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EFTA00141295_sub_002 - EFTA00141295_200
reasons an institution or region may need to provide an incentive. For example, there are five institutions in California — USP Atwater, FCI Dublin, FCI Herlong, FCC Victorville, and FCI Mendota, or the "California 5" — that have been offering retention incentives consistently for over 10 years and make up a
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