments ($341,680). 
    • August 27, 2019: Adopted a salary ordinance adding one Chief Psychologist position in Custody Health Services to lead the Psychology Team in the planning, implementation, and evaluation of treatment modalities offered to patients within the county jails and support the implementation of needed jail reform efforts ($258,641).
    • FY 2021 Adopted Budget: Add 1.0 FTE Medical Unit Clerk position to support the Custody Health Services Department’s discharge process, review release prescription orders, and issue vouchers for transportation resources ($109,925).
    • FY 2021 Adopted Budget: Funding for the Space Feasibility Study of the Main Jail North booking area, along with exam rooms adjacent to booking to allow for a more efficient booking process ($225,000).
    • FY 2021 Adopted Budget: Delete 4.5 FTE Psychiatrist positions, which are difficult to fill and have been vacant for several years ($1,453,693).
    • FY 2021 Adopted Budget: Delete 4.0 FTE Psychologist positions to reduce reliance on psychologist positions ($846,826). Custody Health Services will modify the treatment programs and coverage to provide enhanced care for inmates.
    • FY 2021 Adopted Budget: Delete 1.0 FTE Rehabilitation Officer II position in the Inmate Screening Unit to screen inmates for in- and out-of-custody programs ($181,738).
    • FY 2021 Adopted Budget: Delete 1.0 FTE Law Enforcement Clerk position in the Administration Booking Unit ($104,150).
    • FY 2021 Adopted Budget: Reduce ongoing contract services funding supporting psychiatrist services by $1,209,844. This action will limit the contractor’s ability to provide critical services in Intake Booking and the Acute Inpatient Psychiatric Unit.
    • FY 2021 Adopted Budget: Transfer 1.0 FTE Chief Psychologist position from the Santa Clara Valley medical Center to the Custody Health Services Department.
    • FY 2021 Adopted Budget: Delete 1.5 FTE Clinical Nurse positions ($386,265)
    • FY 2021 Adopted Budget: Delete 3.0 FTE Rehabilitation Officer positions ($545,214).
    • February 9, 2021: Delete 0.5 FTE Psychologist position ($90,909) and 0.5 FTE Staff Developer ($116,608) within Custody Health Services relating to the Voluntary Separation Incentive Program.
    • February 9, 2021: Delete 1.0 FTE Rehabilitation Officer II position related to the Voluntary Separation Incentive Program as part of the Fiscal Year 2020-2021 Mid-Year Budget Review ($206,474).
    • •March 23, 2021: Add 1.0 FTE Health Care Service Line Director position, 1.0 FTE Medical Social Worker position, Add 2.0 FTE Psychiatric Technician positions, 4.0 FTE Medical Assistant positions for Main Jail, 9.0 FTE Medical Assistant positions for Elmwood, 6.0 FTE Medical Unit Clerk positions, 1.0 FTE Management Analyst position, 4.0 FTE Janitor positions, 1.0 FTE Infection Control Nurse position, 1.0 FTE Health Care Program Analyst II position, 1.0 FTE Sr. Mental Health Program Specialist position, and 2.0 FTE Business Intelligence Analyst positions to meet the Consent Decree’s mandate to provide adequate integrated medical care to incarcerated patients as measured through access to care and population health quality indicators and evidenced-based clinical practices that mitigate risk and reduce patient harm, morbidity, and mortality.

    • FY 2022 Adopted Budget: Add 1.0 FTE Chief of Quality Management position, 1.0 FTE Chief of Mental Health Position, 2.0 FE licensed Vocational Nurse positions, 2.0 FTE Administrative Assistant positions, 4.0 FTE Medical Unit Clerk positions, 2.0 FTE Management Analyst positions, and 1.0 FTE Community Worker positions as part of the phase two of Custody Health Services’ restructure to meet the requirements of the federal consent decrees ($1,945,598)

    • March 8, 2022: Add 43.0 FTE Correctional Deputy positions related to the Chavez and Cole Consent Decree Remedial Plans to work directly with the Custody Health Services Behavioral Health Teams to provide acute or seriously mentally ill, intellectually disabled, and cognitive disability inmates with assisted daily living services, escorts, access to care, and constant and direct supervision of mental health structured programming and out-of-cell time ($750,224).
    • FY 23 Adopted Budget: Add 4.0 FTE Medical Assistant positions for telepsychiatry services ($306,318); Add 1.0 FTE Medical Social Worker II position for Jail Population Team ($126,790); Acquire High Security Group Therapy Chairs ($32,000); Add 6.0 FTE Recreation Therapist II positions to establish a Recreational Therapy Services Team ($586, 588); Add 5.0 FTE Clinical Nurse I positions and 5.0 FTE Marriage and Family Therapist II positions to establish a Crisis Intervention Team in partnership with the Office of the Sheriff ($1,328,733); Approved ongoing funding in the amount of $534,504 for 1.5 FTE Pharmacist Specialist and 1.0 FTE Pharmacy Technician position to increase medication dispensing volumes and ensure patients receive medication while in custody.
    • FY 24 Budget: Add 2.0 FTE Mental Health Peer Support Workers for in reach services. 

    Source Report(s): Blue Ribbon Commission on Improving Custody Operations

    Responsible Department(s): Sheriff’s Office, Custody Health Services

    Master List Nos.: 94, 105-106, 116

    Review Date: FGOC reviewed on November 10, 2016.

    Steps Taken: Through industries and in-reach programming with San Jose and Goodwill, the Sheriff’s Office has expanded these areas since February 2016.  

    In collaboration with the Office of Re-Entry Services, Sheriff’s Programs Unit and Rehabilitation Officers conduct monthly meetings to discuss and explore programs and services that will increase the ability to reduce recidivism, with an emphasis on programs that provide development, training, and educational services.

    As part of the pilot program, Five Keys, Work2Future and NOVA will work in collaboration to prepare inmates for employment post-release and to assist them with job placement or pre-apprenticeship programs.

    As of October 31, 2018, 74 inmates were enrolled in Five Keys Charter School and five are currently on track to graduate high school this school year.  There were 80 students enrolled in Five Keys Charter School at Main Jail with 13 on track to graduate high school this school year.

    As of January 28, 2019, there are 41 inmates enrolled in Five Keys Charter School at Elmwood and 60 students enrolled at Main Jail.

    The Sheriff’s Office has been analyzing issues and compiling resource need requests related to this Summarized Recommendation, which will help to conduct research and policy development for both Custody and Enforcement.  The primary function of these positions will be to track, monitor and implement jail reforms.  They will also evaluate external best practices to ensure the Sheriff’s Office Custody and Enforcement Bureaus are remaining up to date and are consistent in both Bureaus.  They will be tasked with developing management reports to recommendations to Executive Staff for areas of improvement.  This will allow Office of Operational Standards and Inspection Unit within the Sheriff’s Office Custody Bureau to focus on audits and policy compliance. They will evaluate commissary options and establish the Vocational Training Program.

    The work being done to increase educational and vocational programming is ongoing. In FY 2019-2020, the Office of the Sheriff has expanded the Five Keys Charter School to include medium security inmates. 

    The Sheriff's Office has reached out to local community colleges regarding vocational services. They are looking to work with numerous colleges in order to provide multiple training programs to both the male and female populations.

    This Summarized Recommendation has been audited by the Office of Correction and Law Enforcement Monitoring (OCLEM) and has been found to be implemented. 

    Budget Status: The Board approved the following:

    • August 2016: 3-year contract for $325,000 with San Jose State University Research Foundation for in-custody education services.
    • FY 2017 Adopted Budget: 6 Rehabilitation Officer positions and 1 Senior Management Analyst ($1.1 million) for programming and discharge planning.
    • FY 2018 Adopted Budget: $250,000 in ongoing funding for the Department of Correction to obtain contract instructors for a Vocational Training Program at both Main Jail and Elmwood
    • FY 2020 Adopted Budget: Added one Senior Management Analyst position to support the Reentry Resource Center’s education and employment services provided to justice involved clients ($156,267).
    • FY 2021 Adopted Budget: Delete 1.0 FTE Rehabilitation Officer II position in the Inmate Screening Unit to screen inmates for in- and out-of-custody programs ($181,738).
    • FY 2021 Adopted Budget: Delete 3.0 FTE Rehabilitation Officer positions ($545,214).
    • February 9, 2021: Delete 1.0 FTE Rehabilitation Officer II position related to the Voluntary Separation Incentive Program as part of the Fiscal Year 2020-2021 Mid-Year Budget Review ($206,474).

    Source Report(s): Sheriff’s Jail Reform Plan, Blue Ribbon Commission on Improving Custody Operations

    Responsible Department(s): Sheriff’s Office

    Master List Nos.: 115, 128, 432, 435, 437-438

    Review Date: FGOC reviewed on November 10, 2016.​

    Steps Taken: The Sheriff’s Office continually evaluates programming to ensure it meets the needs of inmates and helps them to reenter the community and not reoffend. The Sheriff’s Office actively works on discharge planning.

    The Programs Unit has collaborated with the Office of Re-Entry Services to conduct an independent review of programs. These efforts are ongoing and include additional programs and services.​

    As of January 31, 2019, 24% of inmates were actively enrolled in programs.  The Programs Unit has set a goal of increased inmate program participation by 5% annually.

    Budget Status: The Board approved the following:

    • FY 2017 Adopted Budget: 6 Rehabilitation Officer positions and 1 Senior Management Analyst ($1.1 million) for programming and discharge planning.
    • September 10, 2019: An agreement with FIRST 5 Santa Clara County to provide parenting classes at the jail facilities and Reentry Resource Center and family support services in the amount of $500,000.
    • FY 2021 Adopted Budget: Delete 1.0 FTE Rehabilitation Officer II position in the Inmate Screening Unit to screen inmates for in- and out-of-custody programs ($181,738).
    • FY 2021 Adopted Budget: Delete 3.0 FTE Rehabilitation Officer positions ($545,214).
    • February 9, 2021: Delete 1.0 FTE Rehabilitation Officer II position related to the Voluntary Separation Incentive Program as part of the Fiscal Year 2020-2021 Mid-Year Budget Review ($206,474).

    Source Report(s): Commission on the Status of Women, Human Relations Commission, Blue Ribbon Commission on Improving Custody Operations

    Responsible Department(s): Sheriff’s Office

    Master List Nos.: 114, 182, 340, 435

    Review Date: FGOC reviewed on November 10, 2016.​

    Steps Taken: These are all ongoing efforts by the Sheriff’s Office. The Sheriff’s Office is also working with County Procurement and County Information Services Department to release an RFP for tablets that will enable inmates to have more access to educational materials.

    There are 10 Behavioral Health Teams working at Main Jail and Elmwood. They provide crisis intervention, case management, discharge planning, and individual and group therapy. Behavioral Health Team group sessions have also expanded to include 13 weekly Supportive Transition Empowerment Program (STEP) group sessions in addition to the 25 weekly BHT group sessions. As of April 2017, there are 23 sessions being held each week, with a plan to increase group offerings over the next few months. Each group session accommodates between 5 and 10 inmates. Class offerings include:  Illness, Management and Recovery; Anger Management; Seeking Safety; Emotion Management; Thinking for a Change; Healthy Relationships; Dialectical Behavior Therapy (DBT) Skills. In addition, there are 12 weekly sessions related to Substance Use offered. As of November 2018, STEP started offering LGBTQ+ weekly group sessions facilitated by a counselor at the Elmwood facility. LGBTQ+ Services are projected to start at the Main Jail in March 2019.

    From the Sheriff’s Office, blended learning has been incorporated in several housing areas via the use of portable media carts and additional interns/volunteers have been selected to assist in expanding services. The Sheriff’s Office has also begun reviewing educational providers that other counties are utilizing to conduct one-on-one and tablet educational instruction.

    The Inmate Telephones and Tablets RFP was finalized by a multi-departmental team, and it was published on BidSync on November 22, 2017. Legacy Long Distance International, Inc. was awarded the Inmate Telephones and Tablets agreement at no cost to the County on October 22, 2019. The Sheriff's Office and TSS are working with the contractor to start the new inmate phone service by the end of June 2020. FAF is currently installing WiFi at the Main Jail to support the tablet implementation, while work is pending to start at the Elmwood complex. The tablet implementation is dependent on the completion of the WiFi installation project (JNICE). As such, the tablet implementation will be a phase II portion of the Legacy Long Distance International, Inc. work to be completed.

    As part of the pilot program, Five Keys, Work2Future and NOVA will work in collaboration to prepare inmates for employment post-release and to assist them with job placement or pre-apprenticeship programs.  In addition to Five Keys programming, the new In-Custody Programs Manager is evaluating current programming needs to identify potential expansion of inmate programs.

    As of October 31, 2018, 74 inmates were enrolled in Five Keys Charter School and five are currently on track to graduate high school this school year.  There were 80 students enrolled in Five Keys Charter School at Main Jail with 13 on track to graduate high school this school year.

    On August 14, 2018, the Board approved the amendments to agreements with two chaplaincy services organizations that are responsible for the coordination and delivery of all religious services for individuals while in custody. Through one of these amendments, a professionally trained Muslim chaplain will be added to serve the needs of Muslim inmates.

    As of January 31, 2019, 24% of inmates were actively enrolled in programs.  The Programs Unit has set a goal of increased inmate program participation by 5% annually.

    On April 15, 2019, female inmates were moved from one of the oldest housing units at Elmwood, W1, to the newest housing unit at Elmwood, M1.  The move included a welcome reception with medical, mental health, and service providers who would be assigned to M1.

    As of May 1, 2019, the Classification Unit rehoused the remaining inmates from M1, and successfully integrated them into general population housing.  This was the most recent move to further integrate female inmates into less restrictive housing, increase out of cell time, and to encourage increased participation in programming.

    The Sheriff's Office Custody Bureau Programs Unit has been working with multiple providers to increase the number of in-custody programs. In 2018, the Sheriff's Office offered 28 unduplicated program courses. As of February 2020, they have 82 unduplicated program courses in collaboration with Custody Health and Chaplaincy services.

    On September 10, 2019, the Board approved an agreement with FIRST 5 Santa Clara County to provide parenting classes at the jail facilities and Reentry Resource Center and family support services to criminal justice involved individuals.

    On December 10, 2019, the Board approved the amendments to agreements with two chaplaincy services organizations that are responsible for the coordination and delivery of all religious services for individuals while in custody. These providers also act as liaisons between the Sheriff's Office and various religious communties.

    On December 15, 2020, the Board approved an agreement with GTL to take over the original contract with Legacy Long Distance International, Inc. for providing inmate telephone and tablet services in the jails.

    This Summarized Recommendation is pending review by the Office of Correction and Law Enforcement Monitoring (OCLEM) as part of the Jail Reforms Audit to assess the status of implementation.

    Budget Status: The Board approved the following:

    • FY 2017 Adopted Budget: 6 Rehabilitation Officer positions and 1 Senior Management Analyst ($1.1 million) for programming and discharge planning.
    • December 2016: Agreements for chaplaincy services within the jails
    • FY 2019 Adopted Budget: Approved funding in the amount of $1,250,000 for WiFi expansion at the County Jail to support Jail Inmate Service Platform Tablets and funding in the amount of $1,440,000 for the Inmate Tablets/Phones.
    • September 10, 2019: Approved an agreement with FIRST 5 Santa Clara County to provide parenting education classes at the jail facilities and Reentry Resource Center and family support services in the amount of $500,000.
    • December 10, 2019: Approved second amendments to agreements for chaplaincy services within the jails to increase the contract amounts by $312,088.
    • FY 2021 Adopted Budget: Delete 1.0 FTE Rehabilitation Officer II position in the Inmate Screening Unit to screen inmates for in- and out-of-custody programs ($181,738).
    • FY 2021 Adopted Budget: Delete 3.0 FTE Rehabilitation Officer positions ($545,214.).
    • December 15, 2020: The Board approved Assignment Agreement assigning the Jail Inmate Services Program contract with Legacy Long Distance International, Inc. relating to the implementation of an inmate phone and tablet service.
    • February 9, 2021: Delete 1.0 FTE Rehabilitation Officer II position related to the Voluntary Separation Incentive Program as part of the Fiscal Year 2020-2021 Mid-Year Budget Review ($206,474).  

    Source Report(s): Sheriff’s Jail Reform Plan, Commission on the Status of Women, Human Relations Commission, Blue Ribbon Commission on Improving Custody Operations

    Responsible Department(s): Sheriff’s Office

    Master List Nos.: 93, 118-122, 126-127, 180, 339, 433-434, 436, 439

    Review Date: FGOC reviewed on November 10, 2016.​

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