Review of Key Issues for Informed Decision-Making Introduction Even though infertility is a medically recognized condition, there’s no consensus in the business community about the sometimes confusing and sensitive issue of fertility benefits. Some employers are engaged on the issue, and through a deliberate process, have designed a fertility benefit that is consistent with their overall benefits philosophy and responsive to the unique benefits challenges posed by infertility treatment. Conversely, other employers don’t consider employee infertility treatment their responsibility, or have shied away from fertility benefits because of its perceived potential to be a black hole of spending. The purpose of this employer guide is threefold. First, it is intended to provide some basic “birds and bees” information about infertility and its treatment— particularly female infertility. Second, it presents financial data about the costs of infertility treatment and the costs of fertility benefits to employers. Finally, this report explores key issues in fertility treatment insurance coverage, issues about which many employers have interest, but lack knowledge for informed decision-making. These medical and benefits thought leaders contributed to the content of this employer guide… 34% Howard W. Jones, Jr., MD Ray Brusca J. Brooks Watt, MD Professor Emeritus, Eastern Virginia Medical School, Professor Emeritus,Johns Hopkins University School of Medicine, Honorary Chairman of the Jones Institute Foundation VP of Benefits Black & Decker Corporate Medical Director Gillette Company 33% 33% Þ Male reproductive problems Þ Female reproductive problems Source: RESOLVE: The National Infertility Association 1 What Is Infertility? Infertility, which can be caused by many diseases, is defined as the inability to conceive after one year of unprotected intercourse (six months if the woman is over age 35). Þ Male and female reproductive problems, or unexplained Causes of Infertility The major causes of infertility include the following: Þ Woman’s fallopian tubes may be blocked or damaged, making it difficult for the egg to be fertilized or for an embryo to travel to the uterus. Þ Woman’s ovaries may not be maturing and passing eggs normally or egg quality and number may have diminished with age; or the woman may have hormonal conditions that adversely affect ovulation. Þ Disorders of the uterus or vagina that impair fertility. Þ Male sperm count may be low or there may be problems with sperm function. Female Reproductive System Source: JAMA patient page: infertility. JAMA.1999 Nov 17;282(19)1888. Fertility Benefits Basics 62.1 million women in U.S. age 15 to 44 years 9.32 million women receive infertility treatment How Common Is Female Infertility and Its Treatment? As depicted in this chart to the right, over 15% of women of reproductive age in the U.S. have received some level of infertility treatment. 15% 85% No fertility service Sources: 2005 Population Estimates. U.S. Census Bureau; Infertility Treatment as a Covered Health Insurance Benefit. Association of Women’s Health, Obstetrics and Neonatal Nurses. 36% Require additional treatment 64% Require only basic medical advice or diagnostic tests Fertility service How Is Female Infertility Treated? The overwhelming majority of female infertility cases are treated with conventional drug therapy or surgical procedures. Since the early 80s, assisted reproductive technology (ART) such as in vitro fertilization (IVF), gamete intrafallopian transfer (GIFT) and zygote intrafallopian transfer (ZIFT) have also been used to overcome infertility. Fewer than 3% of infertility cases require ART, which is defined as fertility treatments in which both eggs and sperm are handled in the laboratory for the purpose of establishing a pregnancy. ART does not include ovarian stimulation utilizing medications such as clomiphene citrate tablets, USP and/or gonadotropin to induce ovulation with (or without) intrauterine insemination. A typical ART procedure begins when a woman starts taking drugs to stimulate egg production or begins having her ovaries monitored with the intent of having embryos transferred. If eggs are produced, the procedure progresses to the egg-retrieval stage. After the eggs are retrieved, they are combined with sperm in the laboratory (IVF), and if fertilization is successful, the resulting embryos are selected for transfer. IVF accounts for over 99% of ART procedures. Sources: Fast Facts About Infertility. RESOLVE: The National Infertility Association; 2004 Assisted Reproductive Technology Success Rates. CDC; Assisted Reproductive Technology Surveillance—United States, 2003. CDC; 2004 Assisted Reproductive Technology (ART) Report: National Summary. CDC Trends in Infertility Treatment Growth in ART The chart to the right illustrates how the use of ART has increased significantly in the last decade. From 1996 to 2004 the number of ART procedures started almost doubled, from 64,681 to 127,977; and the number of live births due to ART increased more than 250%, from 14,507 to 36,760. In 2003, approximately 1% of the infants born in the U.S. were conceived through ART. Sources: 2004 Assisted Reproductive Technology Success Rates. CDC; Assisted Reproductive Technology Surveillance—United States, 2003. CDC 140,000 127,977 120,000 100,000 ART Procedures 80,000 64,681 60,000 40,000 Infants Born* 36,760 20,000 20,840 0 14,507 49,458 Live Birth Deliveries 1996 1997 1998 1999 2000 2001 2002 2003 2004 * The number of infants born exceeds the number of live-birth deliveries because of multiple-infant births. 2 Why Has ART Utilization Increased? Employer Economics ART utilization has increased because couples are increasingly using it to overcome their infertility, and it is indicated as the treatment of choice for an increasing number of infertility disorders. The increased use of ART combined with higher ART success rates have resulted in dramatic increases in the number of children conceived through ART each year. of Fertility Benefits Another reason ART utilization has increased is because of the growing trend for women to wait later in life before having a child. Since fertility progressively declines after age 30 in women, they are at increased risk for having a difficult time conceiving. Thus, delayed childbearing is a key driver of ART. Sources: Assisted Reproductive Technology Surveillance— United States, 2003. CDC; Moultry et al. Formulary. 2005;40;329-41. How Many Employers Provide Fertility Benefits? Employer benefit coverage for infertility issues varies considerably. Here are some examples. 59% Infertility Services 33% 37% Drug Therapy In Vitro Fertilization 25% Þ Large Employers Þ All Employers 19% 11% Source: 2005 National Survey of Employer-Sponsored Health Plans. Mercer Health & Benefits LLC. Risks of Infertility Treatment: Multiple Births, Preterm Births and Ovarian Hyperstimulation Syndrome Patients who undergo ART treatments are more likely to deliver multiple-birth infants or preterm infants than women who conceive naturally. Multiple births are associated with increased risks for mothers and infants, such as pregnancy complications, premature delivery, low-birthweight infants and long-term disability among infants. Another risk of ART is ovarian hyperstimulation syndrome (OHSS), a condition in which the patient’s ovaries become enlarged and produce too many eggs. Patients with OHSS need to be monitored closely by their healthcare professional (HCP). Progress on High Order Multiple Pregnancies First, it is important to note that IVF is not the major cause of multiple and/or preterm births. The majority of multiple births (60%) are a consequence of drug-induced ovulation combined with intrauterine insemination. As to high order multiple pregnancies associated with ART, their numbers have continued to decrease over the past five years as ART techniques have improved and the number of embryos transferred decreased. Sources: Assisted Reproductive Technology Surveillance— United States, 2003. CDC; Fritz MA. Contemporary OB/GYN. 2002;9:65-92. 3 Approximately 1/3 of all employers cover some type of fertility services—usually diagnosis and surgical treatment. Assisted reproductive technologies, such as IVF, are covered only 11% of the time. Top Three Reasons Why Employers Do or Don’t Provide Fertility Benefits Here’s what the latest research survey findings tells us about the reasons for employer coverage or noncoverage of infertility treatment. Why Employers Provide Infertility Treatment Benefits* 73% Ensure employee access to quality, cost-effective care 67% Be recognized as family friendly and attract employees 62% Increase morale and retain employees Why Employers Don’t Provide Infertility Treatment Benefits* 64% Concern about cost 29% Not employer responsibility 29% Provide only basic coverage and infertility treatment doesn’t qualify *Percentages do not total 100% because respondents could select more than one reason for coverage or noncoverage. Source: Employer Experience with, and Attitudes Toward, Coverage of Infertility Treatment. May 2006. Mercer Heath & Benefit LLC. How Much Does It Cost an Employer to Provide Fertility Benefits? Research has shown that when compared to total healthcare costs, the cost of providing comprehensive infertility services is negligible. Total Healthcare Benefit Cost Comprehensive Fertility Benefit Cost $591 PMPM1 $2.42 PMPM or 0.41% of total healthcare benefit cost2 2005 National Survey of Employer-Sponsored Health Plans. Mercer Health & Benefits LLC. Griffin M, Panak W. Fertility and Sterility. 1998;70:22-9. 1 2 State Mandates for Infertility Treatment Although there are no federal requirements pertaining to infertility treatment insurance, 14 states require employers to provide some type of infertility insurance coverage (the American Society for Reproductive Medicine (www.asrm.org) is a good source of information on this topic). However, by virtue of ERISA, employers that are self-insured are exempt from any state infertility treatment mandates. What has been the impact of the mandates? One study3 found that in states that do not require insurance coverage for IVF, more embryos were transferred per cycle, and there were higher rates of multiple births. It also concluded that multiple births as a percentage of total births might be expected to decrease with mandated IVF insurance coverage. The study further noted that the additional cost of covering IVF is likely to be only a small fraction of total health insurance costs. Another study pointed out the unintended consequences of NOT having a mandate: “limiting the number of ART attempts could motivate clinics to maintain policies of transferring numerous embryos as a way of increasing success rates for couples who cannot afford numerous ART attempts.” 4 Jain T, et al. New England Journal of Medicine. 2002;347:661-6. Griffin M, Panak W. Fertility and Sterility. 1998;70:22-9. 3 4 Key Issue: Multiple Embryo Transfers Multiple embryo transfers (the number of embryos transferred may exceed two, but varies widely by patient and practitioner) is a common practice in the U.S. The number of embryos transferred is largely unregulated in the U.S., although the American Society for Reproductive Medicine has issued practice guidelines regarding the number of embryos to transfer. In contrast, the number of embryos transferred is limited by law or by insurance plans in some European countries. FASTFACTS for Employers on Infertility Treatment Infertility treatment is determined by the diagnosis and may include the following: Þ Oral or injectable medications (ranging from $200 to $3,000 per cycle) Þ Surgery (tubal surgery can cost $10,000 to $15,000) Þ Assisted reproduction procedures (ranging from $10,000 to $25,000 per cycle) Þ A combination of these treatments Adapted from Benefit Manager Guide: Assisted Reproductive Technologies. National Business Group on Health. August 2006. Sources: Assisted Reproductive Technology Surveillance—United States, 2003. CDC; Van Voorhis. New England Journal of Medicine. 2007;356:379-86. 4 Fertility Benefit Strategies of Three Fortune 500 Companies Benefits decision-makers may sometimes wonder: “How are other companies dealing with infertility treatment? Is it a major issue for them? How much are they spending?” Here are three “real world” answers to those questions. Gillette Black & Decker J. Brooks Watt, MD, Corporate Medical Director of the Gillette Company, says that the company’s fertility benefit philosophy is simple: “provide the best/richest benefit that we can afford.” This translates into a fertility benefit that Dr. Watt describes as “liberal,” which means, for example, that there’s no dollar limit on the medical portion of the fertility benefit. On the other hand, the benefit does have some boundaries. Lifetime infertility treatment prescription drugs are capped at $25,000. All IVF procedures require prior approval by the company’s health plan and must be performed at one of seven approved facilities. There’s a limit of six attempted IVFs. It bears noting that Gillette’s fertility benefit benevolence is not because the company is located in Massachusetts, a state that mandates employers provide fertility benefits. Because Gillette is a self-insured company, it is exempt from that mandate. The company’s fertility benefit design reflects the desire of Gillette to “do the right thing” for the small number of its employees with fertility issues. Dr. Watt points out that by so doing Gillette provides a benefit to employees that has incalculable value for a relatively small cost. According to Ray Brusca, VP of Benefits at Black & Decker, “our company provides a generous but not unlimited fertility benefit.” Employees can utilize any physician or healthcare facility provider in their health plan’s network for infertility treatment. IVF is covered, and there’s no limit on the number of IVF attempts. However, there is a $25,000 lifetime limit on the medical portion of the fertility benefit. (Infertility treatment prescription drugs are managed through the company’s drug benefit and have no dollar limit.) Mr. Brusca has some telling observations about employers and fertility benefits. “When you put the cost of the benefit in perspective of how much we spend on MRIs and CT scans, for example, the cost of the fertility benefit isn’t even a rounding error.” Also, “employers who think there’s a lot of cost involved in covering infertility are mistaken. It’s not a cost driver. It’s an employee relations issue that’s a winner for all of us.” 5 Anonymous Fortune 500 Company Ms. Smith reports that her company currently does not offer any fertility benefits to its workforce (with one exception). Why not? One answer is that the benefit has never been offered. Another answer is that because the company is selfinsured, it’s exempt from any mandated fertility coverages. And on top of that, a significant portion of the workforce is located in states without a fertility benefit mandate. The previously noted fertility benefits exception is the approximately 7% of workforce at company headquarters who have access to one HMO plan that provides infertility treatment coverage due to a state mandate. This employee subpopulation is largely professional, more challenging to attract and retain, and the group from which infertility coverage questions have primarily originated. Finally, Ms. Smith makes the point that although her company does not currently provide fertility benefits for the large majority of its employees, “fertility benefits has become a dynamic issue for us and something we are evaluating.” This is in part because the company’s workforce is changing—becoming younger and more female. Also, although the current HMO arrangement for fertility solves the problem for a small subset of employees, it contradicts the company’s overall benefit strategy of moving away from fully insured health plans. Fortune 500 Company J. Brooks Watt, MD Ray Brusca Mary Smith Corporate Medical Director Gillette Company VP of Benefits Black & Decker Benefits VP Fortune 500 Company “We provide the best/ richest fertility benefit that we can afford.” “Our company provides a generous but not unlimited fertility benefit.” “Fertility benefits has become a dynamic issue for us and something we are evaluating.” Comparison of Three Companies’ Fertility Benefits Benefit Design Element Description of benefit Covered lives (employees + spouses + dependents) Dollar limit on medical infertility treatment Limitations on infertility treatment – provider or facilities? Dollar limit on pharmacy infertility treatment Infertility diagnostic tests covered Gillette “Liberal” “Best benefit we can afford” Black & Decker Anonymous Fortune 500 Company “Generous but not unlimited” None for >90% of workforce 19,000 23,000 None $25,000 lifetime Provider: No Facilities: Yes Provider: No Facilities: No $25,000 None Yes Yes Intrauterine artificial insemination covered? Yes – No limit on attempts Yes – 6 attempts limit In vitro fertilization covered? Yes – 6 attempts limit Yes – No limit on attempts Use rate of fertility benefit? (claimants per covered lives) 0.18% 0.8% Cost per fertility benefit claimant $6,000 $6,100 Estimated PMPM cost of fertility benefit $0.89 $4.04 30,000 NA for >90% of workforce Specific elements of fertility benefits for <10% of workforce with coverage determined by MCO in which they are enrolled 6 Findings and Questions from Employer Fertility Benefits Advisory Board In June 2006, a Fertility Benefits Advisory Board was conducted with attendance by representatives from ten Fortune 500 employers. The meeting started with the HR, benefits and corporate medical executives attending the session describing their companies’ fertility benefits. Then, invited speakers made presentations on clinical and financial issues pertaining to infertility treatment and responded to participants’ comments and questions on the information that had been presented. Major Findings of the Advisory Board Þ 8 of 10 participants’ companies provided fertility benefits, but elements of coverage varied widely. For companies that provided fertility benefits, the majority had lifetime caps on both the medical and drug benefits, or the medical or drug benefit, but not both. Some companies covered IVF, others did not, and for those that did, the number of IVF cycles varied from one to unlimited. Þ The primary reasons participants’ companies provided fertility benefits were because the benefit was consistent with their company’s overall benefits philosophy and/or to retain employees and/or to remain competitive in their labor market. Þ 9 of 10 participants said that their company was self-insured, and thus was exempt from any state mandates for providing fertility benefits. This means that since 80% of participants’ companies provided fertility benefits, most participants’ companies were providing a benefit that they were not obligated to provide. Þ Participants’ companies were handicapped in their ability to make data-driven fertility benefit decisions. Why? Their fertility benefit utilization and cost data were hiding in plain sight amid aggregated benefits data. Key Employer Questions from Advisory Board Þ “How do we get a better understanding of infertility procedures and medications to determine if controls or guidelines need to be established?” Þ “Aren’t physicians abdicating their ethical and professional responsibilities when they overuse fertility drugs or implant excessive numbers of embryos?” Þ “How can we ‘connect the dots’ between maternity costs and fertility costs?” Gaps in Knowledge and Data Make Informed Fertility Benefits Decision-Making Difficult Employers’ fertility benefits status quo 7 What employers need for fertility benefits decision-making • Lack of knowledge about fertility issues • Education about fertility clinical/financial issues • Absent, minimal or confusing internal data • Information on best practices in fertility benefits • No external benchmarks • Internal maternity and fertility-specific benefit data • Fear of the unknown and cost control • Integrated data Creating a Contemporary Infertility Treatment Benefit Advice from an Infertility Treatment Founding Father Howard W. Jones, Jr., MD Professor Emeritus, Eastern Virginia Medical School, Professor Emeritus Johns Hopkins University School of Medicine, Honorary Chairman of the Jones Institute Foundation Dr. Jones and his wife were responsible for the first successful IVF pregnancy in the United States. Explaining why Howard W. Jones, Jr., MD, is a true luminary in the field of reproductive medicine would take up most of this monograph. Suffice it to say that he has been practicing in the field of reproductive medicine for over 60 years; he and his late wife, Georgeanna Seegar Jones, MD, were responsible for the first successful IVF pregnancy in the United States; he is an author of 284 scientific papers on reproductive medicine issues; and the Jones Institute for Reproductive Medicine at the Eastern Virginia Medical School (www.jonesinstitute.org ) is named in honor of Dr. Jones and his wife. In addition to his daily work with patients on the medical frontiers of reproductive medicine, Dr. Jones has also been at the forefront of fertility benefits issues. He is intimately knowledgeable about the clinical, emotional and financial consequences of employer fertility benefits decisions. He knows how the behavior of patients with infertility problems can be influenced by whether or not they have insurance coverage. In that regard, here are two important infertility treatment issues about which Dr. Jones believes employers are not fully informed. Surreptitious Diagnostic Codes and Hidden Costs Dr. Jones believes that infertility can be, and is, often unknowingly reimbursed by health insurers under surreptitious diagnostic codes. That is, when treating a patient without fertility benefits coverage, some physicians creatively mask their infertility treatment services under reimbursement codes that they know will be reimbursed. For example, a patient with infertility who at the same time has asymptomatic endometriosis may be diagnosed and treated under endometriosis diagnostic and treatment codes, despite the fact that the patient’s principal reason for seeking treatment was infertility. Insurers and the health plan sponsors pay for infertility treatment costs such as unrecognized or hidden costs when infertility treatment is specifically excluded under the patient’s insurance coverage. Obsolete Therapies Dr. Jones also points out that “since IVF is frequently not covered by insurance, it can create a dilemma for physicians who want to help patients who lack coverage but are desperate to bear children.” Regrettably, these circumstances can cause certain physicians to use inappropriate or obsolete therapies to treat infertility. They do so because they know these less effective therapies are likely to be reimbursed by the insurer. For example, a provider treating a patient who is a bona fide candidate for IVF, but who lacks insurance coverage for IVF, may use ovary-stimulating drugs in excess of clinical guidelines in order to increase the chance of the patient conceiving. This practice increases the risk for multiple and/or preterm births, both of which employers pay for, whether fertility treatment was a covered benefit or not. “Jones Fertility Benefit Model” Based on his decades of experience, Dr. Jones believes that if the diagnosis and treatment of infertility were covered by all employers, patient outcomes would be better and the cost for treating patients kept the same or reduced. This would be true because such uniform coverage would eliminate or greatly reduce the perverse financial incentives currently in the system that can encourage multiple embryo transfers and the resulting risk of high order pregnancies and multiple births. As Dr. Jones sees it, creating a contemporary infertility benefit for self-insured employers would be costeffective while making more effective services financially accessible to employees. Savings would be realized by eliminating hidden infertility costs, eliminating payments for ineffective treatments, providing coverage for effective contemporary treatments, and reducing costs associated with multiple pregnancies by reducing the number of embryos transferred. The key features of the “Jones Fertility Benefit Model” are presented below. Two of these features really stand out: • Services must be provided by certified infertility treatment providers AND • The cost of infertility medical procedures and medications will be shared by the employer and the employee 8 Key Features of a Contemporary Infertility Treatment Benefit As recommended by Howard W. Jones, Jr., MD, and Brian Allen* Covered Services Þ Þ Þ Treatment only for documented infertility of at least one year’s duration Services must be authorized and delivered according to determinations of medical necessity Þ Facilities and providers must be certified by the insurance plan Þ Providers must receive preauthorization for proposed services in advance of treatment Þ Insurance plan will provide providers with detailed instruction on coding and billing issues Example services include: • Consultations • Office visits, laboratory and/or radiologic procedures Non-Covered Services Þ Medically unnecessary services such as those with less than 5% chance of success for a live birth Þ Treatment to reverse voluntary sterilization • Embryo transfer (fresh or frozen)— no cycle limit Þ Costs associated with gestational carrier and surrogacy cycles Example services requiring Reproductive Endocrinologist guidance and criteria: Þ Experimental or investigational infertility treatments • Intracytoplasmic sperm injection (ICSI) Þ ZIFT and GIFT • Standard evaluation per American Society of Reproductive Medicine • In vitro fertilization oocyte (unfertilized egg cell) retrieval—limited to 6 stimulated cycles Þ • Cryopreservation of embryos and sperm • Donor sperm and egg/embryo • Pre-implantation genetic diagnosis (PGD) Employer and Patient Cost-Sharing Þ Facilities and Providers Þ Medical providers must be boardcertified reproductive endocrinologists Þ Covered services to be performed by facilities that conform to the American Society of Reproductive Medicine’s current standards and guidelines Appropriate cost management and sharing strategies for deductibles, copayments/coinsurance, out-ofpocket maximums, lifetime medical/ medication dollar or number of cycle caps * Brian D. Allen, Allen Consulting Incorporated. More information on fertility benefits guidelines from Dr. Jones and Brian Allen is available from Brian Allen at [email protected]. 9 Key Issues for Informed Fertility Benefit Decision-Making 1. Over 15% of women of reproductive age in U.S., approximately 9.3 million, have received some level of infertility treatment. 2. Approximately 1/3 of all employers cover some type of fertility services—usually diagnosis and surgical treatment. Assisted reproductive technologies, such as IVF, are covered only 11% of the time. 3. The cost of providing a comprehensive fertility benefit ($2.23 PMPM) is almost inconsequential compared to the overall cost of health benefits ($591 PMPM). 4. Most employers’ ability to make informed decisions about fertility benefits is hampered by lack of maternity and fertility-specific internal data and external benchmarks and best practices. 5. According to a renowned infertility treatment specialist: Þ Due to the billing and clinical creativity of some physicians, employers sometimes pay for infertility treatments even when they are not a covered benefit, and for outdated or ineffective infertility treatments. Þ Uniform coverage of infertility treatment by employers would improve fertility outcomes for the same or reduced cost. This would be true because such coverage would eliminate or greatly reduce the perverse financial incentives currently in the system that can encourage multiple embryo transfers and the resultant high order pregnancies and multiple births, both of which can have huge cost consequences for employers. Action Items for Informed Fertility Benefit Decision-Making Step 1: Document current coverages. What infertility treatment services are covered? Which ones aren’t? What’s the history behind current fertility benefits? Step 2: Run the numbers. Identify, collect and analyze company’s fertility-specific data. How many fertility benefit claims are there? What’s the total and per claimant cost? What’s the trend? What specific infertility treatments are being used? Step 3: Get benchmarks. What comparative fertility benefit metrics can your company’s benefits consultant or health plan(s) provide? How about fertility benefit best practices examples? Step 4: Ask the tough question. Once educated and updated on your company’s current fertility benefit, ask: Is the company’s current fertility benefit (or lack thereof ) appropriate? Is it consistent with the company’s corporate culture? Is it based on a rational decision-making process? Is it up to date considering the current workforce? Step 5: Make informed decision. Based on the outcome of Steps 1-4, keep, modify or update fertility benefit. Reevaluate company’s fertility benefit annually to keep it up to date. 10 This report made possible by the financial support of Organon, a part of Schering-Plough. About Schering-Plough Schering-Plough Corporation is a global science-based health care company with leading prescription, consumer and animal health products. Through internal research and collaborations with partners, Schering-Plough discovers, develops, manufactures and markets advanced drug therapies to meet important medical needs. Schering-Plough's vision is to earn the trust of physicians, patients and other customers. Following the acquisition in November 2007 of Organon BioSciences (OBS), a Dutch human health (Organon) and animal health (Intervet) company, Schering-Plough now has approximately 50,000 colleagues around the world. Our products reach patients and caregivers in more than 120 countries. Copyright © 2008 Schering Corporation, Kenilworth, NJ 07033. All rights reserved. Printed in USA FQN0001B 2/08
© Copyright 2024