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March 6, 2020 - SB 1206

 

Members,
We are continuing our advocacy to move SB 1206 to the Senate Floor but wanted you to know that HB 731, the AHCA bill that contains a health clinic licensure exemption for all Medicaid providers, moved forward again today and will be ready for a vote on the House Floor early next week.

Take Action Now!

Let Senate President Bill Galvano know that SB 1206 – Applied Behavior Analysis is critical to making sure children with special needs receive medically necessary services. One more time! We are asking each of you to contact Senate President Bill Galvano to make sure that Senate Bill 1206 – Applied Behavior Analysis is either withdrawn from the Senate Appropriations Committee or heard by the Senate Appropriations Committee. As of today, SB 1206 is still stuck in Senate Appropriations and cannot advance. If the bill is withdrawn or heard in Senate Appropriations the bill can move to the Senate Calendar and be matched up with its companion bill, HB 575, that has already passed the House and is awaiting action by the Senate. Please feel free to customize the draft e-mail so that it applies to your unique personal situation.

Go the Action Center now to send your e-mail: 

https://www.votervoice.net/FABA/campaigns/72144/respond




 

May 4, 2019 - AHCA Announces New Proposed Changes to Florida Medicaid Behavior Analysis

 

The Agency for Health Care Administration (AHCA) hosted a packed meeting in Tallahassee on March 29, 2019, to announce updates regarding the delivery of Florida Medicaid Behavior Analysis services. The meeting featured a presentation by representatives from the Agency where they announced a number of updates, which are summarized below. 

A number of these updates may be positive developments that will hopefully increase access to service and efficiency in the near future. However, the proposed rate reductions are concerning and have the potential to dramatically limit quality providers’ ability to render service. The most effective way to put a stop to these proposed changes is by reaching out to your lawmakers and asking them to STOP THE CUTS. You can seamlessly email and call them NOW using the FABA Action Center.

Here is a summary of the updates that were announced:

Changes to Reimbursement Rates
AHCA believes the current rates are significantly higher than is necessary to ensure access to the service statewide, especially when examining the actual wages earned by professionals providing the service. AHCA is working to realign provider reimbursement rates with a revised methodology. 

The proposed changes in the rates include:

  • The rates for a Behavior Analysis Assessment will decrease from $385.19 to $301.31
  • The rates for a Behavior Analysis Reassessment will decrease from $192.59 to $150.65
  • The rates for a Behavior Analysis Lead, per quarter hour, will remain the same at $19.05
  • The rates for a Behavior Analysis Assistant, per quarter hour, will decrease from $15.24 to $10.52
  • The rates for a Behavior Analysis Registered Behavior Technician, per quarter hour, are decreasing from $12.19 to $5.98

Provider Enrollment Moratorium
AHCA is seeking to partially lift the moratorium in Miami-Dade and Broward counties. This will include registered behavior technicians, lead analysts, and board certified assistant behavior analysts seeking enrollment to participate as a member of a provider group that is already enrolled in Florida Medicaid. However, the moratorium will remain in effect for new group providers and lead analysts wishing to practice independently. The goal is for this to take place at the end of April. AHCA will host provider enrollment trainings in late April and early May.

Health Care Clinic License
Provider groups will be required to prove that they have a health care clinic license by December 31, 2019 or provide a copy of the certificate of exemption. This requirement is not new, but stronger verification procedures will be implemented. 

Multidisciplinary Team Approach
In an attempt to streamline the delivery of medically necessary services, AHCA will be implementing a Multidisciplinary Team (MDT) approach. The MDT approach includes telephone or home visit contacts with parents, medical documentation review by clinicians from two separate disciplines, and a team meeting that can include the provider.

Coverage Policy Revisions
The behavior analysis coverage policy will be combined into one policy with other Medicaid-covered behavior modification and intervention services. However, the Agency did not address one of FABA’s top priorities regarding a requirement that treatment programs be administered by a lead analyst who is a Board Certified Behavior Analyst.

Electronic Visit Verification
The Agency is working on implementing an Electronic Visit Verification (EVV) requirement. The EVV policy will require providers to check in and check out using an app on a mobile phone. This will link the provider check in with a claim submission and ensures submitted claims information is valid and aligns with prior authorization information.

This is the first of a series of meetings that will be held across the state. Over the next month and a half, additional meetings will be held at the following locations:

  • Tampa
    Friday, April 5 at 10:30am
  • Orlando
    Thursday, April 18 at 10:30am
  • Jacksonville
    Friday, April 19 at 10:30am
  • Miami
    Thursday, April 25 at 10:30am
  • Ft. Lauderdale
    Friday, April 26 at 10:30am
  • Pensacola
    Friday, May 10 at 10:30am

It’s important to note that none of these changes are finalized right now, so it is critical that FABA members do everything possible to attend these meetings and provide feedback and public testimony. We also need as many providers and parents as possible to email their lawmakers and the governor using the FABA Action Center. 

 


 

May 19, 2017 – Attention FL Medicaid ABA Providers!

Please find below some helpful resources, courtesy of AHCA.

The Medicaid Public Web Portal provides access to the Provider Services page where providers can obtain helpful information including:

  • Electronic Data Interchange (EDI) including companion guides for the creation of claims, EDI software and manuals, EDI forms and agreements, and Submission Information such as an interactive Web site for testing claims transactions and sample files.
  • Provider Enrollment guidance and forms.
  • Provider support including alerts of policy or protocol changes, links to Medicaid handbooks and fee schedules, and contact information.
  • Provider Training

https://portal.flmmis.com/FLPublic/Provider_PublicHome/tabId/36/Default.aspx

Web-based Trainings

  • The Provider Electronic Solutions (PES) Web-based Training (WBT) is an interactive walk-through that introduces providers to the available menu items in PES and provides step-by-step instructions for completing and submitting claims via PES.
  • The Web Portal WBT is designed to demonstrate various functionality of the Medicaid Web Portal through an interactive walk-through that introduces providers to the available menu items that provide important provider information such as provider demographics and recipient eligibility.

http://portal.flmmis.com/FLPublic/Provider_ProviderServices/Provider_Training/Provider_Training_WBT/tabId/86/Default.aspx

The Medicaid Provider Contact page provides links to contact information for the following:

  • The Medicaid Fiscal Agent, DXC Technology, for claims and provider enrollment inquiries and assistance with access to the Medicaid Secure Web Portal.
  • Recipient and Provider Assistance to contact a Medicaid representative.
  • Fiscal Agent Field Representative Map
  • Online tool for submission of and inquiry and to request a contact from the Fiscal Agent.

https://portal.flmmis.com/FLPublic/Provider_ProviderServices/Provider_ProviderSupport/Provider_ContactUs/tabId/40/Default.aspx


 

May 15, 2017 – Attention providers of Medicaid ABA services:

The FAQs for Behavior Analysis services have been posted to the AHCA website. They are located at the bottom of the page after the Enrollment Begins Now section. For your convenience, the link is Included below.

https://portal.flmmis.com/FLPublic/Provider_ProviderServices/Provider_ProviderSupport/Provider_ContactUs/tabId/40/Default.aspx


 

April 18, 2017 – Florida Behavior Analysis Month

The Florida Senate approved Resolution No. 1814 Commending FABA on its 37th Anniversary, and recognizing the month of October 2017 as “Florida Behavior Analysis Month”!!! The resolution was introduced by Senator Bean.


 

April 24, 2017 – ATTENTION MEDICAID PROVIDERS OF ABA SERVICES!

AHCA has reported a drop in authorization requests since the deadline was pushed back to May 15. It is important that providers keep sending their authorization requests during this transition period to avoid the last minute rush just prior to May 15. If too many requests come in at the last minute, it could delay authorizations for everyone.


 

March 23, 2017 – Important Updates/Clarifications

Many of us have heard in the Beacon trainings (regarding the Medicaid Behavior Analysis Services Policy) that clients must have maladaptive behavior to be approved for Behavior Analysis services. In a recent meeting between the FABA Legislative Committee and AHCA, we were told that Behavior Assessments that are missing maladaptive behaviors will not be denied for that reason alone. Instead, they will be escalated to a higher level review to determine medical necessity. Medically necessary services, which include habilitative services according to EPSDT, are covered.

To help providers understand what is important to include in their authorization requests, Beacon has reported some trends in the Behavior Plans received from Lead Analysts. These include:

  • Lack of parent/caregiver goals
  • Service intensity not justified in the plan
  • Group code requested but no group goal addressed
  • Plan not individualized to the recipient

However, to date, Beacon has not denied any authorizations. Please make sure to pay close attention to the above trends to help facilitate the authorization process.

Many of our members have contacted FABA to ask for help because their Type 39 Provider application has still not been approved. AHCA has been informed about this urgent issue and is looking into options to remedy the situation. In the meantime, they have suggested that those who need help with applications should contact the following:

[email protected]
For more information:
Medicaid Provider Type 39 enrollment number:
1-800-289-7799
(option 4) for Provider Enrollment


 

March 15, 2017 – Behavior Assessments that are missing maladaptive behaviors

Many of us have heard in the Beacon trainings (regarding the Medicaid Behavior Analysis Services Policy) that clients must have maladaptive behavior to be approved for Behavior Analysis services. In a recent meeting between the FABA Legislative Committee and AHCA, we were told that Behavior Assessments that are missing maladaptive behaviors will not be denied for that reason alone. Instead, they will be escalated to a higher level review to determine medical necessity. Medically necessary services, which includes habilitative services according to EPSDT, are covered.

To help providers understand what is important to include in their authorization requests, Beacon has reported that the most common reasons that authorization requests have been denied include:

  • Lack of parent/caregiver goals
  • Service intensity is not justified

Many of our members have contacted FABA to ask for help because their Type 39 Provider application has still not been approved. AHCA has been informed about this urgent issue and is looking into options to remedy the situation. In the meantime, they have suggested that those who need help with applications should contact the following: [email protected]

Please make sure to check the http://www.fabaworld.org website for important announcements and updates.


 

February 3, 2017 – AHCA Agrees to Delay Implementation of Behavior Analysis Policy Until March 1, 2017

The implementation of the new Medicaid Behavior Analysis Policy for children age 0-20 was planned to start on February 1, 2017.  As of that date, many ABA agencies and individual providers had not yet received their new Type 39 provider number.  This would have meant that many providers would not be able to get reimbursed for their services until their application was approved.  Since many providers would not be able to continue providing services without pay, resulting in loss of services for many recipients, the FABA Legislative Committee brought these concerns to AHCA.  After some deliberation, AHCA agreed to delay the requirement to begin using the new billing codes (which can only be provided by Type 39 providers) until March 1, 2017.

The requirement to have an authorization from Beacon prior to April 3, 2017 is still in place, so all providers planning to provide services for recipients age 0-20 on or after April 3 will need to request an authorization.


 

FABA Successfully Challenges AHCA Policy on Behavior Analysis Services & Encourages Its Members to Immediately Enroll In The BA Services Program

As we previously reported, on November 14, 2016, the Florida Association for Behavior Analysis filed a petition with the Division of Administrative Hearings in Tallahassee, challenging the Agency for Health Care Administration’s (AHCA) adoption of Proposed Rule 59G-4.125, F.A.C., regarding its Behavior Analysis Services Policy.

FABA’s challenge to the published policy focused on preserving positive changes to the policy achieved during the workshop and hearing process, as well as making sure that the policy is limited to behavior analysis services, not services that have no connection to behavior analysis. For example, it was important the policy was clarified that psychological testing, neuropsychology, psychotherapy, cognitive therapy, sex therapy, psychoanalysis, hypnotherapy, and long-term counseling are not to be reimbursed under the behavior analysis policy. Further, it was essential that the policy require that lead analysts who are not BCBA’s but who are licensed under Chapter 490 or 491, have training and expertise in the field of behavior analysis.

A link to the second notice of change for the policy is found here:
http://www.ahca.myflorida.com/medicaid/review/Rules_in_Process/NOC/59G-4.125_BA_Coverage_Policy_afterNOC2_trk_chgs.pdf and incorporates revisions made in each of the workshops and the final proposed rule hearing. FABA and AHCA filed a joint motion to dismiss the petition based upon AHCA’s changes to the behavior analysis policy, which has been accepted by the administrative law judge.

With the major policy considerations resolved as a result of the litigation, FABA encourages its members to ENROLL IMMEDIATELY in the behavior analysis provider program at the Florida Medicaid Web Portal. As most of you know, ABA services for Medicaid recipients under the age of 21 will soon be required to be provided under the new Medicaid Behavior Analysis policy, and ABA services provided through all other Medicaid funding streams (e.g., Early Intervention, Community Behavioral Health, iBudget Waiver, “state plan” Autism services) will be discontinued.

Although the policy is expected to be officially promulgated in mid-February, the implementation of the new policy starts February 1, 2017, which is only a week away.  According to AHCA and Beacon, all services provided on or after that date will have to be billed under the new policy’s service codes and limits, and only agencies and individuals with Type 39 provider numbers will be able to provide those services.  If you are currently providing ABA services under another Medicaid policy and have not received your Type 39 provider number yet, you will not be able to be paid for services after 2/1/17.  All ABA provider types (BCBA “Lead Analyst,” BCaBA “Assistant Behavior Analyst,” and RBT) are required to obtain an individual provider number, even if providing services under a Type 39 group.

Between 2/1/17 and 4/2/17, providers need to be submitting authorization requests for ABA services to Beacon because all services provided on or after April 3, 2017 will be required to have an authorization from Beacon in order to be paid.  Only approved Type 39 providers will have access to the Beacon system to submit authorization requests.  Beacon has pre-recorded trainings to explain the authorization process and the elements required in the Behavioral Assessment and Reassessment.

Link to AHCA Behavior Analysis Services Provider
Information: http://ahca.myflorida.com/medicaid/Policy_and_Quality/Policy/behavioral_health_coverage/bhfu/BA_Services.shtml

Link to the Beacon pre-recorded trainings:
http://fl.beaconhealthoptions.com/provider/prv-archive.html

Link to the most recent version of the proposed Behavior Analysis policy:
http://ahca.myflorida.com/medicaid/review/Rules_in_Process/NOC/59G-4.125_BA_Coverage_Policy_afterNOC2_trk_chgs.pdf

Link to the proposed Behavior Analysis billing codes and fee schedule:
http://ahca.myflorida.com/medicaid/review/Rules_in_Process/Develop/2016-08-01_BA_Fee_Schedule.pdf

Link to the AHCA Provider Enrollment Application:
https://portal.flmmis.com/flpublic/Provider_ProviderServices/Provider_Enrollment/Provider_Enrollment_EnrollmentApplication/tabid/67/Default.aspx?desktopdefault=%20

Link to the AHCA Provider Enrollment Application Guide:
http://portal.flmmis.com/FLPublic/Portals/0/StaticContent/Public/Public%20Misc%20Files/Guide_for_App_for_2015_Final_2015-02-27.pdf


 

May 30, 2016 – Medicaid Policy on Behavior Analysis Coverage


April 14, 2016, – New Insurance Coverage Law for Down Syndrome Treatment Includes Behavior Analysis Services

On April 14, 2016, Governor Rick Scott signed House Bill 221, which requires health maintenance organization contract and certain insurance policies to cover behavior analysis services for the treatment of Down Syndrome. Previously, Florida statutes provided that behavior analysis services were only mandated for the treatment of autism, however this change significantly expands the law. Thank you to Senate President Andy Gardiner who help shepherd this long-overdue amendment to the insurance law. This change is effective July 1, 2016, and FABA will be working with the Office of Insurance Regulation to make sure families can access this new insurance benefit.


 

April 7, 2016 – AHCA Holds Workshop On Medicaid Policy For Behavior Analysis Service & Contracts With Beacon Health Options For Utilization Management

On April 7, 2016, the Agency for Health Care Administration held its third workshop on the new policy for behavior analysis services. FABA participated in the workshop and commented on the need to include an accurate definition of behavior analysis as well other issues that should be addressed before the policy is finalized. AHCA is expected to publish a revised policy and a notice of hearing on the policy in the near future. AHCA also selected Beacon Health Options as its vendor to handle utilization management for behavior analysis services for the treatment of autism under the Medicaid program. FABA met with members of Beacon’s leadership team to discuss their role in authorizing and reviewing behavior analysis services for the Florida Medicaid program. Beacon has considerable experience working with BCBAs in other states and FABA looks forward to Beacon presenting at the Annual Meeting in September.

 
 Digital Archive File Number Title of Document Desciption Associated Dates
1993Hx001 13th Annual Call for Presentation Announcement FABA 93 Announcement 9/22/93
1993Hx002 Offical FABA Nominations Ballot    
1993Hx003 Proceedings Note Pad for the 13th Annual Convention Blank  
1993Hx004 1993 Behavior Counts Catalog Cover    
1993Hx005 FABA 93 Program (67 Pages) Convention held in Ft Lauderdale 9/22/93
1993Hx006 FABA Newsletter Volume 13 Number 1   Spring 93
1993Hx007 FABA Newsletter   Summer 93
1993Hx008 FABA Newsletter Special Pre-Conference Issue   Summer 93
1993Hx009 FABA Newsletter Volume 14 Number 1    
FABA Party Singers.jpg Cute picture of a group of singers during the Conference    
 
 Digital Archive File Number Title of Document Desciption Associated Dates
1983Hx001 Two Day Workshop Announcement Legal sized flyer that announced the February Two Day Workshop and provided a paper slip tp register for the hotel. 2/10/83                   2/11/83
1983Hx002 Program for the 2nd Day Workshop Three paper booklet with the workshops' schedule, presenters, and topics. 2/11/83
1983Hx003 November 1982* FABA Quarterly Volume 3 No 1 Eight page booklet; editors Bill Wehr and Linda Mintle; President Jerry Martin of Sunland 11/1/82
1983Hx004 February 1983 FABA Quaterly Volume 3 No 2 Eight page booklet; editors Bill Wehr and Gary M. Jackson; headline by Reed Martin on Legal Issues of Behavior Modification 2/1/83
1983Hx005 Small conference pre-registration and membership application Small 1/3 sized slip with a deadline of August 19, 1983 to Jon S. Bailey 8/19/83
1983Hx006 Third Annual Meeting and Two Day Work Session Announcement Legal sized flyer announced the Annual Meeting in September highlighting the special invited presentation by David Pingree N/A
1983Hx007 May 1983 FABA Quarterly Volume 3 No 3  Eight page booklet; editors Bill Wehr and Gary M. Jackson; Call for Papers for 1983 Meeting  5/1/83
1983Hx008 August 1983 FABA Quarterly Volume 3 No 4 Eight page booklet; editors Bill Wehr and Gary M. Jackson; Further Information on Third Annual Meeting 8/1/83
1983Hx009 Third Annual Meeting Program Three fold eighteen page booklet;  Hilton Inn Florida Center in Orlando 9/15/83
1983Hx010 Speaker Reimbursement for Expenses Single Page form N/A
1983Hx011 Participant Survey Single Page form N/A
1983Hx012 Overall Worksheet and Session Evaluation Sheet Two sided half page evaluation sheet N/A
1983Hx013 Template Letter for Returned Registration Single page template letter to inform member of registration received after the deadline.  N/A
1983Hx014 Pre-Registration Response Cover Letter Single page form with three response options for pre-registrations received 8/23/83
1983Hx015 Group Registration Letter Single Page letter defining the different ways to obtain group registration N/A
1983Hx016 List of Pre-Registered Members Six page list of paid and not paid pre-registered members N/A
1983Hx017 Revised List of all Paid FABA Members Twenty-four page print out with hand written note: "as of 8/19/83" 8/19/83
1983Hx018 List of Paid FABA Members Twenty-four page print out with handwritten notes: "FABA Dues Pd Members as of 7/29/83" and "Approx 255 are paid out of 730."  7/29/83
1983Hx019 Convention Income & Expenses 1981, 1982, 1983 Single Page print out comparing income and expenses for the conference years (81, 82, 83) N/A
1983Hx020 Hand Written Notes on Letterhead (Jon Bailey) Single page blank letterhead with handwritten notes: "Things to Do." N/A
1983Hx021 Hand Written Conference Notes on Notebook Paper (Jon Bailey) Three page hand written notes: "1983 Conf Notes." 9/17/83
1983Hx022 Hand Written Conference Notes on Letterhead Single page hand written note: "Executive Committee Meeting  9/14/83
1983Hx023 Draft Invitation to Speakers to become Members Single page print out of template thanking speakers and asking them to join as members 10/4/83
1983Hx024 Conference Badge Ribbons Two ribbons one for Secretary and one for FABA staff N/A
1983Hx025 Hand Written Survery Data Two page hand written notes on yellow legal paper: "Survery Data." 10/28/83
1983Hx026 Letter to Governor Graham Two separate letters scanned together; one being a draft to Gov. Graham from Jon Bailey 7/27/83
1983Hx027 Governor Graham Letter Two page scan of single page Response letter from Gov Graham and the envelope it was mailed in. 8/2/83
1983Hx028 Drafts of Call for Papers Two page scan of single page print out draft of Call for Papers and single page scan of hand written sketch for the Call for Papers. 7/1/83
1983Hx029 Correspondence packet with David Pingree Three page scan of single page print out letter to Secretary David Pingree from Maxin Reiss, single page response letter from Sec. Pingree accepting our invitation to speak at the 1983 conference; single page response thank you from Jon Bailey. 3/26/83
1983Hx030 FABA Conference 1983 Proposed Speaker List Single page print out of a list of proposed speakers N/A
1983Hx031 FABA Paper Presentations Three page print out of paper presentations including presenter, time requirements, and title. N/A
1983Hx032 Draft of Speaker Biographies Two page print out of select individuals' biography paragraphs N/A
1983Hx033 Gorden Paul Speaker Acceptance Response letter Single page letter from Gorden Paul accepting our invitation to speak at the conference on University of Houston letterhead. 4/22/83
1983Hx034 Photo Use Request Letter Single page letter to Mary Tomlinson at Disney requesting permission to use Spaceship Earth" photo on the cover of the program. 6/6/83
1983Hx035 General Correspondence  Single page letter from Louis Hoechstetter at FSH about rejected registration and checks. 8/11/83
1983Hx036 Call for Papers Draft Single page draft of the call for papers with hand written note: "Attached to S/83 Newsletter."  7/8/83
1983Hx037 Cover Letter Membership Reminder Single page letter from Darrel Bostow reminding members about dues and the upcoming deadline. 1/27/83
1983Hx038 Letter from President  Single page letter from Jerry Martin notifying Executive Committee of his scheduling a meeting during the Two Day Spring Workshop 1/10/83
1983Hx039 Hand Written Conference Notes* on Notebook Paper (Linda Mintle) Single page hand written notes from Linda Mintle to Darrel Bostow on notebook paper: "The following information would be helpful for the newsletter." 11/1/82
1983Hx040 Next Step to Get Nov 82 FABA Newsletters in the Mail Single page letter to Darrel Bostow from Bob Wehr about Steps to Get Nov 82 Newsletter in the mail. 12/1/82
1983Hx041 Cover Letter for FABA Directory of Members Two page scan of single page letter to members from Darrel Bostow announcing the attachment of a membership directory and a single page scan of a membership application. 4/12/83
1983Hx042 Executive Committee Meeting October Agenda Single page print out on letterhead with a post conference agenda on it. 10/28/83
1983Hx043 Treasurer's Report or Compilation Fifteen page scan of memberhsip stats, hand written notes: "Cash Flow," graphs on registrations, room pick up, and paid/ not paid print out reports.  N/A
1983Hx044 On Site Registration Stats Nine page report of on site registrations and hand written notes on calaculations with "9/26/83." 9/26/83
1983Hx045 1983 FABA Registrations Eight page print out listing member names and registration fees paid with hand written notes on income calculations. N/A
1983Hx046 Various receipts and financial correspondence Twelve page scan of various receipts for expenses, correspondence regarding checks, and checks received. N/A
 

 

 

The new ABA Ethics Hotline Website is now available!

Sometimes it is difficult to understand how the Code of Ethics for our field applies to your specific situation.  The ABA Ethics Hotline site offers responses for difficult situations that arise every day in the practice of behavior analysis.


Originally Posted: Monday, October  8, 2018


 
The 2018 Program is now on line!
 

Originally Posted: Friday, September 9, 2018


 

2018 FABA Board of Directors Election is now open!
For more information on FABA's annual elections,
please contact Corey Robertson

Originally Posted: Friday, August 31, 2018


 

The Call for Papers is Now Open!

Submission Deadline:  Sunday, April 15th   11:59 PM EST
FABA is currently accepting submissions for our 2018 Annual Conference.  

Click here for more information on submissions:  Call for Papers

Originally Posted: Monday, March 19, 2018

 

 

2020

  15-3     Summer 2020  
   15-2     Spring 2020  

2019

  15-1     Winter 2019  
  14-3     Summer 2019  
  14.2     Spring 2019

2018

  13.4     Fall 2018
  13.3     Summer 2018  
  13.2     Spring 2018  

 

 

 

 

 

 

 

 
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