Prepared by
Joe Nalley
show your work.

Continuum
Pilot Plan

Virtual SUD/OUD Treatment · 90-Day Employer Pilot
Pilot plan for virtual substance use disorder and opioid use disorder treatment. Buprenorphine via permanent DEA telehealth pathway. Named navigator continuity. 42 CFR Part 2 compliant. Kentucky and Ohio operations. Fee-first model earning into risk.
joe.nalley@showyourwork.health · continuumhealth.care
Confidential · Not for distribution · June 2026joe.nalley@showyourwork.health
01
Executive Summary

Virtual MAT programs prescribe buprenorphine.
Continuum manages the episode.

Continuum is a virtual-first SUD/OUD treatment company. We deliver medication-assisted treatment via the permanent DEA telehealth prescribing pathway, assign a named navigator who stays with each member from intake through step-down, and measure outcomes against the employer's own claims baseline.

This is not a digital wellness app. This is treatment delivery. Buprenorphine induction. IOP sessions. Relapse management. Return-to-work coordination. Every touchpoint tracked, every outcome measured, every consent documented under 42 CFR Part 2.

Pilot scope

90-day measurement window. Minimum 25 referred members. Claims-verified outcomes at days 30, 60, and 90. Performance guarantees active from first member.

Target population

Employees and dependents with SUD/OUD diagnosis, injury-to-opioid pipeline referrals, EAP escalations, and self-referrals. Workers' comp coordination where injury is origin.

Expected outcomes

70%+ treatment retention at 90 days. 80%+ MAT adherence. 40%+ reduction in SUD-related ED visits. Measurable return-to-work improvement.

21.5M
Americans with substance use disorder in 2023
2.7M
Opioid use disorder specifically. 75% receive no treatment.
$9,000+
Average employer cost per untreated SUD episode annually
67%
Of opioid-dependent workers cite workplace injury as origin
All figures sourced and linked. We verify against employer claims data during pilot.01 / 13
02
Scope & Population

Who we treat, how they reach us,
and how many we need to measure.

Minimum referral volume

25 referred members over 90 days for meaningful measurement. Below that threshold, the data is anecdotal -- but we still treat every member who shows up. If volume is under 25, we extend the measurement window to 120 or 150 days rather than force a premature scorecard. Above 50, we can run subgroup analysis (injury-origin vs. non-injury, buprenorphine vs. non-MAT, IOP intensity levels). At 100+, we can model actuarial projections for full deployment.

Target population

Active SUD/OUD diagnosis

Employees or dependents with existing substance use disorder diagnosis (ICD-10 F10-F19). Currently in treatment, between episodes, or untreated.

Injury-to-opioid pipeline

Workers' comp or medical claims showing workplace injury followed by opioid prescription. The most predictable pathway to OUD in physical-labor workforces. Often invisible until dependency is established.

EAP escalations

Members whose substance use exceeds what 6 EAP sessions can address. EAP counselors identify these early but have nowhere to escalate that includes MAT, IOP, and longitudinal navigation.

Self-referral

Members who contact Continuum directly through the benefits portal or a dedicated intake line. Confidential. No employer notification. 42 CFR Part 2 protections apply.

Referral pathways

EAP warm handoff

EAP counselor identifies SUD beyond session scope. Warm transfer to Continuum intake with member consent. No gap in care. Navigator assigned within 24 hours.

HR referral

HR identifies performance issues potentially linked to substance use. Refers to Continuum as a treatment resource. Voluntary participation. No employer access to treatment records under 42 CFR Part 2.

Self-referral

Member contacts Continuum through benefits portal listing, dedicated phone line, or website. Fully confidential. Employer receives aggregate utilization data only.

Workers' comp coordination

For injury-origin OUD: coordination with workers' comp TPA. Treatment records remain Part 2 protected. Claims coordination handled by Continuum's compliance team. Separate consent required.

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03
Prerequisites from Employer

What we need from you.
It's a short list.

We are a treatment provider, not a software vendor. There is no technology integration. No API connections. No IT project. Your team provides four things and we handle the rest.
Prerequisite 1

Referral pathway agreement

Define how members reach Continuum. EAP warm handoff protocol, HR referral process, self-referral channel (benefits portal listing or dedicated line). We provide template language for each pathway. Typical setup: 1–2 weeks.

Prerequisite 2

Claims data feed

12 months of baseline BH/SUD utilization data. De-identified acceptable for baseline analysis. This is for measurement, not for treatment. We need to know your starting point to prove we moved the numbers. Standard 837/835 or TPA extract.

Prerequisite 3

Communication

Benefits portal listing for self-referral access. EAP warm handoff protocol documentation. Optional: internal benefits communication to HR/managers about the program. We provide all template materials.

Prerequisite 4

Business Associate Agreement

Standard HIPAA BAA between employer (or employer's TPA) and Continuum. We provide our template or execute yours. Required before any PHI exchange. Typical execution: 1–2 weeks with legal review.

What's not on this list
No IT integration. No SSO configuration. No data warehouse connection. No API development. No EHR interoperability project. We are a treatment provider billing through standard medical claims channels. Your IT team has zero deliverables.
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04
Our Setup Requirements

What we build before a single
member is referred.

01
Hybrid MSO structure. Continuum MSO (LLC, founder-owned): technology platform, navigators, employer contracts, billing admin. Friendly PC (physician-owned PSC/PLLC): holds AODE license, employs/contracts prescribers. Management Services Agreement (MSA) ties them together. MSO carries E&O only; PC carries clinical malpractice.
02
AODE licensure (via Friendly PC). Fastest path: partner with an existing AODE-licensed medical group in KY (~30 days to launch). Alternative: recruit physician to own PC, apply for AODE together through KY DBHDID (60–120 days). SB 227 (2022) means NPs can prescribe buprenorphine independently — no collaborating physician required. OH: OH SMBO licensure. CARF accreditation required under HB 33.
03
DEA registration. For buprenorphine prescribing via telehealth. Permanent DEA telehealth waiver (no X-waiver requirement since 2023 MATE Act). Registration through DEA Diversion Control. Each prescribing clinician requires individual DEA registration in state of practice. Clinicians employed by or contracted through the Friendly PC.
04
MSA + insurance. KY healthcare attorney drafts Management Services Agreement between MSO and PC ($10–15K). Clinical malpractice carried by the Friendly PC ($15–35K/yr for telehealth-only practice). MSO carries E&O/general liability only. Tail coverage included on PC policy. Required before first prescription.
05
42 CFR Part 2 compliance. Full compliance program built with healthcare counsel ($5–10K). Consent tracking already deployed in Supabase. Audit trail logging on all PHI tables. Re-disclosure restriction enforcement. Breach notification protocol. 42 CFR Part 2 full text.
06
Telehealth platform. HIPAA-compliant video conferencing. Zoom Healthcare or Doxy.me. BAA with platform vendor. No member software installation required. Browser-based access.
07
E-prescribing & PDMP. Electronic prescribing system for Schedule III controlled substances. Integration with state Prescription Drug Monitoring Program (PDMP) — KY KASPER and OH OARRS. PDMP check required before every buprenorphine prescription in both states.
08
Supabase infrastructure. Already deployed. 22-table schema with SECURITY DEFINER functions, RLS on all tables, audit triggers on PHI tables, SDOH fields, health equity metrics, COWS assessment tracking, state transition validation, group session management.
Every item on this list is our responsibility. The employer's only deliverables are in Section 03. We don't ask you to build anything. We show up ready to treat.
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05
Clinical Model

One navigator. One episode.
Intake through step-down.

Intake assessment

ASAM criteria assessment within 48 hours of referral. Determines level of care (outpatient, IOP, residential referral). COWS (Clinical Opiate Withdrawal Scale) for opioid-dependent members. SDOH screening at intake. 42 CFR Part 2 consent obtained and logged.

Buprenorphine induction

Virtual, physician-supervised. Member at home with telehealth connection to prescribing clinician. COWS score verified before induction (score 12+ required). First dose observed via video. Follow-up within 24 hours. PDMP checked in KY (KASPER) or OH (OARRS) before every prescription. Naloxone co-prescribed at induction per SAMHSA guidelines. Urine drug screen (UDS) at intake and random thereafter.

Named navigator assignment

Same person from intake through step-down. Licensed counselor (LCSW or LPCC). Minimum 3 touchpoints per week during IOP. Manages medication adherence tracking, session attendance, crisis response, return-to-work coordination. Not a call center. Not a rotating roster.

IOP structure

9 hours/week standard (ASAM Level 2.1): 3 group sessions (3 hrs each). 12 hours/week intensive: adds individual therapy session + medication management. Group sessions capped at 10 members. All sessions virtual with attendance tracking. Evidence-based modalities: cognitive behavioral therapy, motivational interviewing, contingency management. No proprietary curriculum. Standard clinical tools with measured outcomes.

Step-down protocol
IOP

Intensive outpatient

9–12 hrs/week. Weeks 1–8 typical. Buprenorphine stabilization. Group + individual sessions. Navigator touchpoints 3x/week minimum.

OP

Outpatient

3–5 hrs/week. Weeks 8–16 typical. Reduced group frequency. Individual therapy continues. Navigator touchpoints 2x/week. Buprenorphine dose stabilized or tapering.

MAINT

Maintenance

Monthly medication management. Monthly navigator check-in. Ongoing PDMP monitoring. Duration: 6–12 months standard. No forced taper timeline.

DC

Discharge

Planned discharge with warm handoff to community resources. 90-day post-discharge navigator check-in. Re-entry pathway documented.

Relapse protocol
Relapse does not mean discharge. It means re-escalation. Member returns to IOP intensity without re-intake. Same navigator. Same treatment record. Same 42 CFR Part 2 consent. No gap in care. No new paperwork. Relapse is a clinical event, not an administrative one. If a member requires residential or inpatient detox (ASAM Level 3+), Continuum coordinates the referral, maintains navigator contact throughout, and resumes virtual IOP upon discharge. We do not abandon members who need a higher level of care.
42 CFR Part 2 at every stage
Consent obtained at intake. Re-verified at every level-of-care transition. Re-disclosure restrictions apply to all external communications. Employer receives aggregate data only. No individual treatment records shared without member's written, time-limited consent.
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06
Timeline

Week by week. From agreement
to final scorecard.

Pre-launch (Weeks -8 to 0)
W-8
MSO/PC structure. Fastest path: identify existing AODE-licensed medical group in KY for Friendly PC partnership (~30 days to launch). Alternative: recruit physician owner, file AODE application with DBHDID (60–120 days). MSA drafting with KY healthcare attorney ($10–15K). OH SMBO application if dual-state. CARF accreditation process initiated for OH.
W-6
Clinician contracting (through Friendly PC). Prescribing psychiatrist or NP identified. DEA registration confirmed. Clinical malpractice insurance bound on PC. MSO E&O bound. 1099 or W-2 agreement executed through PC entity.
W-4
Platform setup. Telehealth platform BAA executed. E-prescribing system configured. PDMP integration tested (KASPER/OARRS). Supabase schema verified.
W-2
Employer onboarding. BAA executed. Referral pathways documented. Benefits portal listing drafted. EAP warm handoff protocol finalized. Claims baseline received.
W-1
Baseline analysis. 12-month claims data analyzed. SUD/OUD utilization mapped. ED visit baseline established. Scorecard metrics finalized with employer.
Active Pilot (Weeks 0 to 13)
W0
Launch. Referral pathway goes live. Self-referral channel active. EAP warm handoff protocol active. Navigator on standby.
W1-4
First referrals. Intake assessments begin. Buprenorphine inductions for OUD-presenting members. Navigator assignments. IOP sessions launch. Weekly utilization report to employer (aggregate only).
W4
First scorecard. Day 30 metrics: referral volume, intake completion rate, MAT initiation rate, navigator engagement frequency. Delivered to employer within 5 business days.
W5-8
Treatment engagement. IOP retention measured. Navigator continuity verified (same-navigator rate). Group session attendance tracked. Buprenorphine fill rates measured.
W8
Second scorecard. Day 60 metrics: treatment retention, MAT adherence, ED utilization (first vs. baseline comparison), navigator touchpoint frequency.
W9-12
Outcomes measurement. 90-day retention data. Return-to-work tracking. Relapse rate measurement. Cost-per-episode calculation against baseline.
D91
Final scorecard + decision. Complete outcomes report. ROI analysis against baseline. Recommendation: continue, expand, or terminate. No penalty either direction.
The pilot is the product. Either the numbers move on your claims data, against your baseline, measured by the metrics you agreed to before launch — or they don't. That's the whole conversation.
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07
Staffing

Four roles. Staged hiring.
Unit economics per member.

RoleQualificationEngagementCostPilot Scope
Prescribing Clinician Psychiatrist or NP. DEA registration. Buprenorphine experience. Employed/contracted through Friendly PC (AODE holder). Via Friendly PC $150–200/hr 4–8 hrs/week at pilot volume. Scales with member count. One clinician covers 40–60 active members. SB 227: NPs prescribe independently in KY.
Navigator LCSW or LPCC. SUD treatment experience. State-licensed in KY and/or OH. 1 W-2 to start $55–70K/yr Caseload: 15–20 active members. One navigator for pilot. Second at 20+ members.
Clinical Director Licensed psychologist or psychiatrist. Program oversight. Quality assurance. Part-time / 1099 $100–150/hr 4–6 hrs/week. Treatment plan review. Clinical supervision. Quality metrics.
Founder Oversight Joe Nalley. Employer relationship. Scorecard delivery. Compliance oversight. Direct Hands-on through pilot. Scorecard preparation. Employer communication. No delegation during proof period.
$14–16K
Monthly operating cost at pilot volume (25–50 members)
15–20
Active members per navigator. Quality ceiling, not a target.
Clinician recruitment: NPs with buprenorphine experience are the primary hiring target. Psychiatrists preferred but scarce. Backup: locum tenens agencies (Weatherby, CompHealth) with 2–4 week placement timelines. Peer recovery specialists added after 20 active episodes (P2 roadmap). 1099 contract model. Biostatistician engaged after 50 episodes for outcomes analysis.
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08
Technology Stack

Built. Deployed. Audited.
Not a roadmap.

Supabase — 22-Table Schema
continuum_profiles
continuum_members
continuum_navigators
continuum_navigator_assignments
continuum_episode_types
continuum_episodes
continuum_episode_state_transitions
continuum_touchpoint_templates (19 IOP touchpoints seeded)
continuum_touchpoints
continuum_outcomes
continuum_performance_guarantees
continuum_alerts
continuum_rx_links
continuum_audit_log
continuum_contact_submissions
continuum_consents
continuum_allowed_transitions
continuum_group_sessions
continuum_group_attendance
Security & Compliance Features
SECURITY DEFINER functions with pinned search_path. No privilege escalation vectors.
Row-Level Security on all tables. Users see only their assigned members.
Audit triggers on all PHI tables. Every read, write, update logged with timestamp and user ID.
State transition validation. Episodes can only move through valid clinical states (intake → active → step-down → maintenance → discharge). No skipping.
42 CFR Part 2 consent tracking. Every consent logged with expiration, scope, and revocation capability.
SDOH and health equity fields on member records. Not bolted on after the fact.
COWS (Clinical Opiate Withdrawal Scale) in instrument enum. Tracks withdrawal severity across induction.
Medical hold state for members requiring higher-level medical intervention.
Other platforms
Telehealth: Zoom Healthcare or Doxy.me (BAA required)
E-prescribing: DrFirst or DoseSpot (EPCS-certified for Schedule III)
PDMP: KY KASPER + OH OARRS (mandatory check before every buprenorphine Rx)
6 migrations deployed. Schema audited. Zero open security findings.08 / 13
09
Scorecard

Eight metrics. Each with a source,
a measurement method, and a target.

MetricDefinitionSourceMethodologyTarget
Treatment retention Members still engaged in treatment at measurement point. National OUD average: ~45% at 90 days. Continuum episode records Active episode status at day 30/60/90. Denominator: all members who completed intake. 70%+ at 90d
MAT adherence Buprenorphine prescription fill rate among MAT-enrolled members Rx claims + PDMP Prescriptions filled / prescriptions written. Cross-referenced with KASPER/OARRS data. 80%+
ED utilization SUD-related emergency department visits, treatment period vs. baseline Employer claims data ICD-10 F10-F19 ED claims during treatment vs. 12-month pre-pilot baseline for same members. 40%+ reduction
Return to work Members who return to active employment status during treatment Employer HR data Employment status at day 90 vs. status at intake. Employer provides aggregate confirmation. Measured
Relapse rate Return to active use requiring re-escalation to higher intensity Continuum clinical records Episode state transition to re-escalation / total active episodes. Relapse = clinical event, not discharge. <30%
Navigator engagement Touchpoints per member per week during active treatment Continuum touchpoint records Logged touchpoints (call, video, message) / active member-weeks. IOP minimum: 3/week. 3+/week (IOP)
Cost per episode Total Continuum charges per treated member over 90-day pilot Continuum billing + employer claims All Continuum charges per member compared against employer's 12-month pre-pilot SUD spend per episode (ED, inpatient, pharmacy, outpatient BH claims). Below baseline
Same-navigator rate Members who had the same navigator from intake through measurement point Continuum assignment records Members with zero navigator reassignment / total active members. 95%+
Day 30 Scorecard
Referral volume, intake completion, MAT initiation rate, navigator assignment rate. Leading indicators only. Treatment retention begins to measure.
Day 60 Scorecard
All 8 metrics measured. First ED utilization comparison. Retention and adherence trends. Navigator engagement frequency verified.
Day 91 — Decision Document
Full scorecard. Claims-verified ROI. Cost-per-episode analysis. Recommendation with data. The employer decides with the scorecard in hand, not a sales pitch.
Metrics are agreed before launch. We don't choose which numbers to show after we see the results.09 / 13
10
Economics

What the pilot costs. What we cost to run.
What the employer should expect back.

Fee-first model
ComponentRateBasis
Per-patient per-month$750–950During active treatment
Maintenance phase$200–350Monthly after step-down
Setup / implementation$0No setup fee
Termination fee$0Walk away anytime
Our cost to run (per month, pilot volume)
ItemMonthly
Prescribing clinician (6 hrs/wk @ $175/hr avg)$4,200
Navigator (1 W-2 LCSW)$5,000
Clinical director (5 hrs/wk @ $125/hr avg)$2,500
Telehealth platform$300
E-prescribing + PDMP$200
Malpractice insurance (prorated)$2,100
Supabase infrastructure$25
Total monthly operating cost$14,325
Expected ROI for employer

ED diversion savings

Average SUD-related ED visit: $3,500–$5,200. At 40% reduction for treated population, savings of $1,400–$2,080 per member per year in ED costs alone. For 50 treated members: $70K–$104K annually.

CDC WONDER / HCUP-AHRQ 2023

Workers' comp reduction

Opioid-involved workers' comp claims cost 7x more than non-opioid claims. Median: $67,622 vs. $9,643. Early MAT intervention reduces claim duration and total cost.

NCCI Workers' Compensation Statistical Plan 2023

Productivity gains

Employees with untreated SUD miss 14.8 additional work days per year. At median wage, that represents $3,500–$6,000 per employee in lost productivity annually. Treatment reduces absenteeism by 40–60%.

SAMHSA NSDUH 2023 / JOEM
Year 2: Earning into risk
After pilot proof, Year 2 introduces performance guarantees tied to scorecard metrics. If we miss agreed targets, PEPM decreases. If we exceed them, gain-sharing activates. The employer pays for results only after seeing them verified in the pilot.
All economics verified against employer claims data during pilot. We don't model in a vacuum.10 / 13
11
Escalation to Full Contract

What happens after the scorecard
says yes.

Decision point: Day 91

Employer reviews final scorecard. All 8 metrics measured against agreed targets. ROI analysis delivered. Three options: continue at pilot terms, expand to full contract, or terminate with no penalty. The scorecard is the decision document.

Full contract terms

12-month initial term with annual renewal. PEPM at pilot rates (or better, at volume). Performance guarantees formalized: retention, adherence, and ED utilization targets with PEPM adjustment if missed. Gain-sharing on ED savings above baseline.

Population expansion

Pilot proves on a defined segment. Full contract expands to all eligible members. Additional referral pathways opened. Workers' comp coordination formalized. Second navigator hired at 20+ active members. OH operations added if KY-only pilot.

Risk-sharing structure (Year 2+)

After 12 months of claims-verified outcomes: shared savings model. Continuum shares in verified ED diversion and claims reduction above baseline. Performance guarantees tighten. PEPM adjusts based on demonstrated outcomes. Capital reserved against guarantees.

Reporting cadence

Monthly utilization report (aggregate). Quarterly scorecard with all 8 metrics. Annual claims-verified outcomes analysis. All reports delivered within 10 business days of period close. No self-reported outcomes. Everything verified against claims.

Termination rights

90-day notice for either party. No termination fee. Active members transitioned to alternative treatment with warm handoff. Treatment records provided to member (not employer) per 42 CFR Part 2. Navigator continuity maintained through transition period.

If the pilot doesn't work, you walk away with better data than you started with. If it does work, the full contract is a formality. The proof already happened.
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12
Legal & Compliance

Every regulation cited. Every requirement
mapped to our compliance protocol.

42 CFR Part 2 — SUD Confidentiality

Consent requirements: Written consent required for any disclosure of SUD treatment records. Consent must specify: who may disclose, who receives, purpose, extent of information, expiration date, right to revoke. Separate consent for each recipient.

Re-disclosure restrictions: Every disclosure must include: "This information has been disclosed to you from records protected by federal confidentiality rules (42 CFR Part 2). The federal rules prohibit you from making any further disclosure of this information unless further disclosure is expressly permitted by the written consent of the person to whom it pertains."

Medical emergency exception: Part 2 permits disclosure without consent when a member's life is in immediate danger. Limited to information necessary to address the emergency. Documented in audit log within 72 hours.

2024 final rule: HHS aligned Part 2 with HIPAA for treatment, payment, and healthcare operations disclosures (effective Feb 2024). Consent still required for initial disclosure. Re-disclosure notice still mandatory. Our consent flow already reflects the updated rule.

Audit requirements: Audit trail on all PHI access. Breach notification within 60 days. Annual compliance review. Already built into Supabase schema.

42 CFR Part 2 → ecfr.gov/current/title-42/chapter-I/subchapter-A/part-2

DEA Telehealth Prescribing

DEA finalized permanent telehealth prescribing rules for Schedule III–V substances (2024). Buprenorphine (Schedule III) prescribable via telehealth without in-person visit. X-waiver eliminated by MATE Act (2023). Prescribers must complete 8-hour training (MATE Act requirement) for DEA registration or renewal. DEA registration required in each state of practice. Prescribing clinician must hold active medical license in the state where the member is physically located at time of visit. Electronic prescribing for controlled substances (EPCS) compliant system required.

DEA Diversion Control → deadiversion.usdoj.gov

State Licensure — KY vs. OH
Dimension
Kentucky
Ohio
License type
AODE (Alcohol & Other Drug Entity) — held by Friendly PC
SMBO (State Medical Board of Ohio)
Regulatory body
Structure
Hybrid MSO/PC. MSO (Continuum LLC) + Friendly PC (physician-owned). MSA ties them.
No CPOM restriction (2012 SMBO)
CARF required
No
Yes (HB 33)
NP supervision
Eliminated (SB 227). NPs prescribe independently.
Standard collaboration agreement
Insurance
PC carries clinical malpractice. MSO carries E&O only.
Same split applies
Fastest path
Partner with existing AODE group (~30 days)
90 days + CARF
Alternative path
Recruit physician, apply for AODE together (60–120 days)
Month 6–9
HIPAA / BAA
Standard HIPAA compliance. BAAs required with: employer (or employer TPA), telehealth platform vendor, e-prescribing vendor, cloud infrastructure (Supabase). All BAAs executed before any PHI exchange.
Workers' Comp Coordination
For injury-origin OUD: coordination with workers' comp TPA requires separate 42 CFR Part 2 consent. Treatment records remain Part 2 protected regardless of injury origin. Workers' comp carriers often need treatment status for claims adjudication -- Part 2 consent must specifically name the comp carrier, the information disclosed (treatment status and dates only, not clinical details), and the expiration. Claims coordination handled by Continuum compliance team. KY KRS 342 and OH RC Chapter 4123 workers' comp reporting requirements observed alongside Part 2 protections.
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