Can I provide input on spending?

• 85% local share: Up to each locality (generally not required). Only the minority of local governments that have opted into Option B’s collaborative, strategic planning process are required to seek public input on uses of their shares.[1] (See Decision-Making for an explanation of this scheme.) Regardless of whether a locality chooses Option A or B, local governments must adopt an authorizing resolution and a budget ordinance to spend from this share,[2] and you can attend hearings of your county board of commissioners and/or city councils. These hearings must be open to the public and provide at least one public comment period per month at their regular meetings.[3] Watch for other opportunities to weigh in on city and county spending decisions, such as city council meetings and town halls (e.g., Durham County's annual community meeting and online survey and Guilford County’s annual stakeholder input sessions).

• 15% state share: No opportunities available (not required). The state has not established recurring opportunities for the public to provide input on uses of its share.[4]

Can I apply for grants?

Yes. The state has offered grants in the past from the 15% state share.[5] Local governments may create grant programs to distribute their share of funds. The existence, parameters, and processes for local settlement grant programs will vary by locality, so stay alert for new opportunities. Visit the Opioid Settlement Community Grants Portal (OpioidSettlementTracker.com and Legal Action Center) for the most up-to-date information on settlement grant opportunities for community organizations.

Where do I go for updates?

• For updates on the local share, visit CORE-NC: Community Opioid Resources Engine for North Carolina[6] — which contains several Data Dashboards, e.g., Opioid Indicators, Community Drivers of Health, NC Payment Schedule, Local Spending Plans, and Past Spending— and be sure to bookmark the Coordination Group page to keep apprised of its meetings.[7] See also individual localities’ opioid settlement-related websites (e.g., Durham County).

• For updates on the state share, visit the State Spending of Opioid Settlement Funds page.

• You can also sign up for updates from Community Education Group’s Appalachian Opioid Remediation (AOR) Database, which tracks information about the 13 states of Appalachia.

What else should I know?

Each county is required to hold at least one annual meeting in which all municipalities within the county are invited so that it may receive input on how to use its opioid settlement funds and encourage collaboration among local governments. These meetings must be open to the public,[8] although there are no requirements to solicit input from the general public.

Citations

1. See Local Spending Plans Dashboard. CORE-NC website. Accessed September 1, 2024 (as of September 1, 2024, reporting that 11 local governments have reported Option B-related planning, as compared to Option A's 79 takers). ↑

2. See New guidance to local governments on how to authorize the expenditure of opioid settlement funds pursuant to the MOA and state law. North Carolina Department of Justice. July 12, 2023. ↑

3. See N.C. Gen. Stat. Sec. 143-318.10(a) (official meetings of public bodies generally must be open to the public), 159-12(b) (providing that prior to adopting a budget ordinance, a local governing board must “hold a public hearing at which time any persons who wish to be heard on the budget may appear”). See also See N.C. Gen. Stat. Secs. 153A-52.1 (county board of commissioners must provide at least one public comment period per month at a regular meeting of the board), 160A-81.1 (city council must provide at least one public comment period per month at a regular meeting of the board). ↑

4. If you see this change, email tips@opioidsettlementtracker.com. ↑

5. See, e.g., State Spending of Opioid Settlement Funds. MorePowerfulNC website. Accessed September 1, 2024 (describing assorted grant opportunities over the past several years). ↑

6. North Carolina Opioid Settlements. CORE-NC website. Accessed September 1, 2024 (“The Community Opioid Resources Engine for North Carolina is a collaborative partnership between the NC Department of Justice, the NC Department of Health and Human Services, the NC Association of County Commissioners, and the UNC Injury Prevention Research Center”). ↑

7. See, e.g., NC MOA Coordination Group. MorePowerfulNC website. Accessed September 1, 2024. ↑

8. Memorandum of Agreement Between the State of North Carolina and Local Governments on Proceeds Relating to the Settlement of Opioid Litigation, Sec. E(4). ↑

Where do these monies live?

The state government’s 15% share of opioid settlement funds is directed to the North Carolina General Assembly.[1] The monies are held in the Opioid Abatement Reserve, which sits within the state’s General Fund.[2]

What can this share be spent on?

With limited exceptions,[3] this share can be spent on the state government’s litigation costs and to “abate and remediate the harms caused to North Carolina and its citizens by the opioid epidemic.”[4]

Who ultimately decides how to spend this share (and how)?

State legislature decides. The North Carolina General Assembly ultimately decides how to appropriate this share as part of its normal budgeting process.[5]

In past years, the General Assembly has appropriated most of its share to the North Carolina Department of Health and Human Services (DHHS), whether for its own remediation uses or for the agency to distribute as sub-grants to organizations.[6]

Is this share attached to an explicit bar against supplantation?

No, supplantation is not prohibited. Like most states, North Carolina does not explicitly prohibit supplantation uses of its opioid settlement funds. This means that the 15% state share may be spent in ways that replace (or “supplant”) — rather than supplement — existing resources.

Can I see how this share has been spent?

Yes (neither public nor intrastate reporting required). View summaries of the General Assembly’s appropriations here.[7]

Visit OpioidSettlementTracker.com’s Expenditure Report Tracker for an updated collection of states’ and localities’ available expenditure reports.

What else should I know?

The legislature appears to have become more specific with its appropriations from the Opioid Abatement Reserve over time. Compare the more general appropriation to DHHS in the 2021 budget with the detailed allocations to specific organizations in the 2023 budget.

Citations

1. Memorandum of Agreement Between the State of North Carolina and Local Governments on Proceeds Relating to the Settlement of Opioid Litigation (MOA) B.2 (“15% [shall be allocated] directly to the State (‘State Abatement Fund’)”). Supplemental Agreement III.B(2). See Frequently Asked Questions on the Memorandum of Agreement on the Allocation, Use, and Reporting of Opioid Settlement Funds in North Carolina. North Carolina Department of Justice. July 2024. Accessed August 13, 2024 (“The North Carolina General Assembly (NCGA) decides how to spend the 15 percent state share in keeping with the broad requirement – stated in the national settlement agreements and the MOA – that such funds be spent on opioid remediation activities”). ↑

2. S.L. 2021-180, Secs. 9F.1.(a)-(b) (2021 Appropriations Act), as amended by S.L. 2022-103 (2022 Appropriations Act). ↑

3. MOA B.5 (all funds to be spent on opioid remediation “except as related to the payment of the Parties’ litigation expenses and the reimbursement of the United States Government”). ↑

4. S.L. 2021-180, Sec. 9F.1.(a) (2021 Appropriations Act), as amended by S.L. 2022-103 (2022 Appropriations Act). ↑

5. S.L. 2021-180, Sec. 9F.1.(a) (2021 Appropriations Act), as amended by S.L. 2022-103 (2022 Appropriations Act) (“Reserve may be allocated or expended only by an act of appropriation by the General Assembly”). See also MOA B.5 (“all Opioid Settlement Funds, regardless of allocation, shall be utilized only for opioid remediation activities”) and Supplemental Agreement III.B(5) (“The use of Additional Funds for opioid remediation activities shall be as described in MOA section B.5”). ↑

6. State Spending of Opioid Settlement Funds More Powerful NC website. Accessed August 13, 2024. (see “FISCAL YEAR 2021-2022,” “FISCAL YEAR 2022-2023,” and “FISCAL YEARS 2023-2024 AND 2024-2025”). More Powerful NC is a campaign led by Attorney General Josh Stein and DHHS Secretary Mandy Cohen. ↑

7. Embedded throughout are links to the state budgets themselves. ↑

CORE-NC (Community Opioid Resources Engine for North Carolina)

• About the Settlements

• General Support Resources

• Data Dashboards

  • Opioid Indicators

  • Community Drivers of Health

  • NC Payment Schedule

  • Local Spending Plans

  • Past Spending

North Carolina Department of Justice

• Frequently Asked Questions on the Memorandum of Agreement on the Allocation, Use, and Reporting of Opioid Settlement Funds in North Carolina (July 2024)

• Frequently Asked Questions about Option A Strategies in the MOA (October 2023)

North Carolina Department of Health and Human Services

• Opioid and Substance Use Action Plan Data Dashboard

North Carolina Association of County Commissioners

• Opioid Settlements Assistance

University of North Carolina (UNC) Family Medicine

• North Carolina Technical Assistance Center

North Carolina Survivors Union

North Carolina Harm Reduction Coalition

Community Education Group

• Appalachian Opioid Remediation (AOR) Database

• North Carolina: Allocation of Funds

Where do these monies live?

North Carolina allocates 85% of its settlement funds directly to its participating counties and municipalities according to the percentages in Exhibit G of North Carolina’s state-local agreement.[1]

Each are required to establish separate funds to hold their opioid settlement proceeds separate from any other local funds.[2] Municipalities may direct their shares to their counties.[3]

What can this share be spent on?

With limited exceptions,[4] this share must be spent on opioid remediation uses,[5] which the state defines for local governments to include “High-Impact Opioid Abatement Strategies” (“Option A” or “Exhibit A”) and/or “Additional Opioid Remediation Activities” (“Option B” or “Exhibit B”).[6] Settlement monies may not be used to reimburse past expenditures.[7]

• Under Option A, a local government may fund one or more strategies from a shorter list of “high impact” strategies (Exhibit A).[8]

• Under Option B, a local government must implement a collaborative strategic planning process in order to fund activities from a longer and more comprehensive set of strategies (Exhibit B).[9]

Who ultimately decides how to spend this share (and how)?

Local governments decide autonomously (subject to audit and consequences for misspend). Decisionmakers for the counties and municipalities will ultimately decide for themselves how to spend their monies on the High-Impact Opioid Abatement Strategies (“Option A” or “Exhibit A”) and/or Additional Opioid Remediation Activities (“Option B” or “Exhibit B”) lists,[10] whether directly or as grants to non-profit organizations.[11]

A local government’s governing body (i.e., county board of commissioners or city council) must adopt both an authorizing resolution and a formal budget ordinance to spend the locality’s settlement dollars.[12] Additional planning is required by both Option A and Option B:

• Under Option A, a county must hold at least one annual meeting and invite its municipalities to “receive input” and to “encourage collaboration between local governments both within and beyond the county.” This meeting is all that is required for a locality to pursue the opioid remediation expenditures described in “Exhibit A.”[13]

• Under Option B, localities must additionally engage in the “collaborative strategic planning process” outlined in Exhibit C to North Carolina’s state-local agreement.[14] This process requires engagement with a diverse array of stakeholders,[15] and results in a report and non-binding recommendations to the local government’s governing body.[16] This process must occur at least every four years thereafter, regardless of whether the locality adopts additional Exhibit B strategies.[17] If a locality chooses to pursue a new strategy listed in Exhibit B, it must implement this collaborative strategic planning process anew.[18]

Local settlement funds are subject to an annual audit, and local governments must report any misspent funds to the Attorney General.[19] Localities that use their settlement funds for impermissible purposes risk reductions of future payments or even redistribution of their funds by the state’s Attorney General.[20]

Is this share attached to an explicit bar against supplantation?

No, supplantation is not prohibited. Like most states, North Carolina does not explicitly prohibit supplantation uses of its opioid settlement funds. This means that the 85% local government share may be spent in ways that replace (or “supplant”) — rather than supplement — existing resources.

Can I see how this share has been spent?

Yes (public reporting required). Local governments must annually report expenditure information for inclusion in CORE-NC’s Past Spending Dashboard.[21]

Visit OpioidSettlementTracker.com’s Expenditure Report Tracker for an updated collection of states’ and localities’ available expenditure reports.

What else should I know?

The North Carolina Department of Health and Human Services and North Carolina Association of County Commissioners offers technical assistance to local governments on planning, implementation, and evaluation of opioid settlement spend.[22]

Citations

1. Memorandum of Agreement Between the State of North Carolina and Local Governments on Proceeds Relating to the Settlement of Opioid Litigation (MOA) B.2 (“80% [shall be allocated] to abatement funds established by Local Governments (‘Local Abatement Funds’) and MOA B.3 (The Local Abatement Funds shall be allocated to counties and municipalities in such proportions as set forth in Exhibit G”). 5% of funds are allocated to a County Incentive Fund. MOA B.2 and MOA G (describing a 5% bonus “if every municipality in the Local Government's county with population of at least 30,000 [] executed th[e] MOA by October 1, 2021”). See also Supplemental Agreement for Additional Funds from Additional Settlements of Opioid Litigation (Supplemental Agreement) III.B(2) (allocating 15% to the state, 84.62% to local governments, and 0.38% to a Local Counsel Fee Fund) and III.B(3) (“The allocation of Local Additional Abatement Funds between Local Governments shall be as described in MOA section B.3. However, to the extent required by the terms of an Additional Settlement, the proportions set forth in MOA Exhibit G shall be adjusted: (i) to provide no payment from an Additional Settlement to any listed county or municipality that does not participate in the Additional Settlement; and (ii) to provide a reduced payment from an Additional Settlement to any listed county or municipality that signs onto the Additional Settlement after the deadline specified by the Additional Settlement”). ↑

2. MOA D.1-2 (“Every Local Government receiving Opioid Settlement Funds shall create a separate special revenue fund, as described below, that is designated for the receipt and expenditure of the Opioid Settlement Funds,” and “[f]unds in this special revenue fund shall not be commingled with any other money or funds of the Local Government”). See also MOA D.3 (“The funds in the special revenue fund may be invested, consistent with the investment limitations for local governments, and may be placed in an interest-bearing bank account. Any interest earned on the special revenue fund must be used in a way that is consistent with this [Agreement]”) and Supplemental Agreement III.D. ↑

3. MOA B.4(b). Supplemental Agreement III.B(4) (“ Consistent with the manner in which MOA section B.4.b has been interpreted by the parties to the MOA with respect to Opioid Settlement Funds, a municipality that directs Local Additional Abatement Funds to the county or counties in which it is located pursuant to MOA section B.4 shall be relieved of any reporting or other obligations under the MOA with respect to the redirected funds”). ↑

4. MOA B.5 (requiring all funds to be spent on opioid remediation “except as related to the payment of the Parties’ litigation expenses and the reimbursement of the United States Government”), MOA F.3 (“Reasonable audit costs that would not be required except for this Section F may be paid by the Local Government from Opioid Settlement Funds”), Supplemental Agreement III.B(2) (“0.38% to a Local Counsel Fee Fund described in section IV of this [Supplemental Agreement]”), Supplemental Agreement IV (“As soon as practicable, but in any event no later than May 1, 2023, Local Counsel shall report to the settlement administrator the proportion of the Local Counsel Fee Fund to be received by each Local Counsel”). ↑

5. MOA E.5 (“Local Governments shall spend Opioid Settlement Funds from the Local Abatement Funds on opioid remediation activities using either or both of the processes described as Option A and Option B below, unless the relevant National Settlement Agreement or Bankruptcy Resolution further limit the spending”) and Supplemental Agreement III.E(1) (“Local Governments shall expend Additional Funds according to the requirements for Opioid Settlement Funds stated in [the MOA’s] section E”). See also MOA B.5 and Supplemental Agreement III.B(5) (“all Opioid Settlement Funds, regardless of allocation, shall be utilized only for opioid remediation activities” and “[t]he use of Additional Funds for opioid remediation activities shall be as described i MOA section B.5”). ↑

6. MOA E.5 (“Local governments shall spend Opioid Settlement Funds from the Local Abatement Funds on opioid remediation activities using either or both of the processes described as Option A and Option B” (emphasis added; Option A and Option B are not mutually exclusive) and Supplemental Agreement III.E(1) (“Local Governments shall expend Additional Funds according to the requirements for Opioid Settlement Funds stated in [the MOA’s] section E”). ↑

7. MOA E.1 (“Local Governments shall expend Opioid Settlement Funds only for opioid-related expenditures consistent with the terms of this MOA and incurred after the date of the Local Government’s execution of this MOA, unless execution of the National Settlement Agreement requires a later date”) and Supplemental Agreement III.E(1) (“Local Governments shall expend Additional Funds according to the requirements for Opioid Settlement Funds stated in [the MOA’s] section E”). ↑

8. MOA E.5(a)(i) (“This list is a subset of the initial opioid remediation strategies listed in the National Settlement Agreement”). See also North Carolina Opioid Settlements. CORE-NC. Accessed August 12, 2024. ↑

9. MOA E.5(b)(i) (“This list contains all the initial opioid remediation strategies listed in the National Settlement Agreement), E.5(b)(ii). Unlike Option A, “[t]his list shall be automatically updated to match the list of approved strategies in the most recent National Settlement Agreement”). MOA Exhibit B. See also North Carolina Opioid Settlements. CORE-NC. Accessed August 12, 2024. ↑

10. MOA E.5 (“Local Governments shall spend Opioid Settlement Funds from the Local Abatement Funds on opioid remediation activities using either or both of the processes described as Option A and Option B below, unless the relevant National Settlement Agreement or Bankruptcy Resolution further limit the spending”) (emphasis added; Option A and Option B are not mutually exclusive) and Supplemental Agreement III.E(1) (“Local Governments shall expend Additional Funds according to the requirements for Opioid Settlement Funds stated in [the MOA’s] section E”). ↑

11. MOA D.2 (“counties or municipalities may make contracts with or grants to a nonprofit, charity, or other entity”). ↑

12. MOA E.6(a) (“Opioid Settlement Funds can be used for a purpose when the Governing Body includes in its budget or passes a separate resolution authorizing the expenditure of a stated amount of Opioid Settlement Funds for that purpose or those purposes during a specified period of time”) and Supplemental Agreement III.E(1) (“Local Governments shall expend Additional Funds according to the requirements for Opioid Settlement Funds stated in [the MOA’s] section E”). See also MOA A (defining “Governing Body” to mean “for a county, the county commissioners of the county, and … for a municipality, the elected city council, town council, board of commissioners, or board of aldermen for the municipality”). The North Carolian Department of Justice reiterated these requirements in a July 2023 memo. See Memorandum: NC local governments receiving opioid settlement funds. North Carolina Department of Justice. July 12, 2023. Accessed August 13, 2024. (“Local governments receiving opioid settlement funds must satisfy both MOA requirements and state law requirements in order to authorize the expenditure of opioid settlement funds. … For these reasons, a local government must adopt both an authorizing resolution (consistent with the MOA requirements described below) and a formal budget ordinance (consistent with NC law) in order to authorize the expenditure of opioid settlement funds”) (emphasis in original). ↑

13. MOA E.4 (“Each county receiving Opioid Settlement Funds shall hold at least one annual meeting with all municipalities in the Local Government’s county invited in order to receive input as to proposed uses of the Opioid Settlement Funds and to encourage collaboration between local governments both within and beyond the county”) and E.5(a)(i) (“Without any additional strategic planning beyond the meeting described in Section E.4 above, Local Governments may spend Opioid Settlement Funds from the list of High-Impact Opioid Abatement Strategies attached as Exhibit A”). Supplemental Agreement III.E(1) (“Local Governments shall expend Additional Funds according to the requirements for Opioid Settlement Funds stated in [the MOA’s] section E”). ↑

14. MOA E.5(b)(ii) (“Before spending any funds on any activity listed in Exhibit B, but not listed on Exhibit A, a Local Government must first engage in the collaborative strategic planning process described in Exhibit C”). Supplemental Agreement III.E(1) (“Local Governments shall expend Additional Funds according to the requirements for Opioid Settlement Funds stated in [the MOA’s] section E”). ↑

15. Frequently Asked Questions on Option A Strategies in the Memorandum of Agreement On the Allocation and Use of Opioid Settlement Funds in North Carolina. North Carolina Department of Justice. October 2023. Accessed August 13, 2024. (“To engage diverse stakeholders means to involve a wide array of individuals and organizations in the discussion and planning around opioid settlement funds, including but not limited to these groups listed and described in Exhibit C: (1) local officials, (2) healthcare providers, (3) social service providers, (4) education and employment service providers, (5) payers and funders, (6) law enforcement, (7) employers, (8) community groups, (9) stakeholders with “lived experience,” and (10) stakeholders reflecting the diversity of the community”). ↑

16. MOA E.5(b)(ii) (“This process shall result in a report and non-binding recommendations to the Local Government’s Governing Body described in Exhibit C”). Supplemental Agreement III.E(1) (“Local Governments shall expend Additional Funds according to the requirements for Opioid Settlement Funds stated in [the MOA’s] section E”). ↑

17. MOA E.5(b)(iii) (“A Local Government that has previously undertaken the collaborative strategic planning process described in Exhibit C and wishes to continue implementing a strategy listed in Exhibit B, but not listed in Exhibit A, shall undertake a new collaborative strategic planning process every four years (or more often if desired)”). Supplemental Agreement III.E(1) (“Local Governments shall expend Additional Funds according to the requirements for Opioid Settlement Funds stated in [the MOA’s] section E”). ↑

18. MOA E.5(b)(iv) (“A Local Government that has previously undertaken the collaborative strategic planning process described in Exhibit C that wishes to implement a new strategy listed in Exhibit B but not listed in Exhibit A, shall undertake a new collaborative strategic planning process”). Supplemental Agreement III.E(1) (“Local Governments shall expend Additional Funds according to the requirements for Opioid Settlement Funds stated in [the MOA’s] section E”). ↑

19. MOA F.1 (“If any such audit reveals an expenditure inconsistent with the terms of this MOA, the Local Government shall immediately report the finding to the Attorney General”). See also Supplemental Agreement III(F)(1) (“If any such audit reveals an expenditure inconsistent with the terms of this MOA, the Local Government shall immediately report the finding to the Attorney General”). ↑

20. MOA E.2 (“If a Local Government spends any Opioid Settlement Funds on an expenditure inconsistent with the terms of this [Agreement], the Local Government shall have 60 days after discovery of the expenditure to cure the inconsistent expenditure through payment of such amount for opioid remediation activities through budget amendment or repayment”) and MOA E(3) (“If a Local Government does not make the cure required by Section E.2 above within 60 days, (i) future Opioid Fund payments to that Local Government shall be reduced by an amount equal to the inconsistent expenditure, and (ii) to the extent the inconsistent expenditure is greater than the expected future stream of payments to the Local Government, the Attorney General may initiate a process up to and including litigation to recover and redistribute the overage among all eligible Local Governments. The Attorney General may recover any litigation expenses incurred to recover the funds. Any recovery or redistribution shall be distributed consistent with Sections B.3 and B.4 above”). ↑

21. MOA F.6(a)-(c). MOA Exhibit F includes the impact information that is required to be included in local government reporting. ↑

22. See North Carolina Opioid Settlements: Contact Information. CORE-NC. Accessed September 1, 2024. ↑

Here are the entities that ultimately decide how each of North Carolina’s opioid settlement shares are spent:

• 85% local share: local officials for counties and municipalities

• 15% state share: North Carolina General Assembly

This Community Guide will describe how North Carolina is spending its opioid settlements and whether North Carolina is working to ensure community access to opioid settlement funds. Last revised September 1, 2024

Has the state established an advisory body for settlement funds?

Yes. North Carolina’s memorandum of agreement establishes a 12-member that may provide support to local governments, but this Coordination Group does not operate in a traditional advisory capacity.[1] Specifically, the Coordination Group may work with parties to the MOA, “the North Carolina Association of County Commissioners, the North Carolina League of Municipalities, other associations, foundations, non-profits, and other government or nongovernment entities” to support local governments’ uses of opioid settlement funds,[2] including by:

• Assisting with data identification, location, collection, analysis, and reporting

• Developing resources and providing training and technical assistance

• Developing pilot programs or other resources to support collaborative strategic planning processes

• Developing and implementing voluntary learning collaboratives

• Developing voluntary leadership training programs[3]

The Coordination Group also:

• Must approve a to govern a compliance audit of local governments’ expenditures[4]

• May modify the MOA’s list of high-impact strategies (), collaborative planning process (), annual financial report (), impact information (), or “other information” reported to [5]

• May propose other amendments to the MOA for approval by the North Carolina Attorney General and local governments[6]

The Coordination Group is required to meet once annually for three years and once every three years thereafter.[7] Information about past and upcoming meetings is available .

Is the state advisory body required to include member(s) with lived and/or living experience?

No. The neither operates in a traditional advisory capacity nor is required by North Carolina’s MOA to include member(s) with lived and/or living experience. However, those responsible for making appointments to the Coordination Group “are encouraged to appoint individuals who reflect the diversity of North Carolina, taking into consideration … the experience and perspective of persons with ‘lived experience.’”[8]

What is the overall membership of the state advisory body?

The Coordination Group’s appointing entities “are encouraged to appoint individuals who reflect the diversity of North Carolina, taking into consideration the need for geographic diversity; urban and rural perspectives; representation of people of color and traditionally underrepresented groups; and the experience and perspective of persons with ‘lived experience.’”[11]

Are local governments required to establish a settlement advisory body? If so, are local advisory bodies required to include member(s) with lived and/or living experience?

All localities also may independently choose to establish advisory councils that include members with lived and/or living experience to help ensure that settlement spending reflects community priorities.

What else should I know?

Not applicable.

Citations