LTCP Training Update: State-specific content?

October 28, 2009 at 08:00 PM

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America's Health Insurance Plans' new ongoing training course is now available. As most LTCI agents know, after you have completed the initial LTCI training, you have to take ongoing training every two years. And AHIP provides the training you need. Our four-hour ongoing course has been approved by 23 states so far. It now available on our website (www.ltcpartnershipsonline.com), and classroom training is being conducted.

All state-approved ongoing courses cover the required topics. But AHIP's course not only provides a comprehensive discussion of LTCI and LTC partnerships, it tells you what you need to know to remain ahead of the curve — we give you the latest information on new LTCI product features and designs, market trends, long-term care costs and regulatory developments. For those who want not just the basics, but a competitive edge, this is the course.

In this month's article, we discuss how agents can fulfill the ongoing training requirements of multiple states. And as always, we provide updated information on the training requirements and regulatory developments in all 50 states. We draw your attention in particular to changes in Iowa, Vermont and Wyoming.

Ongoing training — state-specific content?

As those in the field know, almost all the states that have established long-term care partnerships in recent years have adopted the model of the National Association of Insurance Commissioners (NAIC) for producer training. But many of these states modify this model somewhat by requiring training in state-specific content (the Medicaid and partnership rules particular to the state and sometimes the state's LTCI regulations). This has meant that while an agent can fulfill the initial training requirement of about half the states by taking only an NAIC model course, for the other half he or she must take another hour or two of state-specific training.

What about the ongoing training — the four-hour course that producers must take every two years after completing the initial training? Can agents take one course and meet the requirements of all states? Or must they take state-specific content for some states, as they do for the initial training?

Good news! Very few states are requiring state-specific content for the ongoing training. And even for those states, nonresident agents may not have to take it. So an agent who takes a four-hour NAIC model course for one state meets the requirements of almost all other states.

The exceptions:

Colorado requires five hours of ongoing training, including state-specific content. But nonresidents may to able to qualify with a four-hour NAIC course by means of reciprocity (see Colorado entry below).
Minnesota requires state-specific content.
South Carolina requires a short state supplement.
Washington requires state-specific content, but both residents and nonresidents can use a course taken for another state, such as a four-hour NAIC course, to qualify. (However, they will not receive CE credit — see Washington entry.)
Wisconsin requires the same two hours of state content as for the initial course.

The bottom line — meeting the ongoing training requirements of multiple states is much easier than for the initial training. By taking one four-hour NAIC course, you can qualify in almost all states. And if you need to take state content in addition to the NAIC course, you can do so through AHIP.

Training deadlines
A reminder of upcoming deadlines:

Dec. 31, 2009–Alabama*
March 31, 2010–Vermont (new agents only)
July 1, 2010–Kansas, West Virginia*, and Wyoming

* The deadline was for existing LTCI agents; new agents in these states had to complete the initial training before selling policies. For details, see state reports below.

State reports

Note: California, Connecticut, Indiana and New York have had long-term care partnership programs in operation for several years and are often referred to as the "original partnership" states. These programs are in many ways different from the new partnerships currently being established in other states in response to the federal Deficit Reduction Act (DRA) of 2005. Their training requirements do not follow the NAIC model created to implement the DRA and adopted by most new partnership states. Therefore, agents who take training based on the NAIC model will not meet the requirements of the four original states, and those who take partnership training in one of the original states will not meet the requirements of the new states. (However, a few new partnership states may accept the training of an original partnership state — when in doubt, check with the new state.)

Check with your carrier!

We would like to remind agents that some states do not review and approve courses as meeting their LTCI/LTC partnership training requirements. In these states, it is up to the carrier to decide whether a course fulfills the state requirements. And in all states, carriers must track agents' completion of the required training. So in seeking to meet state training requirements, always check with the carrier or carriers you represent.

Alabama. All LTCI agents must complete an eight-hour initial training course. The course must be based on the NAIC model (no state-specific content required) and approved by the state for long-term care CE credits. Courses approved for general CE do not fulfill this requirement, even if they address long-term care and have "long-term care" in the title. (AHIP's course is approved for LTC and fulfills the requirement.) Agents already licensed for LTCI before March 1, 2009, have until Dec. 31, 2009, to complete the initial training; new agents (those not already licensed before March 1, 2009) must complete the initial training before selling LTCI.

Agents are also required to complete four hours of ongoing training for every 24-month license renewal period beginning in 2010. This means that during the first renewal period an agent may have to take both the initial and the ongoing training (12 hours total). For example: Beth renewed her license in May (her birth month) of 2008 and must renew it again in May 2010. She must complete the initial training by Dec. 31, 2009, and she must complete the ongoing training by May 2010, for a total of 12 hours this renewal period. But when she renews in May 2012, she will have to take only a four-hour ongoing course.

Alaska. No action to establish an LTC partnership has been reported. To sell LTCI, an agent must be licensed to sell health insurance — there are no training requirements specific to LTCI.

Arizona. As of June 30, 2009, all LTCI producers must complete eight hours of initial training based on the NAIC model before selling LTCI. Producers must also complete four hours of ongoing training during each 24-month period beginning July 1, 2009, after the 24-month period in which they completed the initial training.

Arkansas. As of July 1, 2009, all LTCI agents must complete eight hours of initial training before selling LTCI. The content of this training is based on the NAIC model plus a state-issued supplement on the Arkansas partnership and Medicaid programs. Agents must also complete four hours of ongoing training during every 24-month license renewal period after the period in which they completed the initial training.

California is one of the original partnership states (see note above). Before selling partnership policies, agents must complete eight hours of general long-term care training and eight hours of training specific to the California LTC partnership. The partnership-specific training must be received in a classroom setting. In addition, eight hours of ongoing classroom partnership training must be taken during every two-year license approval period.

Colorado. All resident LTCI agents must complete 16 hours of initial training before selling LTCI. This training must include the topics of the NAIC model plus substantial additional content, as stipulated by the state. Eight hours must cover long-term care and long-term care insurance and can be classroom, self-study, or Internet-based; the other eight hours must focus on partnership and must be classroom training. Agents must also complete five hours of ongoing training (classroom only), including state-specific content, during every 24-month CE period after the period in which they completed the initial training.

Nonresident agents can sell LTCI (including partnership policies) in Colorado without fulfilling the above requirements (for both initial and ongoing training) if all of the following conditions are met:

Their home state has an LTC partnership.
They meet their home state's training requirements for partnership policies (even if the state requires less than 16 hours or its rules otherwise differ from Colorado's).
They hold a Colorado nonresident license for life insurance or accident and health insurance.

If a nonresident agent's home state does not have a partnership, the agent must fulfill Colorado's requirements, even if she meets the home state's requirements for nonpartnership LTCI. If the home state has a partnership but the agent meets the training requirements only for nonpartnership LTCI policies, she must fulfill Colorado's requirements.

Connecticut is one of the original partnership states (see note above). To sell partnership policies, an agent must complete first a prerequisite online course approved by the partnership program and then four hours of classroom instruction conducted by partnership program staff.

Delaware. No action to establish an LTC partnership has been reported. To sell LTCI, an agent must meet the training requirements for a health insurance license and also, every two years, complete a three-hour course in LTCI approved by the state.

District of Columbia. No action to establish an LTC partnership or new LTCI training requirements has been reported. Currently there are no training requirements specific to LTCI — an agent must simply be licensed to sell life and health insurance.

Florida. At present, all LTCI agents must complete eight hours of initial training based on the NAIC model before selling LTCI policies. Agents must also complete four hours of ongoing training every 24 months, beginning on the date they completed the initial training. In addition, the state is currently developing a rule under which agents will have to complete two hours of Florida-specific training (on the state's Medicaid and partnership programs and its regulations), either as part of the initial eight-hour training or in addition to it. (This rule is expected to be finalized soon, but it is not yet in effect.)

Georgia. Agents intending to sell partnership policies (not all LTCI agents) must complete initial training before selling. The initial training consists of the NAIC model plus two hours of state-specific content, for a total of eight hours. Georgia resident agents who have already taken the training required to sell partnership policies in another state may receive up to six hours credit for that training and need to take only the two hours of Georgia-specific training. Nonresident agents who are qualified to sell partnership policies in their home state need to take only the Georgia-specific training.

Agents selling partnership policies must also take four hours of ongoing training during every two-year license renewal period, which runs from Jan.1 to Jan. 1. The first ongoing training must be completed by the second Jan. 1 after completion of the initial training. To give some examples: Mary Jones completed the initial training on Oct. 14, 2008; she has until Jan. 1, 2010, to complete the first ongoing training. Bob Smith completes the initial training on Feb. 6, 2009; he has until Jan. 1, 2011.

Hawaii. In 2007, the legislature passed a bill requiring all LTCI agents to complete eight hours of training based on the NAIC model. But this requirement will not go into effect until the state's partnership program is established, and it is unclear when that might happen — a partnership bill failed to pass in the 2008 and 2009 legislative sessions but may be reintroduced in 2010. The bottom line for agents: There are no partnership training requirements in effect at this time; there will be no such requirements until the partnership is established; and when that occurs, agents will have one year from that date to complete the training.

Idaho. All LTCI agents must complete eight hours of initial training based on the NAIC model before selling LTCI products. They must also take four hours of ongoing training during every 24-month license renewal period after the period in which they completed the initial training.

Illinois. As of July 1, 2009, all LTCI agents must complete course 25008. To be approved by the state as 25008, a course must cover the NAIC content and provide at least eight hours of instruction. (AHIP's NAIC Model Course is approved.) Agents must also complete four CE credits in long-term care during each 24-month license renewal period after the period in which they completed the initial training.

Indiana is one of the original partnership states (see note above). To sell LTCI, agents must take eight hours of initial training and five hours of ongoing training every two years. To sell partnership policies, agents must also take seven hours of partnership training (classroom only). Agents licensed in another state are exempt from the general LTCI requirement, but to sell partnership policies they must receive the seven hours of Indiana partnership training.

Iowa. At present, LTCI agents must complete four hours of initial training based on the NAIC model (not the usual eight hours) and three hours of ongoing training during every three-year CE term. But the state has proposed a new training rule that is intended to become effective on Nov. 25, 2009. Under this rule, by Jan. 1, 2010, all LTCI agents will have to complete an eight-hour initial training course covering the NAIC model and content specific to Iowa's partnership and Medicaid programs. However, agents who have already taken the previously required four-hour course can fulfill the new requirement by completing an additional four-hour course focusing on LTC partnerships and the Iowa Medicaid program. The proposed rule states that the initial training should be in a classroom setting but allows that some self-study or online courses may be approved. Finally, under the new rule four hours of ongoing training (not three as previously required) must be completed during every three-year CE term. We emphasize that this rule is proposed but not final.

Kansas. Effective July 1, 2010, agents selling partnership policies (not all LTCI agents) must complete four hours of initial training. Partnership agents must also take one hour of ongoing training during every two-year license renewal period after the period in which they completed the initial training. In both cases, courses must be certified for partnership training by the Commissioner of Insurance.

Kentucky. The state's LTC partnership and related regulations are now in effect, and partnership policies are beginning to be approved and will be available soon. Agents intending to sell partnership policies (not all LTCI agents) must complete eight hours of initial training before selling. This initial training must cover the topics of the NAIC model as well as certain Kentucky-specific content stipulated by the state. Agents selling partnership products must also take four hours of ongoing training during each 24-month license renewal period after the period in which they completed the initial training. Note that although the state requires only agents selling partnership policies to receive this training, it is expected that many carriers will require all agents to take it. Nonresident agents who meet the partnership training requirements of their home state will not be required to meet Kentucky's requirements.

Louisiana plans very soon to submit to the federal government a state plan amendment (SPA) seeking authorization to establish an LTC partnership. Presently, there are no training requirements specific to long-term care insurance; to sell LTCI, agents must be licensed to sell accident and health insurance. However, the state is currently considering new LTCI requirements, expected to become effective in 2010. As these are developed, we will keep you informed.

Maine. All LTCI agents must complete eight hours of initial training based on the NAIC model before selling LTCI. An agent must also take four hours of ongoing training during every 24-month period beginning on the date he or she completed the initial training. The state recently submitted to the federal government a state plan amendment (SPA) seeking authorization to establish an LTC partnership, but this will not affect the training requirement.

Maryland. All LTCI agents must complete eight hours of initial training based on the NAIC model before selling LTCI. An agent must also take four hours of ongoing training during every 24-month period beginning on the date he or she completed the initial training.

Massachusetts. No action to establish an LTC partnership or new LTCI training requirements has been reported. The state does not currently have training requirements specific to LTCI; the only requirement is that LTCI agents be licensed to sell accident and sickness insurance and meet continuing education requirements for accident and sickness. However, carriers are required to provide agents selling LTCI with training in the product.

Michigan. The federal Centers for Medicare and Medicaid Services (CMS) and the state are discussing issues involving Medicaid estate recovery, and this matter must be resolved before Michigan's partnership program can be approved and related training requirements issued. Progress continues to be made, but final resolution has not yet been reached.

Minnesota requires resident agents to take a state-specific course before selling LTCI. It is eight hours and is based on the NAIC model, but state-specific information must be incorporated into the course (unlike in other states, where it can be added as a supplement). Nonresident agents can qualify to sell LTCI by taking an eight-hour NAIC model course in another state plus Minnesota-specific content. Agents must also take four hours of ongoing training (including state-specific content) every 24 months, beginning on the date the agent completed the initial training.

Mississippi. No action to establish an LTC partnership or new LTCI training requirements has been reported. Currently there are no training requirements specific to LTCI — an agent must simply be licensed to sell life, accident and health insurance.

Missouri. Before selling partnership policies, agents must complete eight hours of initial training based on the NAIC model. (State-specific content is not required, although the state strongly recommends that agents familiarize themselves with Missouri's Medicaid and partnership programs, and AHIP's course includes material on this.) Agents must also take four hours of ongoing training during every 24-month license renewal/CE period after the period in which they completed the initial training. (These requirements do not apply to LTCI agents not selling partnership products.)

Montana. All LTCI agents must take eight hours of initial training based on the NAIC model before selling LTCI. Agents must also complete four hours of ongoing training every 24 months beginning July 1, 2008.

Nebraska. All LTCI agents must complete eight hours of initial training before selling LTCI. This initial training consists of the NAIC model plus state-specific information. Agents must also take four hours of ongoing training during every 24-month license renewal period after the period in which they completed the initial training.

Nevada. The state has not and does not plan to issue specific partnership training requirements, such as minimum hours, topics to be covered, or deadlines, and it does not approve courses. Rather, the state requires insurers to certify that agents selling partnership policies meet the training standard of the federal Deficit Reduction Act (DRA) — that is, that they have "received training and demonstrated evidence of an understanding of the partnership policies and their relationship to public and private coverage of long-term care." It is up to insurers to decide whether a course meets this standard, and consequently Nevada agents should consult with the carriers they represent and fulfill the training requirements of those companies.

New Hampshire has received federal approval of its LTC partnership program, and related state rules have been drafted and are now in the public comment period, with final approval expected in December 2009. These include proposed (but not final) training requirements under which producers selling partnership policies (not all LTCI producers) would have to complete eight hours of initial training based on the NAIC model before beginning to sell. Partnership producers would also have to take four hours of ongoing training every two years. We emphasize that these requirements are not yet final and subject to change.

New Jersey. As of July 1, 2009, all LTCI agents must complete eight hours of initial training based on the NAIC model. Agents must also take four hours of ongoing training every 24 months. (The exact timeframe for the ongoing training is not specified by the state; insurers, who are responsible for ensuring agent compliance with the requirements, may use their own discretion.)

New Mexico has begun initial discussions on the establishment of an LTC partnership. Currently no special training is required to sell LTCI, only a health insurance license.

New York is one of the original partnership states (see note above). To sell partnership policies, agents must complete eight hours of training, consisting of a four-hour online course followed by four hours of classroom instruction.

North Carolina. The state Department of Health and Human Services has developed a proposal for an LTC partnership and submitted it to the legislature for approval. Presently, to sell LTCI an agent must have a license for health, accident, and sickness insurance and also a special Medicare supplement/long-term care (MS/LTC) license, which requires 10 hours of training in these products and a state examination. When and if a partnership is established, the state will make a decision about adopting the NAIC training model for LTCI (eight hours of initial training and four hours of ongoing training every 24 months).

North Dakota. Before selling partnership policies, agents must complete eight hours of initial training based on the NAIC model. Partnership agents must also take four hours of ongoing training every 24 months beginning July 1, 2008. These requirements do not apply to LTCI agents selling only non-partnership products.

Ohio. All LTCI agents must complete eight hours of initial training before selling LTCI. The content of the training is the NAIC model plus state-specific information. (Nonresident agents must have eight hours of training based on the NAIC model, but they are not required to have the state-specific content.) Agents must also take four hours of ongoing training during every 24-month CE compliance period after the period in which they completed the initial training.

Oklahoma. As of July 14, 2009, all LTCI agents must complete eight hours of initial training based on the NAIC model. In addition, four hours of ongoing training are required during every 24-month license renewal period after the period in which the agent completed the initial training. Courses approved by the Oklahoma Insurance Department as meeting the initial or ongoing training requirements also qualify for CE credit.

Oregon. All LTCI agents must complete eight hours of initial training based on the NAIC model before selling LTCI. Agents must also complete four hours of ongoing training during every 24-month period beginning the date they completed the initial training.

Pennsylvania. In 2007, the state established partnership training requirements, which have been in effect since. Then in 2008, the state proposed a new rule with additional requirements. This proposed rule is currently going through the regulatory review and approval process and is expected to be finalized sometime this year. In the meantime, the 2007 requirements remain in effect.

Rule in effect: Producers intending to sell partnership policies (not all LTCI producers) must, before selling, complete a one-hour course on the Pennsylvania Medicaid program based on state-issued content. This requirement will continue to apply after the new proposed rule goes into effect.

Proposed rule: All LTCI producers (not just those selling partnership policies) will have to complete eight hours of initial training based on the NAIC model. (These eight hours may include the one-hour state-specific course cited above or be taken in addition to it.) Producers will be given time to fulfill this new requirement after it becomes effective, but a deadline has not been set. In addition, all LTCI producers will have to complete four hours of ongoing training during every 24-month licensing cycle after the cycle in which they complete the initial training.

Rhode Island. All LTCI agents must complete eight hours of initial training based on the NAIC model before selling LTCI. An agent must also take four hours of ongoing training during every 24-month period beginning the date he or she completed the initial training.

South Carolina. As of July 1, 2009, all LTCI agents must complete eight hours of initial training. This training is based on the NAIC model plus information on South Carolina's Medicaid and partnership programs. An agent must also take four hours of ongoing training (including state-specific content) during every 24-month period beginning the date he or she completed the initial training.

South Dakota. All LTCI agents must complete eight hours of initial training before selling LTCI. This training is based on the NAIC model plus state-specific information. Agents must also take four hours of ongoing training every 24 months beginning July 1, 2008.

Tennessee. As of July 1, 2009, all resident LTCI agents must complete eight hours of initial training based on the NAIC model. Most resident agents must take an initial training course that includes information on Tennessee's Medicaid and partnership programs. However, resident agents who took an eight-hour NAIC model course for another state before July 1, 2008, may use that course to meet the initial training requirement. (This exception is allowed so that Tennessee agents who took partnership training in another state before Tennessee established its partnership do not have to take the training again.)

Nonresident agents whose home state has a partnership can qualify in Tennessee by meeting the partnership training requirements of their home state. Nonresident agents from a nonpartnership state can qualify by taking an eight-hour NAIC model course, in Tennessee or another state.

Agents must also take four hours of ongoing training during every 24-month license renewal period after the period in which they completed the initial training. Agents exempt from general continuing education requirements (those who have been licensed continuously since Jan. 1, 1994) must take the initial training but are not required by the state to take the ongoing training (although carriers may require them to do so).

Texas. Partnership agents — that is, those intending to perform any of the acts of an agent in relation to long-term care partnership (LTC-P) insurance policies (not all LTCI agents) — must complete eight hours of initial training before selling. The content of this training is the NAIC model plus information on Texas Medicaid eligibility and asset disregard under the Texas partnership. Partnership agents also have to complete four hours of ongoing training during every 24-month licensing renewal period after the period in which they completed the initial training. These requirements are not "grandfathered"–that is, no agent is exempt because he or she was already licensed for LTCI when the requirements were established.

Utah. Legislative action to establish an LTC partnership and new LTCI training requirements had been expected, but it now appears that this will not occur this year. Currently, there are no training requirements specific to long-term care insurance; LTCI agents must simply be licensed for accident and health insurance.

Vermont. The legislature has deferred final consideration of a bill establishing an LTC partnership until the 2010 legislative session, but it has adopted a regulation that includes LTCI training requirements, to become effective April 1, 2010. Under this rule, all LTCI agents must complete eight hours of initial training based on the NAIC model. Agents must take two hours of training in state-specific information, including the Vermont Medicaid program; these two hours can be included in the eight-hour training or taken in addition to it. Agents already licensed to sell LTCI as of March 31, 2010, will have until March 31, 2011, to complete the initial training; agents licensed to sell LTCI after March 31, 2010, will have to complete the initial training before selling. Finally, all LTCI agents will have to take four hours of ongoing training during every 24-month period ending on March 31 of odd-numbered years.

Virginia. Agents intending to sell partnership policies (not all LTCI agents) must complete initial training before selling. These agents must also take four hours of ongoing training during every 24-month period beginning on the date they completed the initial training.

Most resident agents will have to take eight hours of initial training based on the NAIC model plus state-specific information. However, agents who have previously completed six hours of CE credits in long-term care may be able to fulfill the initial training requirement by taking only a two-hour course focusing on partnerships and how they interact with public and private LTC coverage, including information specific to Virginia's Medicaid program. The previous six hours must be approved for CE credit for long-term care and must have been completed on or after Jan. 1, 2007, but before the agent takes the two-hour course.

Nonresident agents must complete a two-hour course that includes information on Virginia's Medicaid program, but they may be able to use LTCI training for another state to fulfill the remaining six-hour requirement (provided that training meets certain criteria).

Agents should contact the Virginia Insurance CE Board (administered by Pearson VUE) at www.virginiainsurance.com/ to find out if their previous CE credits or nonresident training qualify. To meet the needs of all agents, AHIP offers both a two-hour and an eight-hour Virginia course.

Washington. New LTCI training requirements became effective Jan. 1, 2009, replacing earlier requirements. All LTCI producers must complete eight hours of initial training before transacting LTCI. As of July 1, 2009, even producers who previously completed the Washington LTC Special Education Course (six hours) or the LTC Special Refresher Course (four hours) must complete this eight-hour initial training. A producer must also take four hours of ongoing training every 24-month period beginning the date he or she completed the initial training.

Both resident and nonresident producers can fulfill the initial training requirement by taking an eight-hour NAIC model course that meets the LTCI training requirements of another state. And they can fulfill the ongoing training requirement by taking a four-hour NAIC model course that meets the LTCI requirements of another state. However, only those taking the Washington LTC Initial Eight-Hour Course or the Washington LTC Refresher Four-Hour Course approved by the state (both of which include information on the state's LTCI regulations) receive CE credit.

West Virginia. All LTCI agents must complete eight hours of initial training based on the NAIC model. Agents already selling LTCI as of July 1, 2009, have until July 1, 2010, to complete this initial training; effective July 1, 2009, other agents have to complete the initial training before selling. Beginning July 1, 2010, agents will also have to take four hours of ongoing training during each 24-month CE period after the period in which they completed the initial training.

Wisconsin. All LTCI agents must complete eight hours of initial training before selling LTCI. The content of the initial training is based on the NAIC model, but it must include two hours of Medicaid and partnership content specific to Wisconsin and developed and issued by the state. Agents who have already completed an eight-hour NAIC model course, or who take such a course in another state, can fulfill Wisconsin's requirements by taking only the two hours of state-specific content. Agents also have to take four hours of ongoing training (including two hours of state-specific content) during every 24-month license renewal period after the period in which they completed the initial training.

Wyoming. On June 29, the federal government approved Wyoming's state plan amendment establishing an LTC partnership effective July 1, 2009, and on Sept. 9 the Department of Insurance issued a memorandum stipulating training requirements. By July 1, 2010, all LTCI agents will have to complete eight hours of initial training based on the NAIC model plus state-specific Medicare and long-term care information. Agents will also have to take four hours of ongoing training every 24 months.

IMPORTANT NOTE: States are currently developing and implementing their long-term care partnership programs and LTCI training requirements, and rules and regulations are in flux. The information in this article is based on state-issued documents and informal communication with state personnel. It is subject to change.

This article is intended for educational purposes only. Its contents are not a statement of policy on the part of AHIP or of its member companies. This article is distributed with the understanding that AHIP is not engaged in rendering legal advice or other expert assistance. AHIP shall not be liable for any losses or damages claimed through the use of the information contained in this article or relating to any potential inaccuracies of this information. For specific information on a state partnership program, the offices of the program should be contacted.

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