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Published: Jun 30, 2026

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Psychiatric NP Scope of Practice for General Psychiatry in Michigan

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Written by Klarity Editorial Team

Published: Jun 30, 2026

Psychiatric NP Scope of Practice for General Psychiatry in Michigan
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If you’re a psychiatrist or psychiatric nurse practitioner considering telehealth — or already practicing remotely — you’ve probably asked yourself: ‘Can I legally prescribe Adderall, Xanax, or buprenorphine to a patient I’ve never met in person?’

The answer in 2026 is: Yes, for now — but the rules are changing soon, and they vary dramatically by state.

Here’s the reality: Federal telehealth flexibilities that have allowed controlled substance prescribing without an in-person visit are extended through December 31, 2026. But the DEA is finalizing permanent rules that will reshape how psychiatrists and PMHNPs prescribe stimulants, benzodiazepines, and addiction medications remotely. On top of that, each state has its own telehealth laws, PDMP requirements, and scope-of-practice regulations that can make or break your ability to practice across state lines.

This guide cuts through the regulatory fog. We’ll cover what’s allowed right now under federal law, what’s coming in the DEA’s proposed rules, and how state laws in California, Texas, Florida, New York, Pennsylvania, and Illinois affect your ability to prescribe via telehealth — whether you’re an MD/DO psychiatrist or a PMHNP.


Federal Rules: Where Things Stand in 2026

The Ryan Haight Act and COVID-Era Waivers

Under normal circumstances, the Ryan Haight Act (passed in 2008) requires at least one in-person medical evaluation before a provider can prescribe controlled substances via the internet. This was meant to stop pill mills, but it created a barrier for legitimate telepsychiatry.

When COVID hit in March 2020, federal agencies invoked emergency authority to waive the in-person requirement. Psychiatrists and PMHNPs could suddenly evaluate new patients via video and prescribe Schedule II–V medications (stimulants, benzodiazepines, buprenorphine, etc.) without ever meeting them face-to-face.

That waiver has been extended multiple times. As of January 2, 2026, HHS and the DEA announced a fourth extension through December 31, 2026, ensuring no disruption in care while permanent rules are finalized.

What this means for you right now:

  • You can prescribe controlled substances to new patients after a telehealth evaluation (video strongly recommended, audio-only limited to specific cases like buprenorphine).
  • You don’t need a prior in-person visit.
  • You must still follow all other DEA regulations: proper evaluation, legitimate medical purpose, use of PDMP databases, and compliance with state laws.

If a patient has ever been seen in person by you or another provider in your practice, there’s no federal telehealth restriction on prescribing controlled medications — you can manage them remotely indefinitely (state laws permitting).

What’s Coming: DEA’s Proposed Permanent Rules

The DEA is working on three proposed rules to replace the temporary waivers. Here’s what’s on the table:

1. Special Telemedicine Registration for Controlled Substances

The DEA wants to create a ‘Special Telemedicine Prescriber Registration’ that would allow certain qualified providers to prescribe controlled substances to new patients via telehealth without an in-person visit.

  • For Schedule III–V medications (like Suboxone, Xanax, Ambien), any qualified prescriber could apply for this registration.
  • For Schedule II medications (like Adderall, Ritalin, Vyvanse), the DEA is initially limiting eligibility to board-certified psychiatrists, hospice/palliative care physicians, long-term care physicians, and pediatricians.

This is huge for psychiatry: if finalized, psychiatrists could get a special registration to legally prescribe stimulants for ADHD via telehealth-only care. PMHNPs would be able to prescribe Schedule III–V independently (if their state allows), but would need to work with a psychiatrist for Schedule II prescriptions under this framework.

The proposal also includes new requirements:

  • Telehealth platforms must register with the DEA for the first time.
  • A national PDMP system would be created to track controlled prescriptions across states.
  • Providers would likely need to submit annual reports on their telehealth prescribing activity.

2. Buprenorphine for Opioid Use Disorder

The DEA is proposing to allow 6 months of buprenorphine treatment via telehealth (including audio-only visits) before requiring an in-person evaluation. This acknowledges that telemedicine has dramatically improved access to addiction treatment.

For psychiatrists managing OUD, this is a win — you could initiate and stabilize patients on buprenorphine remotely, then require an in-person follow-up at the 6-month mark.

3. VA Continuity of Care Rule

A third rule allows VA providers to prescribe controlled substances via telehealth if the patient had any in-person exam within the VA system (even by a different provider). This treats the VA as one integrated system for telehealth purposes — interesting precedent, but mainly relevant to VA psychiatrists.

Timeline: These rules are still in the comment period. The DEA could finalize them anytime in 2026. Expect some version of the special telemedicine registration to take effect before the end of the year.


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State-by-State Telehealth Prescribing Rules

Federal law sets the floor, but states can impose stricter rules — and many do. Here’s what you need to know in our priority states:

California: Telehealth-Friendly with Strict Compliance Requirements

Bottom line: California allows controlled substance prescribing via telehealth with no in-person requirement, as long as you meet the standard of care.

Key requirements:

  • PDMP checks: You must query the CURES database before prescribing any Schedule II–IV medication to a patient for the first time, and then every 4 months if you continue prescribing.
  • E-prescribing: Mandatory for all prescriptions since January 2022 (paper scripts essentially banned).
  • Standard of care: A video exam is sufficient to establish a patient relationship and prescribe.

PMHNP scope: California is transitioning to full practice authority for experienced NPs. As of 2023, NPs with 3+ years experience can practice without physician supervision in group settings. By 2026, they’ll be able to open independent practices. This makes California a strong state for telepsychiatry platforms using NPs.

Multi-state practice: California joined the Interstate Medical Licensure Compact (IMLC) in 2022, making it easier for out-of-state psychiatrists to get licensed.

Texas: Restrictive for NPs, Watch Out for Schedule II Limits

Bottom line: Texas allows telehealth prescribing under federal waivers, but has strict rules for nurse practitioners and chronic pain.

Key requirements:

  • NPs cannot prescribe Schedule II except in hospitals or hospice settings. This means a Texas PMHNP cannot write a prescription for Adderall for an outpatient ADHD patient — that must be done by a physician.
  • Chronic pain rule: Texas prohibits prescribing controlled substances for chronic pain via telemedicine without a prior in-person evaluation. (This mainly affects pain management, not general psychiatry.)
  • PDMP: Mandatory check of the Texas PMP before prescribing opioids, benzodiazepines, barbiturates, or carisoprodol.

PMHNP scope: Texas requires physician supervision for all NP practice. A PMHNP must have a written delegation agreement with an MD or DO at all times.

For telehealth platforms: If you’re treating Texas patients, you’ll need psychiatrists (MDs) to handle Schedule II prescriptions. Texas is in the IMLC, so out-of-state psychiatrists can get licensed relatively easily.

Florida: Psychiatric Exception for Schedule II — But Read the Fine Print

Bottom line: Florida has a unique carve-out that allows Schedule II prescribing via telehealth only for psychiatric treatment (and a few other limited scenarios).

Key requirements:

  • Schedule II restriction: You can prescribe Schedule II controlled substances via telehealth only if it’s for:
  • Psychiatric disorder treatment
  • Inpatient hospital care
  • Hospice care
  • Nursing home residents

This means a Florida psychiatrist or PMHNP can prescribe Adderall for ADHD via telehealth (psychiatric treatment), but cannot prescribe oxycodone for chronic pain remotely.

  • Out-of-state registration: Florida allows out-of-state providers to register as ‘telehealth providers’ to treat Florida patients without a full Florida license. However, they’re still bound by the Schedule II prescribing restrictions.
  • PDMP: Must check E-FORCSE before prescribing any controlled substance to patients 16 or older.
  • E-prescribing: Mandatory for controlled substances since 2021.

PMHNP scope: Psychiatric NPs in Florida require a collaborative agreement with a physician (no independent practice for psych specialty). Florida does allow some primary care NPs to practice autonomously, but that doesn’t apply to PMHNPs.

Documentation tip: Always document the psychiatric indication for any Schedule II prescription to show it falls under the allowed categories.

New York: Progressive NP Laws, Strict PDMP and E-Prescribing

Bottom line: New York allows telehealth prescribing with no in-person requirement, and experienced NPs can practice independently.

Key requirements:

  • PDMP: Mandatory check of the I-STOP registry before prescribing every Schedule II, III, or IV medication (one of the strictest PDMP laws in the country).
  • E-prescribing: Required for all prescriptions (controlled and non-controlled) since 2016.
  • Standard of care: Video exam is sufficient; no prior in-person visit required by state law.

PMHNP scope: New York now allows full practice authority for NPs with 3,600+ clinical hours (roughly 3 years of practice under collaboration). Once they hit that threshold, they can practice and prescribe independently, including controlled substances. New NPs below that threshold must have a formal collaborative agreement with a physician.

For telehealth platforms: New York is a great state for utilizing experienced PMHNPs. However, New York is not in the IMLC or Nurse Licensure Compact, so out-of-state providers must go through the full licensing process.

Pennsylvania: No Specific Telehealth Law, But PDMP and NP Collaboration Required

Bottom line: Pennsylvania allows telehealth prescribing under standard medical practice rules, but NPs face tight restrictions.

Key requirements:

  • Standard of care: Telehealth exams can establish a patient relationship; no state law requiring in-person visits first.
  • PDMP: Mandatory check of PA PMP before prescribing opioids or benzodiazepines (initial and ongoing).
  • E-prescribing: Required for controlled substances since October 2019.

PMHNP scope: Pennsylvania requires NPs to have a collaborative agreement with at least one physician (some sources suggest two for prescriptive authority). NPs can prescribe:

  • Schedule II: up to 30-day supply
  • Schedule III–IV: up to 90-day supply

For telehealth platforms: Pennsylvania is in the IMLC (for MDs), making multi-state licensing easier for psychiatrists. NPs will need a formal collaboration arrangement.

Illinois: Full Practice for Experienced NPs, But Benzodiazepine Limits

Bottom line: Illinois allows telehealth prescribing and has a pathway for full NP practice, but with a twist on certain controlled substances.

Key requirements:

  • Standard of care: Video exam sufficient to establish a patient relationship and prescribe.
  • PDMP: Mandatory check of ILPMP before prescribing opioids (and recommended for other controlled substances).
  • E-prescribing: Required for all controlled substances as of January 2023.

PMHNP scope: Illinois allows NPs to obtain Full Practice Authority (FPA) after completing 4,000 clinical hours and additional training. However, even with FPA, Illinois NPs must enter a ‘consultation relationship’ with a physician to prescribe benzodiazepines or Schedule II opioids, and can only prescribe a 30-day supply of those medications at a time.

This is a compromise from when the FPA law was passed. For general psychiatry, it may limit an NP’s ability to independently manage patients on long-term benzodiazepines or stimulants without physician involvement.

For telehealth platforms: Illinois is in the IMLC (for MDs), and PMHNPs with FPA can operate independently for most psychiatric care. Just note the consultation requirement for benzos and Schedule II.


Psychiatrist vs. PMHNP: Scope of Practice for Controlled Substances

Psychiatrists (MD/DO)

Full independent authority in all states. Psychiatrists can diagnose, treat, and prescribe the full range of controlled substances (Schedule II–V) in every state, as long as they’re licensed there and follow DEA rules.

There are no state-specific scope-of-practice limitations on psychiatrists — your scope is defined by your training and the standard of care, not by state laws requiring collaboration or supervision.

Key takeaway: If you’re a psychiatrist, your main regulatory concerns are:

  1. Getting licensed in each state where your patients are located
  2. Following federal DEA rules (PDMP checks, e-prescribing, documentation)
  3. Adhering to state-specific telehealth and prescribing rules (like Florida’s psychiatric-only Schedule II rule)

Psychiatric Mental Health Nurse Practitioners (PMHNPs)

Authority varies dramatically by state. PMHNPs are licensed under nursing boards, not medical boards, and each state defines their scope of practice differently.

Full Practice States:

  • New York (after 3,600 hours)
  • California (transitioning to full practice by 2026)
  • Illinois (with FPA license after 4,000 hours, but consultation required for benzos/Schedule II)

In these states, experienced PMHNPs can evaluate, diagnose, and prescribe controlled substances independently (including Schedule II stimulants for ADHD).

Reduced Practice States:

  • Pennsylvania (requires collaborative agreement with physician)
  • Illinois (without FPA license)

In these states, PMHNPs can prescribe controlled substances with a formal physician collaboration agreement in place, but cannot practice independently.

Restricted Practice States:

  • Texas (requires physician supervision; cannot prescribe Schedule II except in hospitals/hospice)
  • Florida (requires collaborative agreement for all psych NPs)

In these states, PMHNPs face significant limitations. Texas is the most restrictive: a PMHNP cannot write prescriptions for Adderall, Ritalin, or any Schedule II medication for outpatient psychiatric care.

Key takeaway for PMHNPs:

  • Check your state’s scope-of-practice laws before joining a telehealth platform
  • If you’re in a restricted state, you’ll need a collaborating physician or the platform will need to provide one
  • Multi-state practice is complicated — you need a license in each state where patients are located, and each state’s scope rules apply

What Telehealth Platforms Need to Get Right (Compliance 101)

If you’re joining a telepsychiatry platform — or building your own practice — here’s what you need to ensure:

1. Licensure in Every State Where Patients Are Located

Telehealth is regulated based on where the patient is, not where you are. If you’re treating patients in California, Texas, and Florida, you need licenses in all three states.

IMLC helps: California, Texas, Pennsylvania, and Illinois are in the Interstate Medical Licensure Compact, which streamlines the process of getting licensed in multiple states. New York and Florida are not (as of 2026).

2. DEA Registration in Each State

You need a DEA registration tied to an address in each state where you’re prescribing controlled substances. Some providers maintain multiple DEA numbers (one per state).

3. PDMP Checks Before Prescribing

Every state in our priority group requires checking the PDMP before prescribing controlled substances. Frequency varies:

  • New York: Every time you prescribe Schedule II–IV
  • California: First time, then every 4 months
  • Texas: Before prescribing opioids or benzos
  • Florida: Every time for patients 16+
  • Pennsylvania: Before prescribing opioids or benzos
  • Illinois: Before prescribing opioids

Many states now participate in interstate PDMP data sharing, so you can see prescriptions from neighboring states.

4. E-Prescribing (Required in All Six States)

All six priority states require electronic prescribing for controlled substances. Paper scripts are essentially banned (with rare exceptions for technical failures or hospice care).

Make sure your platform has a DEA-compliant e-prescribing system with two-factor authentication.

5. Document Thoroughly

State medical boards and the DEA expect rigorous documentation for telehealth controlled substance prescriptions:

  • Document the patient’s history, symptoms, mental status exam, diagnosis
  • Note that you reviewed the PDMP and found no red flags (or document any concerns)
  • Document the treatment plan and follow-up schedule
  • For Schedule II prescriptions in Florida, note that it’s for a psychiatric indication

6. Follow State-Specific Telehealth Rules

  • Florida: Document psychiatric indication for Schedule II
  • Texas: Don’t use NPs for Schedule II prescriptions
  • California: Check CURES every 4 months
  • New York: Check I-STOP every time
  • Pennsylvania: Ensure NPs have collaborative agreements on file
  • Illinois: Ensure FPA NPs have physician consultation for benzos/Schedule II

7. Stay Updated on DEA Rules

The DEA’s permanent telemedicine rules could be finalized anytime in 2026. When they are, you may need to:

  • Apply for a Special Telemedicine Registration
  • Require an in-person visit for certain patients after 6 months (e.g., buprenorphine)
  • Submit annual reports on telehealth prescribing activity

Subscribe to DEA updates or work with a compliance consultant to stay ahead of changes.


The Economics: Why Telehealth Platforms Make Sense for Psychiatrists and PMHNPs

Let’s talk business.

If you’re building a solo practice, acquiring qualified psychiatric patients is expensive and time-consuming. Here’s the reality:

DIY Marketing Costs:

  • SEO: Takes 6–12 months of consistent investment ($2,000–5,000/month for content, technical SEO, and link building) before you see meaningful patient flow.
  • Google Ads: Mental health keywords cost $15–40+ per click. Most clicks don’t convert. Realistic cost per booked patient: $200–400+ when you factor in ad spend, testing, optimization, and no-show rates.
  • Directory Listings: Psychology Today and Zocdoc charge monthly subscription fees, and you’re competing with hundreds of other providers on the same page. Zocdoc charges per booking ($35–100+), but total monthly cost including subscription adds up.
  • Hidden Costs: Agency/consultant fees, staff time to handle and qualify leads, months of trial-and-error, failed campaigns.

Total DIY patient acquisition cost: $3,000–5,000/month with uncertain results for the first 6–12 months.

Platforms like Klarity Health offer a different model:

  • Pay-per-appointment: You pay a standard listing fee per new patient lead, not upfront marketing spend.
  • Pre-qualified patients: Patients are already matched to your specialty, availability, and insurance/cash-pay preferences.
  • No wasted ad spend: You only pay when a qualified patient books with you — guaranteed ROI instead of gambling on marketing channels.
  • Built-in infrastructure: No separate telehealth platform costs, no credentialing headaches, no billing staff.
  • Insurance and cash-pay: Access to both patient populations.
  • You control your schedule: Only pay when you see patients. No monthly minimums.

The business case: Instead of spending $3,000–5,000/month on marketing with uncertain results, you pay only when a qualified patient books with you. That’s guaranteed ROI vs. gambling on whether your SEO strategy will work or your Google Ads will convert.

For psychiatrists and PMHNPs who want to focus on clinical care (not marketing), platforms that handle patient acquisition remove the financial risk entirely. You get the patient volume you need to build a full practice, without the upfront investment or expertise required for DIY marketing.


FAQs: Telehealth Controlled Substance Prescribing in 2026

Can I prescribe Adderall via telehealth to a patient I’ve never met in person?

Yes, under the current federal extension through December 31, 2026. After a proper video evaluation, you can prescribe Schedule II stimulants like Adderall for ADHD without a prior in-person visit. However:

  • In Texas, only psychiatrists (MDs/DOs) can prescribe Schedule II for outpatients — PMHNPs cannot.
  • In Florida, you must document that it’s for psychiatric treatment (which ADHD is).
  • State PDMP checks and e-prescribing are required.

Once the DEA’s permanent rules are finalized, psychiatrists will likely need a Special Telemedicine Registration to continue this practice, or will need to see patients in person within a certain timeframe.

What about audio-only visits (telephone)? Can I prescribe controlled substances after a phone call?

Generally, no — with one exception.

Federal guidance during COVID allowed audio-only visits for buprenorphine (for opioid use disorder) to improve access to addiction treatment. The DEA’s proposed rules would continue to allow audio-only for buprenorphine for up to 6 months before requiring an in-person visit.

For other controlled substances (stimulants, benzodiazepines, etc.), best practice is to use interactive audio-video (video call) for the initial evaluation. Audio-only phone visits don’t meet the standard of care for new patients and controlled substance prescribing, and may not satisfy state telemedicine laws.

Do I need a DEA registration in every state where my patients are located?

Yes. If you’re prescribing controlled substances to patients in multiple states, you need a DEA registration tied to an address in each state. Many telehealth psychiatrists maintain multiple DEA numbers (one per state where they’re licensed and treating patients).

What’s the difference between a psychiatrist and a PMHNP when it comes to telehealth prescribing?

Psychiatrists (MD/DO): Full independent prescribing authority in all states. No supervision or collaboration required. Can prescribe all controlled substances (Schedule II–V) as long as licensed in the state and following DEA rules.

PMHNPs: Authority varies by state.

  • Full practice states (NY, CA by 2026, IL with FPA): Can prescribe independently, including controlled substances.
  • Reduced practice states (PA, IL without FPA): Need a collaborative agreement with a physician.
  • Restricted practice states (TX, FL): Must have physician supervision; in Texas, cannot prescribe Schedule II for outpatients at all.

What happens when the DEA’s temporary extension expires at the end of 2026?

The DEA is expected to finalize permanent rules before then. Based on the proposed rules, psychiatrists will likely be able to apply for a Special Telemedicine Registration to continue prescribing controlled substances (including Schedule II) via telehealth without in-person visits. Providers not eligible for the special registration may need to conduct an in-person evaluation before prescribing, or refer patients for one.

For buprenorphine, the proposed rule allows 6 months of treatment via telehealth before requiring an in-person visit.

What if a patient moves to a different state after I start treating them?

You must be licensed in the state where the patient is physically located at the time of the telehealth visit. If a patient moves from California to Texas, you need a Texas license to continue treating them (and a Texas DEA registration to prescribe controlled substances).

Some providers use the IMLC to quickly add state licenses as their patient panel expands.

Can I use out-of-state telehealth registrations instead of full state licenses?

It depends on the state. Florida allows out-of-state providers to register as ‘telehealth providers’ without obtaining a full Florida license, but you’re still bound by Florida’s prescribing rules (including the psychiatric-only exception for Schedule II).

Most other states require full licensure. There is no federal ‘telehealth license’ — you must be licensed in each state where patients are located.

Do I need malpractice insurance that covers telehealth and multiple states?

Yes. Make sure your malpractice policy explicitly covers:

  • Telehealth/telemedicine services
  • All states where you’re licensed and treating patients
  • Prescribing controlled substances via telehealth

Some insurers have separate riders or endorsements for telehealth. Verify coverage before joining a multi-state platform.


The Bottom Line: Opportunity with Guardrails

Telepsychiatry has permanently changed the mental health landscape. The COVID-era flexibilities proved that remote care works — patients get better access, providers can see more people, and outcomes are comparable to in-person treatment.

But as the temporary waivers expire and permanent rules take shape, psychiatrists and PMHNPs need to navigate a complex regulatory environment:

Federal law (DEA):

  • Controlled substance prescribing is currently allowed via telehealth through December 31, 2026
  • Permanent rules coming in 2026 will likely require a Special Telemedicine Registration for ongoing controlled substance prescribing (psychiatrists eligible for Schedule II)
  • Buprenorphine for OUD will be allowed for 6 months via telehealth (including audio-only) before requiring in-person visit

State laws:

  • Every state has different telehealth rules, PDMP requirements, e-prescribing mandates, and scope-of-practice laws
  • Psychiatrists have full authority in all states (with proper licensure)
  • PMHNPs face varying levels of restriction depending on the state (full practice vs. reduced practice vs. restricted practice)
  • Some states (like Florida) have specific carve-outs for psychiatric prescribing; others (like Texas) heavily restrict NP prescribing of Schedule II

Compliance essentials:

  • Licensure in every state where patients are located
  • DEA registration in each state
  • PDMP checks before prescribing (frequency varies by state)
  • E-prescribing (required in all priority states)
  • Thorough documentation of evaluations and treatment plans
  • Stay updated on DEA rule changes (subscribe to federal updates)

The opportunity:

  • Telepsychiatry platforms like Klarity Health remove the patient acquisition risk by providing pre-qualified, matched patients on a pay-per-appointment basis
  • No upfront marketing spend, no wasted ad dollars, no months of waiting for SEO to work
  • Built-in infrastructure (telehealth platform, credentialing, billing support)
  • Control your schedule and only pay when you see patients

For psychiatrists and PMHNPs who want to build a thriving practice without the financial gamble of DIY marketing, joining a telehealth platform that handles patient acquisition is the smart economic choice — especially in an evolving regulatory environment where compliance and documentation are more important than ever.

Ready to explore a smarter way to grow your psychiatric practice? Klarity Health connects psychiatrists and PMHNPs with patients who need your expertise — no marketing budget required, just clinical excellence. Learn more about joining our provider network.


References

  1. HHS Press Release: ‘HHS & DEA Extend Telemedicine Flexibilities for Prescribing Controlled Medications Through 2026’ – www.hhs.gov, January 2, 2026

  2. DEA Press Release: ‘DEA Announces Three New Telemedicine Rules to Continue Open Access to Care’ – www.dea.gov, January 16, 2025

  3. Florida Statutes §456.47: Use of telehealth to provide services – www.leg.state.fl.us, 2025 edition

  4. Akerman LLP: ‘Harmonizing Federal and Florida Laws on Prescribing Controlled Substances Through Telehealth’ – www.akerman.com, March 2023

  5. Texas Medical Board: Prescriptive Authority FAQs – www.tmb.texas.gov, Updated 2024

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All professional services are provided by independent private practices via the Klarity technology platform. Klarity Health, Inc. does not provide medical services.
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