1. 1 Introduction to FMLA and FMLA Outsourcing Angela Ripper, AVP and Senior Counsel Law Department August 2015 * This presentation is current as of September 2015. Nothing in this presentation is to be construed as legal advice. FX-3182 (5-15)

2. 2 FMLA history FMLA 101 Legal considerations Employer challenges FMLA administrative options Impact of lost time: What are the costs? Presentation content

3. 3 FMLA history

4. 4 Enactment The Family Medical Leave Act (“FMLA”) of 1993 was enacted on February 5, 1993 and became effective on August 5, 1993 for most covered employers. Revisions New regulations interpreting the FMLA were issued in November 2008 with an effective date of January 16, 2009. These amendments included active duty and military caregiver leave. Additional revisions were issued February 6, 2013 (effective March 8, 2013) implementing National Defense Authorization Act for Fiscal Year 2010 and the Airline Flight Crew Technical Corrections Act. FMLA history Accountability The United States Department of Labor is the governmental agency responsible for enforcement of the FMLA. Coverage Nearly 60% of employees meet all criteria for coverage and eligibility under FMLA. 1 Utilization Based on a 2012 survey, 13% of all employees reported taking leave for a FMLA reason in the past 12 months. 2 1, 2 Source: US Dept of Labor Wage and Hour Division, FMLA is Working (2013).

5. 5 FMLA 101

6. 6 Evaluate eligibility for leave  Hours worked  Location  Tenure  Employee status Calculate entitlement for leave  How much time available  Coordination with state leave laws Employer obligations An employer must, within pre-determined time frames: Determine qualification of leave  Meet the definition of a serious health condition or military leave entitlements through review of employee-provided medical certification or information  Meet the definition of non-medical leaves  Follow applicable state leave laws Confirm in writing within five business days of notice or leave  Eligibility  Rights and responsibilities Confirm in writing within five business days of receipt of information  Designation of leave

7. 7 Fixed year method Under the fixed 12-month period method, an eligible employee (EE) can take up to 12 weeks leave at any time within the fixed 12- month period selected. Employer can select one of the following: ●The calendar year ●Any other 12-month period Methods for calculating FMLA leave Note: Flight crew employees have fixed entitlements of 72 days for “regular” FMLA and 156 days for military caregiver leave. Rolling backward method Under the backward method, an EE’s 12-month period is measured backward from the date an EE uses any FMLA leave. Every day an EE takes FMLA leave (including intermittent leaves) he/she is entitled to any remaining balance of the 12 weeks of leave that has not been used during the immediately preceding 12-month period. Rolling forward method Under the forward method, an EE’s 12-month period starts on the day the EE’s first FMLA leave begins and ends 12 months later. The EE can take 12 weeks of FMLA leave during that 12-month period. The EE’s next 12-month period begins the first time he/she takes FMLA leave after completing the previous 12- month period.

8. 8 Which employers are covered?  Private Sector: 50 or more employees for at least 20 weeks in the current or preceding calendar year What about temporary employees?  Time worked counts toward employee’s hours and tenure requirements Who is covered by the FMLA? Note: Flight crew members have different requirements based on airline industry scheduling equivalents Which employees can take FMLA leave?  Been employed for at least 12 months (does not need to be consecutive) ●Any week in which employee is maintained on the payroll counts (including weeks when no work is performed)  Employed at a site with 50 or more employees within a 75 mile radius  Has worked at least 1,250 hours during the 12 months prior to the leave request (consecutive) ●Only actual work is counted ●Leaves of absence, paid or unpaid, including FMLA leave, are not counted ●Pursuant to USERRA, employees returning from military service shall be credited with hours that would have been performed but for the military service

9. 9 Birth of a child Placement of a child for adoption or foster care To care for a spouse, child, or parent with a serious health condition Because of the employee’s own serious health condition Because of a qualifying exigency To care for a family member injured in the line of duty – military caregiver leave When can an employee take FMLA leave?

10. 10 Both mothers and fathers are eligible  But if they work for the same employer, they are only entitled to 12 weeks jointly  They can split up the leave however they want  Leaves can overlap  Each spouse eligible to take his or her own remaining weeks for other purposes Remember, this is a separate kind of leave from leave related to pregnancy. Birth of a child

11. 11 Covers absences required in order for the placement to occur  Attorney meetings  Court appearances  Doctor visits  Going to pick up the child Foster care leave only applies to arrangements sanctioned by state  Employer has right to request documentation  Rule applies even if children are relatives of your employees Adoption or foster care

12. 12 Spouse  Husband or wife (as defined by the state where marriage was entered into)  Includes common law marriage Son or daughter  Biological child  Adopted or foster child  Stepchild  Legal ward  Any child employee has day-to-day responsibility for (practical or financial care if the person intends to assume the responsibility of a parent)  Under 18, or incapable of caring for herself due to mental or physical disability at the time FMLA leave is to commence Parent  Biological or adopted parents  Does not include in-laws or grandparents, except if that individual acted as a parent to the employee when he/she was a child Care for loved ones You can request documentation – but proceed with care !

13. 13 Inpatient care Pregnancy-related conditions Continuing treatment: incapacity and treatment Chronic health conditions Permanent long term condition Treatment to prevent incapacitation or restorative surgery General categories of serious health conditions

14. 14  Allergies  Asthma  Alzheimer’s disease  Diabetes  Epilepsy  Mental illness  Restorative/plastic surgery after an injury  Removal of cancerous tumors  Stroke Serious health condition: examples Remember: Applies to employee or loved one

15. 15 Routine check-ups Minor illnesses, injuries  Even if there is a doctor’s visit  Child falls on playground at school, needs stitches  Employee goes to emergency room with chest pains, turns out to be gas Elective cosmetic treatments not requiring inpatient care  Lasik eye surgery  But if inpatient care is required (as part of standard treatment, or due to complications) it will qualify Absences caused by substance abuse  But absences caused by treatment for addiction typically will be covered Examples of medically related absences NOT typically covered by the FMLA

16. 16 Up to 12 weeks of unpaid leave to address a qualifying exigency arising from the fact that a spouse, son, daughter, or parent of the employee is on covered active duty (or has been notified of an impending call or order to covered active duty) in the Armed Forces Covered active duty includes members of both the regular and reserve components of the Armed Forces Covered active duty must involve deployment to a foreign country Qualifying exigency is specifically defined by the regulations Qualifying Exigency

17. 17 Up to 12 weeks of unpaid leave to address a qualifying exigency arising out of the fact that a spouse, son, daughter, or parent of the employee is on covered active duty (or has been notified of an impending call or order to covered active duty) in the Armed Forces Covered active duty includes members of both the regular and reserve components of the Armed Forces Covered active duty must involve deployment to a foreign country Qualifying exigency is specifically defined by the regulations Military amendments

18. 18 Qualifying exigency To address any issue that arises as a result of short notice deployment of 7 or less calendar days (7-day limit on this leave) To attend military events and activities related to the active duty or call to active duty; includes family support or assistance programs and informational briefings Child care and school activities  To arrange for alternate child care  To provide child care on an urgent, immediate need basis  To enroll in or transfer to a new school or daycare  To attend disciplinary meeting with school or daycare (arises out of active duty or call to active duty)

19. 19 Qualifying exigency (continued) Financial and legal arrangements  Make or update financial or legal arrangements to address absence  To act as covered military member’s representative before an agency regarding military benefits Counseling  To attend counseling (other than by healthcare provider) for oneself, the covered military member or the child, provided the need for counseling is a result of active duty or call to active duty R&R leave (15-day limit)  To spend time with covered military member during periods of deployment Post-deployment  To attend ceremonies, briefings, etc. for a period of 90 days following the termination of active duty status Qualifying exigency (continued)

20. 20 Qualifying exigency (continued) Parental care  Must be parent of service member who is incapable of self-care  To arrange for alternate care when the active duty or call to active duty status necessitates a change in existing arrangements  To provide care on an urgent, immediate need basis when the need to provide care arises from the active duty or call to active duty  To admit or transfer to a care facility when admittance or transfer is necessitated by the active duty or call to active duty  To attend meetings with staff at a care facility (e.g. hospice or social service providers) when meetings are necessary due to circumstances arising out of active duty or call to active duty “Catch-all”  To address other events provided employer and employee agree it is a qualifying exigency and agree to timing and duration Qualifying exigency (continued)

21. 21 Military caregiver leave Leave to provide care for covered service member who is employee’s injured spouse, son, daughter, parent, “next of kin” Covered service member – Current member or veteran of either the Armed Forces, National Guard or military reserves  Veteran’s discharge or release must be under conditions other than dishonorable during the 5-year period preceding the start of leave  October 28, 2009 – March 8, 2013 excluded from 5-year period Not a SHC (serious health condition): a “serious illness or injury” incurred by service member in the line of duty on active duty, and which may render service member unfit for duty Serious injury or illness extended to also mean those that existed before the beginning of the member’s active duty, which were aggravated by service in line of duty on active duty  “In the line of active duty” is defined in military regulations to include any injury suffered while in the military, even if not caused by the performance of military duties, i.e. cancer  There is an exclusion for injuries caused by the service member’s misconduct

22. 22 Military caregiver leave (continued) An eligible employee is entitled to 26 workweeks of leave to care for a covered service member with a serious injury or illness during a single 12-month rolling forward period, regardless of the calculation method used by an employer.  Different (and potentially separate) 12-month period(s)  The leave entitlement is applied on a “per-servicemember, per-injury basis,” such that eligible employee may be able to take more than one period of 26 workweeks of leave if leave is to care for different covered servicemember or same servicemember with subsequent injury or illness; but maximum 26 weeks in each 12 month period  Employee entitled to both caregiver leave and regular FMLA (even for same SHC of covered military member)  Maximum 26 weeks in each 12- month period for “regular FMLA” and “military caregiver leave”  Employer responsible for designating leave as FMLA- qualifying

23. 23 Single, continuous block of leave Intermittent leave Leave taken in separate blocks of time for a single illness or injury  Can be for planned treatments  Or for conditions which “flare up” unexpectedly and prevent employee from doing his job (migraines, arthritis, lupus, bad back, etc.)  FMLA does not require an employer to allow employees to take intermittent or reduced schedule leave for bonding; however, an employer can choose to allow this under their leave policies Reduced leave schedule Leave which results in regular alteration/reduction of scheduled work hours during the certified period  Employee is entitled to be given a reduced leave schedule if condition qualifies and schedule is medically necessary  FMLA does not require an employer to allow employees to take intermittent or reduced schedule leave for bonding; however, an employer can choose to allow this under their leave policies Types of leave But an employee cannot be forced to take more time off than needed

24. 24 How do you deduct leave for intermittent or reduced schedule absences? FMLA leave is based on the employee’s normal work week  If employee normally works a 5-day week and takes off one day, the employer should deduct 1/5 of a week of FMLA leave  If employee who normally works an 8-hour day is put on a 4-hour per day reduced leave schedule, he would use ½ week of FMLA leave each week When employee works part time, FMLA deduction is made on a pro-rata basis by comparing new schedule with old schedule  If employee normally works 30 hours per week, but is put on a 20-hour per week reduced schedule, he is using 1/3 week of FMLA leave each week

25. 25 Intermittent and reduced schedule leave Increment of time clarified  Employer must account for leave using increment no greater than the shortest period of time that employer uses to account for other forms of leave  Increment cannot be greater than 1 hour  Cannot reduce by more than amount of leave actually taken  If increments for other forms of leave vary based on time of day or shift, FMLA increment can vary as long as it remains consistent with other forms of leave taken at the same time of the day  Flight Crew increment no greater than 1 day

26. 26 Tips for managing intermittent leave Remember eligibility rule: Once employee is deemed eligible, he remains so for 12 months going forward  But he still can only take 12 weeks during your chosen 12-month period Always require medical certification  Form should specifically state whether intermittent or reduced leave is required; send it back if it does not  Require re-certification as allowed by the regulations Require foreseeable leave to be scheduled to reduce disruption to your operations

27. 27 Tips for managing intermittent leave (continued) Consider possibility of temporary transfer to a position where intermittent absences won’t have such an impact  This is only allowed for planned medical treatment Carefully track all time Be careful about enforcing attendance policies  Check with Human Resources

28. 28 Legal considerations

29. 29 FMLA/Leave management services Key: colored areas indicate states with additional leave regulations Scope and complexity of the law

30. 30 State leave laws FMLA-like leave laws Pregnancy disability Bonding Bone marrow Volunteer fire fighters (emergency workers) School activities leave laws Domestic violence/crime victim leave laws Kin care

31. 31 Top 10 mistakes 1.Improperly determining eligibility 2.“Deeming” employees FMLA eligible 3.Failure to provide required notices 4.Using a calendar year 12-month period 5.Failure to calculate leave entitlement appropriately 6.Failure to properly designate FMLA time 7.Inappropriate use of medical certifications 8.Failure to request a new certification and re-determine eligibility in a new leave year 9.Improper use of re-certifications 10. Failure to monitor intermittent leaves closely

32. 32 The risk of non-compliance Failing to comply with the law can be costly. Managers can be held personally responsible for violations. Companies can be faced with expensive legal fees and settlement fees. The Case: In Schultz v. Advocate Health and Hospitals Corp., a long-time employee alleged his former employer terminated him in retaliation for using FMLA to care for his two ill parents. The employee took intermittent leave over several months and during this period began having problems with his supervisors who established performance standards he was unable to meet. The problem escalated until the employee was terminated. The Result: A federal jury awarded $11.65 million to the employee. The award consisted of $10.75 million against the employer and $900,000 individually against the two supervisors. 1 1 Schultz v. Advocate Health and Hospitals Corp., N.,D. Ill., No. 01 CV 702, 10/30/02.

33. 33 The risk of non-compliance The Case: In Allen v. A.G. Edwards & Sons*, Inc., the plaintiff, Donald Allen, brought suit against his employer, A.G. Edwards & Sons, Inc. for violations of the ADA and FMLA as well as state laws on constructive discharge. In 2001, he was diagnosed with bi-polar disorder and briefly hospitalized. When he returned to work, the company refused to reinstate him to his old job. A.G. Edwards had options under FMLA and ADA but was concerned about the plaintiff’s ability to perform his job. Allen claimed he was demoted to a financial consultant job that required him to report to the former assistant branch manager and was not reinstated to an equivalent position. The employer argued that there was no FMLA violation because they had returned him to a manager position. The Result: The arbitration panel ultimately found for the plaintiff and found that the employer violated the FMLA. Allen was awarded 1.25 million dollars. Failing to comply with the law can be costly. Managers can be held personally responsible for violations. Companies can be faced with expensive legal fees and settlement fees. *NASD #04-06092, June 26, 2006

34. 34 The risk of non-compliance The Case: Lubke v. Arlington.* The plaintiff, Kim Lubke, sued the City of Arlington, alleging he was discharged in violation of FMLA as a result of missing work to care for his ill wife. Lubke was scheduled to work from December 31, 1999 through January 1, 2000. On December 30, 1999, Lubke telephoned a call box and left a message stating that he would not be working during the Y2K weekend because he needed to stay home with a sick wife. Lubke was terminated for dereliction of duty, unauthorized absence and insubordination. At trial, the employer asserted that Lubke’s leave was not protected by the FMLA because he failed to provide timely and adequate medical certification supporting his leave. The Result: The jury rejected the employer’s claim and found that the employer had violated the FMLA. They awarded the plaintiff over 1 million dollars in damage. On appeal, the Fifth Circuit affirmed the jury verdict. Failing to comply with the law can be costly. Managers can be held personally responsible for violations. Companies can be faced with expensive legal fees and settlement fees. *2006 WL1793268, June 30, 2006 US Court of Appeal, Fifth Circuit

35. 35 The risk of non-compliance The Case: Lore v. Chase Manhattan Mortgage Corp.* The plaintiff, Nicholas Lore, requested leave to address several health issues. He was told an additional manager would be hired to assist with his responsibilities and enable him to take leave. When the additional manager was not hired, Lore inquired of his manager again requesting leave. Less than one month later, Lore was terminated. Lore sued Chase Manhattan for failing to grant him, an eligible employee, leave under the FMLA. In addition, Lore argued Chase Manhattan unlawfully retaliated against him for his attempts to exercise his rights under the FMLA. The Result: A jury found for the employee and awarded him $2,227,241. With liquidated damages equal to the amount of the verdict and prejudgment interest added in, the recovery equaled between $6.2 and $7.6 million. Failing to comply with the law can be costly. Managers can be held personally responsible for violations. Companies can be faced with expensive legal fees and settlement fees. *2008 Lore v. Chase Manhattan Mortgage Co., 2008 WL 2404425 (N.D. Ga., 2008)

36. 36 The Risk of non-compliance The Case: Dotson v. Pfizer*. The plaintiff, Dotson, was seeking to adopt a child from Russia and took intermittent time off to attend to the adoption, taking two trips to Russia. The employee kept his employer informed and spoke to his HR Dept. After returning from Russia with the child, the employee was terminated based on an alleged violation of company policy. Dotson sued for FMLA retaliation. The employer argued that the employee was not entitled to FMLA protection because he failed to indicate that he needed FMLA leave. The court rejected this argument, noting that an employee does not have to expressly state that he needs FMLA or use any magic words to trigger the employer's obligation. The Result: A jury found for the employee and awarded him more than $1 million plus prejudgment interest. The employer appealed but the court affirmed the decision in the employee’s favor. The court also held that the lower court erred when it failed to award the employee prejudgment interest, making the judgment even larger than that awarded by the jury. *2009 Dotson v. Pfizer, No. 07-1920 (4 th Cir. March 4, 2009) Failing to comply with the law can be costly. Managers can be held personally responsible for violations. Companies can be faced with expensive legal fees and settlement fees.

37. 37 The Case:  The employee began maternity leave in June 2009. Her child was born in July and she continued on leave until November 2009. At the time of her request for leave, the employee provided leave of absence forms and medical certification.  Her employer did not provide her individualized notices regarding her leave (Eligibility Notice, Rights and Responsibilities, Designation Notice, etc.). However, they did have all key information regarding FMLA in their employee handbook.  On November 30, the employer informed the employee during a telephone call that her leave had expired, she needed to return to work, and she would need a release from her doctor.  On December 1, the employee was terminated for exhausting her leave and failing to return to work with a release. The Result:  The plaintiff was not afforded the opportunity to make informed decisions about her leave. Had she been appropriately informed regarding her leave time, she could have planned and structured her leave time differently.  The plaintiff was prejudiced by lack of individualized notice, and summary judgment was granted in her favor. Young v. Wackenhut Corporation, Feb. 2013 Young v. The Wackenhut Corp., No. 10-2608 (D.N.J, February 1, 2013) Failing to comply with the law can be costly. Managers can be held personally responsible for violations. Companies can be faced with expensive legal fees and settlement fees.

38. 38 What can you do about abuse of FMLA?  Strictly follow certification requirements  Don’t be afraid to seek clarification or ask for second or third opinions, particularly when dealing with employees with a history of attendance problems  Be consistent – don’t selectively enforce  Put everything in writing, it gives employees less “wiggle room”  Stay in touch with absent employees – there is no prohibition against contacting them, asking about their status  Keep your eyes and ears open – if circumstances have changed, request re-certification  But your documentation must be solid

39. 39 Employer challenges

40. 40 The most frequently cited HR organizational challenges with FMLA:* Key FMLA findings from employers Source: 2014 Employer Leave Management Survey DMEC/Spring Consulting, January 2015 FMLA Activities Ranked as Difficult or Extremely Difficult 2013 2014

41. 41 The challenges facing employers  Leave policies must comply with both federal and state leave laws  Each leave request must be individually evaluated for eligibility and qualifying conditions  Documentation must be collected, verified, recorded and filed for every leave request  Managers may be found to be individually liable. Employers are subject to fines and/or other penalties if there is a violation of the FMLA  Intermittent leaves are difficult to track  It is difficult to coordinate STD & FMLA when they are outsourced separately  Retention and termination of employees  Productivity and employee morale  Indirect costs of covering absences (overtime, temporary workers, outside contractors)

42. 42 FMLA administrative options

43. 43 FMLA administrative options  TPA  Carrier/TPA  Carrier with dedicated capabilities In-source  Decentralized model  Centralized model Out-source

44. 44 The costs of in-house administration Productivity  Employee leaves disrupt work routines and cause confusion and distraction among remaining staff.  Leaves can require replacement workers and/or overtime wages.  Managers must consider any impact of FMLA absence separately from other performance issues, complicating the entire management process. 1 Based on Unum internal experience, 2007. 2 ABT Associates for U.S. Dept of Labor, Family and Medical Leave in 2012: Technical Report (2013). Tracking & Administration  About half of employers report that the cost of complying with FMLA has increased over the years. Less than 1% said the cost decreased. 2  Other tracking and administration costs include maintenance of records, storage and supplies in conjunction with the administration of other benefits such as STD and workers compensation. Legal/Compliance  State leave laws are numerous and change often. Employers and their legal counsel must constantly survey court rulings and changes in the laws to remain up-to-date.  Failing to comply with the law can be costly and managers can be held personally responsible for violations.  Litigation costs are roughly $100K to $200K per claim not including settlement costs. 1

45. 45 FMLA administrative options  Employer size  Demographics  Industry  Location and number of operational sites  Absence management philosophy  Company culture  Current capabilities In-source versus outsourcing — factors to consider:

46. 46 Outsourcing evaluation look for robust leave management services capabilities  Single integrated solution, one vendor administering STD and FMLA  Single point of intake (STD/FMLA)  Web-based reporting that allows drill-down into data  Real-time updates to changes in state leave laws or federal  In-house legal and technical expertise, includes newsletter to employer  Proven scale with large customer base and covered lives, strong customer persistency  Superior customer satisfaction survey results  Administration for all separate state leave laws  Look for case studies showing enhanced productivity though reduction of lost time  Indemnification Whether managing in-house or with a Carrier/ TPA, look for these capabilities:

47. 47 Lost time costs

48. 48 The case for integration Because of the significant overlap that exists between short term disability and FMLA leaves, managing these leaves separately can cause additional costs and result in employees absent from work longer than entitled. The case for integration

49. 49 Clients benefit from our centers of excellence Absence Management Specialist STD Specialist FMLA Specialist Employer or Employee Toll-free call Short Term Disability Specialists  Quarterback of the overall process  Determine benefit eligibility  Assess medical expertise for disabling condition  Evaluate functional capacity  Complete job analysis  Calculate benefits  Support return-to-work efforts  Support integration with health programs Knowledgeable about customer’s unique needs Absence Management Specialists  Intake new leave/claim and inform employee  Set expectations and next steps  Record intermittent hours  Answer questions related to leave and disability claim FMLA Specialists  For disability claims, follows STD decision  State and Federal leave eligibility and designation  Coordination between Federal, State and Corporate policies  Family leave, bonding  Intermittent management Absence Management Team

50. 50  Direct cost of paid time off for full-time employees in 2013 ‒ accounting for wages, overtime and replacement workers ‒ was equivalent to 15.4 percent of payroll.  When indirect costs such as lost productivity were added, the total cost of paid time off was between 20.9 percent and 22.1 percent of payroll, with unplanned absences having the highest overall cost.  Supervisors spent a average of 4.2 hours a week ‒ or 5.3 weeks a year- dealing with absences, including finding replacements, adjusting workflow and providing training.  The highest average loss in productivity, 36.6 percent, was the result of replacement working being used to cover for an unplanned absence, making this type of absence the greatest cause for concern in controlling costs. Employee absences impact employer’s bottom line and productivity Daily Document Update: HR Compliance Library, ¶33,636, Employee absences have consequences for productivity and revenue, SHRM research shows — SURVEY RESULTS, (Dec. 30, 2014)

51. 51 Case study ‒ intermittent leave management* # US Employees  4,500 year round  11,500 at peak (December) Products and services – retail sales  Offers clothing and outdoor gear for customers to enjoy the outdoors  Contact Centers provide world class legendary service to customers Four year-round centers and one seasonal center in Northern New England Handle inbound order and customer service calls 24 hrs/day, 7 days/week ‒ 365 days a year Daily call volume ‒ 35,250 calls off peak; 133,500 calls during peak Call center operations are supported by centralized planning functions (finance, systems/technology, quality, training, workforce planning) Company ‒ outdoor clothing and gear retailer *This case study is true, although the employer name and other identifying characteristics have been removed or changed to preserve confidentiality.

52. 52 Case study ‒ Intermittent leave management (continued) Annual turnover ‒ 7-8% Short term disability absence in ‘05 – 2,850 days (est. equivalent of 11 full-time employees) Workers’ compensation lost time in ‘05 – 53 days Intermittent FMLA absence:  Year prior to outsourcing:  Equivalent of 1,100 days or est. 92 days/month  First 5 months after outsourcing:  Reduced to the equivalent of 187.5 days or est. 38 days/month  58.7% reduction in lost time Flexible call center staff numbers adapted to meet changing needs ‒ from 1,170 year- round employees to over 4,340 at peak times

53. 53 Questions?

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