Bonus Pod: The Supreme Court Apparently Thinks Your Birth Control is Your Boss's Business

ICYMI: On Wednesday, June 8th, 2020, the Supreme Court ruled that institutions and employers are exempt from the Affordable Care Act’s birth control mandate, which requires employers to provide contraception coverage with no co-pay through insurance plans, as long as they reference a religious or moral opposition. Mara Gandal-Powers, Director of Birth Control Access and Senior Counsel at the National Women’s Law Center, sits down to talk with us about the most recent birth control-related Supreme Court ruling and how this tramples the health and rights of many across the United States.

The Supreme Court held that the Trump administration did have the authority to issue the rules about the ACA’s birth control mandate coverage. This ruling is problematic for a variety of reasons, including this major health care related case taking place during the middle of pandemic, the fact that birth control has been singled out amongst other basic healthcare, employer-mandated insurance coverage in general, and the state of our healthcare system in the U.S. This ruling, if not prevented from advancing throughout the courts again, could have a disastrous impact on folks across the country. In fact, hundreds of thousands of people could lose their coverage of contraception and birth control methods would be considered completely out-of-pocket. For reference, IUD’s can cost over $1,000, and brand-name birth control pills can cost over $100 per pack.

So, what’s next? Since the release of the opinion, Representative Diana DeGette (D-CO-1) announced that the House would consider legislation that would rescind these harmful Trump rules regarding contraception. If there is a change in presidential authority in the November election, that provides another avenue to possibly overturn the rules.

Links from this episode

National Women’s Law Center on Facebook
National Women’s Law Center on Twitter
More information on Little Sisters of the Poor Saints Peter and Paul Home v. Pennsylvania
CoverHer
President and CEO Fatima Goss Grave’s Recent Op-Ed
Wait…It’s 2020 and We’re Still Fighting Over Birth Control? Podcast Episode

Transcript

Jennie: Welcome to RePROs Fight Back, a podcast where we explore all things reproductive health, rights and justice. I'm your host, Jennie Wetter, and I'll be helping you stay informed around issues like birth control, abortion, sex education and LGBTQ issues and much, much more-- giving you the tools you need to take action and fight back. Okay, let's dive in.

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Jennie: Hi and welcome to a special bonus episode of Repros Fight Back. I'm your host, Jennie Wetter, and my preferred pronouns are she and her. So this week we had the birth control benefit decision at the Supreme Court. So we're going to have a special bonus episode talking about that, but before we get there, I wanted to touch on something that, you know, we've been doing on the podcast, but wanted to be more explicit about, and that's the importance of language and making sure that we're using as inclusive language as possible. So one of those things that you may have noticed recently is having people introduce themselves with their pronouns and making sure to give my preferred pronouns, you know, this is one of those things that it's just, it's just basic kindness to make sure that you're using people's preferred pronouns. And one way to do that is when you're introducing yourself to give yours and this way we're not putting the onus on people who have pronouns that are different than how they may present that way you are taking kind of some of the stigma out of it. So it's really important that we are trying to normalize it. That is one way we are doing that. But another way we are making sure is that when we talk about, you know, not just women, right? So when we talk about birth control or abortion or pregnancy, we really try to talk about people because women aren't the only ones who need birth control. They aren't the only people who get pregnant. They're the only people who need abortions. So it's just really important that we are being as welcoming and inclusive as possible. And that's not the only place that it matters, right? So, you know, another place where you can really see some stigmatizing language and you might not even think about it or realize it is a lot of language being ableist, right? So common phrases like “tone deaf” or “turning a blind eye to” are just basic things to try to get out of our vocabulary because they are really ableist. So it's things that I have been trying to work on. And, you know, every once in a while, I will still slip and they will work their way back in. One of the hardest ones is getting “you guys” out of my language, this is when I find myself slipping on a lot or using “crazy.” There's just a number of things that, you know, it's helpful to think about and try to work on getting them out of our language so that it's a more welcoming and inclusive environment for everybody. And it's just, it takes work and thought. So, you know, just wanted to be clear about the steps we're trying to take, we'll have probably at some point have a fuller podcast on language and using inclusive language. It's something I've wanted to do for a long time. And I wasn't gonna do the, having people introduce themselves with their preferred pronouns until we had that episode, but that episode keeps getting pushed and it hasn't happened. And then we're going longer and longer and not doing it. And so it was really important to me that we just stop, stop waiting and just make it happen. And then we can have the fuller conversation at a later date when I have time to make that happen. You can always work on changing yourself right away and finding the things that you need to work on. You know, at first talking about “pregnant people” or “people who need birth control” may not roll off your tongue easily, where you might be so used to only talking about women in these spaces. So, you know, it's, it's something that you have to work on and the more you do it, the more it gets easier.

Jennie: Right? At first I had to really kind of think to make sure that's what I said. And now whenever I hear somebody talking about something that's so woman-centric, I just get this like internal cringe because that's not how we would talk about it. And because the change has just become so innate. So just take the time and make the effort. It is not that hard of all the changes we need to make in the world right now, just doing some basic considerate ones. Like this are a pretty easy one. So I think that's where we're going to, and for that part, you know, I think another thing just to be clear on, I think I haven't said it recently is just being sure you're wearing a mask when you're going out. It's just really important to make sure we're keeping everybody safe. You know, we've seen such big spikes of COVID recently that it's just really important we're all doing our part and that is if we're going out, making sure you're wearing a mask, it's such an easy thing to do. It may be inconvenient, but in the grand scheme of things, it's really a simple thing to do to keep everybody safe. So make sure you're slapping a mask on when you go out. And with that, we'll turn to this week's interview where I talked to Mara Gandal-Powers at the National Women's Law Center. And we talk about what happened at the Supreme Court on Wednesday. We don't do like a deep dive into the back history of the birth control benefit in this episode, Mara and I have had that conversation before. So if you want kind of the backstory for like where it came from, how we got to the point we're at now, we'll make sure to include that episode in our show notes, because you can go back and listen to that and learn how we got to where we are today. We really just focus on what exactly the court was deciding, what the decision was and what happens going forward in the episode. So if you want kind of a longer backstory, you can absolutely check out an older episode from a couple of months ago where I talked to Mara more about the history and that will be in the show notes. And with that, I will turn it to my interview with Mara, enjoy.

Jennie: Hi Mara. Thank you so much for being here today.

Mara: Thank you for having me back, Jennie, and yeah, I'm very happy to be here, although I wish it was under better circumstances.

Jennie: Yes. Same. Do you want to do a real quick introduction, including with your preferred pronouns?

Mara: Absolutely. So I'm Mara Gandal-Powers and I use she/her pronouns. I am at work with the National Women's Law Center and I'm our director of birth control access and senior counsel. So that means I sort of do things related to birth control across our work. So federal level, state level, legislative regulatory, and a little bit related to litigation, which is what brings me here today.

Jennie: Great. So we already talked about the birth control case that was in front of the Supreme Court kind of in depth recently. So maybe instead of doing like a super in depth, like what was the case about, we can do like a real quick, what was the case about, and then people can, if they want more of like the background, they can go and listen to the other episode that we’ll link.

Mara: Yeah, that, that sounds good. So, you know, the quick and dirty version of what the case was about is the Trump administration issued rules that created very broad exemptions to the Affordable Care Act’s birth control benefit. So they created a religious exemption, any moral exemption that virtually any employer or university could be eligible for, there've been a number of lawsuits filed against those rules. The one filed in Pennsylvania and New Jersey is the one that made its way up to the Supreme Court that had the decision that came out yesterday as the day of our taping yesterday. And, you know, the case itself was about whether the Trump administration had authority to issue the rules, whether they were properly issued as well as whether the lower courts can issue nationwide injunctions. And there were some issues around the Little Sisters of The Poor and whether they could intervene in the case.

Jennie: So that is the quick version of it. All right. So let's talk about, so what, what happened on Wednesday?

Mara: Yeah, so what we saw was it was not a win for Pennsylvania and New Jersey. I will start with that, essentially the Supreme Court held that the Trump administration did have authority to issue the rules about birth control coverage. And they had that authority under the ACA. The other piece that the majority said, and it was a majority opinion authored by Justice Thomas, was that there were no violations of the Administrative Procedures Act in how the rules were issued. And then we saw, you know, in the concurrence by Justice Alito and Justice Gorsuch, they would have gone even further. You know, they joined Justice Thomas's opinion, but Justice Alito and Gorsuch would have also held that an exemption to the birth control rules is required under the Religious Freedom Restoration Act. The full majority did not go that far, but Justices Alito and Gorsuch did and Justices Kagan and Briar also filed a concurring opinion concurring in the judgment. And what’s important about their concurrence is that it made very clear that there are some other claims which remain outstanding and could proceed. And we can talk about that a little bit more, but it does what that actually means in terms of the procedures that this case is not done. It was remanded and sent back down to the district court. And the Pennsylvania attorney general has said they will continue to fight this case, which is really good. And they've been a great advocate in all of this, but that is, that is a big part of what folks should know about what happened on Wednesday. And I think another important part, you know, yet again, in a birth control case, we're seeing Justice Ginsburg in a dissent this time joined by Justice Sotomayor and really strongly dissenting saying that neither the ACA nor RFRA authorize or require the exemptions and really highlighting the impact that the rules will have on, on real people out in the world and particularly on women and how important access to birth control is in their lives. It's the only place that we saw that coming up in the opinion. And that's pretty, you know, it's pretty scary that you could have seven other justices in the other parts of the opinion, not even touching on that really. We only saw it in the dissent. So that's what was in the bulk of the decision.

Jennie: Yeah. I mean, that's really striking right. That seven of the justices didn't even mention how this would impact the people who need access to birth control.

Mara: Yeah. I mean it's, and it, isn't, it's very striking, particularly in contrast to the way that the justices talked about the Little Sisters of The Poor, right? The Little Sisters of The Poor are, were involved in this case because they were trying to intervene. They are a group of nuns who run homes for people who need assistance in their lives. And so they're a very compelling group. And, uh, but when you look at the actual language that ustice Thomas in particular used to describe them, it is with great reverence and great deference to them and their work, as opposed to necessarily the actual issues at hand in the case. But that is really contrasted with what Justice Ginsburg invested. So to my, or whose focus ultimately is on the people who work at the Little Sisters of The Poor, you know, they don't say it in those words, but they're talking about people who need insurance coverage through their job to get access to birth control in order to, you know, be the equal in society. And, and that's a really stark contrast, right? Because the folks who work at Little Sisters of The Poor, most of them are not sisters or nuns. Most of them are regular people doing regular jobs that people do at assisted living facilities, right. They are nursing aides, they are cooks, they are on cleaning crews. Like they are regular people. And particularly right now in the middle of a public health crisis and an economic crisis, like those are the folks broadly that we are really worried about the impact of these Trump rules. So that, that contrast in particular was striking to me.

Jennie: Well, yeah. And I think also just really striking was having this happen in the middle of a public health crisis.

Mara: Yeah. Yeah. I mean, we've been saying, and you know, many folks have been saying, as we've been saying, it's like, this is not the time for less healthcare. This is the time for more healthcare. And I think, you know, the, the crisis we've been seeing over the last several months has been highlighting just how problematic our health system is. Our public health system is, and the ways that it plays out and the disparities that are already existing. But I think this case also highlights at times how problematic it is that we still have a system where your health insurance is tied to your employment. You know, now because of this, your birth control coverage is up to whether your boss agrees with it. Or, and that's, you know, because we have this system where health insurance is tied to your employer. So that is, you know, fundamentally really problematic

Jennie: And also worth mentioning. You know, we've definitely done this in prior times, we've talked, but just that birth control itself being singled out is pretty outrageous.

Mara: Yeah. I mean, you know, right now in particular, and we've seen more, especially in the last several weeks and months, since, since we recorded our last podcast, but you know, there's been more and more evidence coming out and more studies and papers coming out, talking about how during past pandemics or past economic crises or public health crises, more and more people are looking to prevent or delay pregnancies. And, you know, in order to do that, you have to have access to family planning and to healthcare broadly. And you know, this is what people… we know people are going to want based on past experiences is to delay and prevent pregnancy. And when you don't have access to birth control, that makes it is really difficult to do. You know, and obviously, you know, there's folks who will come in and say like, just “shut your legs”. Like that's not realistic. Right? We know that. And also people have a right to enjoy sexual pleasure. Like I think that's an important thing as well that people who can get pregnant have a right to enjoy that as much as people who can't get pregnant and don't have to worry about the consequences of a pregnancy for their lives. So I think that's, that's an important part of this.

Jennie: Absolutely. And, you know, birth control is important no matter why you need it. So it absolutely needs to be covered because like you said, it's basic health care.

Mara: Yeah, yeah.

Jennie: So what is this ruling going to mean for people who are trying to access birth control?

Mara: Yeah. And I think this is where it gets a little confusing in part, because, you know, in some ways there's a little bit of a lack of information about some of the employers, but also there's some sort of wheels that need to turn in terms of what happens with the courts, right? So yesterday or on Wednesday, when the Supreme Court issued its ruling, there's a mandate that comes, goes from the Supreme court down to the district court and says, here's what we decided you should resolve the case accordingly. And that will deal with some of the claims, right? But as I said, there are remaining claims that are outstanding. And the Pennsylvania attorney general has said that they will continue to pursue those claims in court. So, you know, we're there nothing to happen in the lower courts as a result of what the Pennsylvania attorney general says, the Trump rules or does the Trump rules will go into effect. There could potentially be something that stops them again. But I also want to want to point out that there were, there are several other cases across the country that have been stayed, sort of put on hold until this birth control case. The Pennsylvania attorney general's case was determined at the Supreme Court. So there were cases filed by the California attorney general joined by, by many other states. Um, the Massachusetts attorney general, and then my organization, the National Women’s Law Center, along with Center for Reproductive Rights and Americans United for Separation of Church and State, we are representing a group called Irish for Reproductive Health. It's a group of folks at University of Notre Dame in a case against the rules and the university. And all of those cases have pieces that could still continue to move. So, you know, this is yesterday was a loss, but this fight is not over. You know, if the rules do go into effect, if nothing happens in the lower courts and they do go into effect, there will be hundreds of thousands of folks who probably do lose coverage or don't have coverage as a result of the rules. For some folks, they will particularly focus in like larger employer plans. They should get notice that they are losing that coverage. So, you know, if you are someone or, you know, someone who is concerned that that might be something that's happening to them, we are really encouraging people to, you know, pay attention to the envelopes that come in the mail from your insurance company. Sometimes I know it's really easy to just sort of like put them to the side in a pile and not look at them for awhile, but it is really important to look at those and, and know what's happening and, you know, really document what you're hearing from your employer, because, you know, the last thing we want to have happen to folks is for them to show up at the pharmacy to pick up their prescription and not have any coverage. And I think that's, that's the reality that folks really need to realize. It's not just that you go back to having, you know, a $10 copay as opposed to no cost sharing. It's that your birth control is treated as if it's not even healthcare. It's not in your insurance at all. So whatever you're seeking, it's completely out of pocket. So, you know, over a thousand dollars for an IUD, for some of the brand name pills that are out there, you're spending more than a hundred dollars per pack. Like it is, it is a huge expense in people's lives. And even when it isn't a huge expense, even if the pill you like as a generic pill, that without coverage, you can still get for not much particularly now in an economic crisis, those small out-of-pocket costs can mean people don't get their pills when they need them. So it's very, we're very concerned about sort of how this is going to play out. And when we're going to start seeing folks not able to access with the care they need.

Jennie: Yeah. Again, it's the striking miss of like against a pandemic and economic crisis and social safety nets being cut with, you know, attacks on Title X and other things that are already making birth control harder to get for particularly low income people.

Mara: Yeah. It's, you know, and that is the government and folks who have opposed the birth control benefit for years have said, oh, you can, anyone can walk into a Title X clinic. Anyone can, you know, use, you could use Medicaid. You know, even in Justice Alito’s opinion, there's a reference to Title X and Medicaid, and even TANF, you know, Temporary Assistance for Needy Families. These are all already doing family planning. And like, yes, that is true. But that is, that is not actually the original intent of TANF in the first place, but those are already stretched. Then they're not meeting. They already were not meeting the needs before this administration has decimated the family planning network and undermined Medicaid. And, you know, it is now with this, with these crises around us, even more people are going into, you know, seeking a system that couldn't meet the needs, that, that we're already putting the pressures on it. So they're going to many people who end up without getting, not getting the care. And particularly for those who, who were already relying on these systems and for whom, you know, for a lot of folks, the Title X network is their only source of care all year long, right. That's that is the only provider they see, you know, if they are squeezed out because other folks have to, you know, the needs of many others need to be met as well. That means our folks were not getting any care in the middle of a pandemic. And that's, you know, that is not the world we want, but it's the world we're in right now.

Jennie: That's really depressing to think about. And hopefully we won't get there, but that leads us to clearly what's next?

Mara: Yeah. Yeah. So part, I mean, part of what's next, I would say in the immediate short term, right. Is it seeing what happens in the lower courts with all these cases? And I think, you know, I'm, I'm really heartened that the Pennsylvania attorney general is so dedicated to not just this case, but to supporting access to women's healthcare broadly. So I think that we have a really good ally there, you know, just yesterday after the opinion came out Representative DeGette announced, they, you know, the House would be introducing a bill to rescind the Trump rules. And I expect, we'll see something similar from the Senate soon. And that is a way that this could be, be dealt with, right. If Congress says these rules are rescinded like that, that could be a way that it's dealt with. You know, I think one small silver lining in all of this is that, you know, the, the majority did say that the administration had authority to issue these rules under the ACA. And that means, you know, another administration has that authority to, so should we see a change in administration after the November election? There's potential to change, change the rules there, but you know, this has not been a short fight up until now. And I, you know, I predict that there will be a lot of work to do over a period of time, you know, still to come to make sure that not only do we make sure everybody gets the birth control coverage they need, but that, you know, that it's really working for them as well.

Jennie: Honestly, I struggled to remember a time when we weren't fighting over this birth control benefit.

Mara: It's basically been my whole legal career.

Jennie: Well, I think, wow. I basically, this has been going almost since I started working in repro.

Mara: Yeah, yeah, exactly. And the thing that's, you know, for me, what's interesting too, is I think about, you know, not just my legal, but like the years that I've been doing work in repro, even when I was like back in college, what were we fighting about? There you're like EC wasn't over the counter yet, Plan B was not over the counter yet. And you know, one of the things that I did when I, when I was in college was going to the state house and giving testimony about why pharmacists in, I was in college in Maine, why pharmacists should be able to have prescription, you know, the ability to, uh, to prescribe EC and, you know, the people who were there saying they shouldn't where they're arguing that EC is an abortifacient, which is essentially some of what we're dealing with here, right? Like they think IUD and EC are abortifacients. It's the same thing, the same thing all over again. And you know, we're still here and we're going to keep fighting this because, you know, we have like, people want birth control. They want birth control coverage. They want to be able to get birth control coverage. They want other people to be able to get birth control and when they need it, it's a popular thing. You know, there's, there's that often cited, you know, 99% of sexually active women have used birth control. Like it's so common. And so non-controversial in people's everyday lives, most people's everyday lives. And yet here we are. And I think that's because it is sort of a proxy for being able to be an equal part of society. Right. Being able to do the same things as people who can't get pregnant from sex would do with their lives. So I think that that's a huge part of it.

Jennie: Absolutely. Okay. So now that we know everything that happened and looked at some of the things that are coming and what is next, is there anything listeners can do? Is there any actions they can take right now?

Mara: Yeah, I think, well, you know, right now we are sort of in this time period, after a number of different Supreme Court opinions related to reproductive health and equality and gender discrimination broadly, and I think there are, you know, a number of bills that we will see coming up. And I think as those, as there are activities around the Equality Act, the Women's Health Protection Act, the bill that Representative DeGette is introducing related to, you know, the birth control rules. I think letting your members of Congress know, and I will give a plug as a DC resident-- I don't have voting member of Congress--so I would love if you, if you are not a DC resident to call your member of Congress and tell them to support these things, you know, it's important for all of us. I think that's certainly one thing. I think, making sure, you know, making sure that folks broadly know where we've gone in the last six years, right. In 2014, the makeup of the court, then we had a decision that said, yes, this violates Hobby Lobby's rights, but people still need to be able to get their birth control. The court shifted. And in 2016 we had Zubik and, you know, Justice Kennedy was still on the court. Justice Scalia had passed and we got, you know, sort of a non-decision it got sent back down saying, make sure that we do accommodate people's religious objections, but also make sure people get birth control coverage. And now we have two different justices on the court, Justice Gorsuch, and Justice Kavanaugh. And, you know, that's part of what we're seeing here is this shift. And I think that's an important thing for people to know, right? Like it is, these are the results of, of having different justices there and justices who are not looking at the impact on women, that, that seemingly can ignore that when they are joining an opinion and deciding how they think about this case. So that is, that is a sort of big picture takeaway, I think.

Jennie: Yeah. And I think it's also good to say all is not lost, right? Like there are still steps to be taken and, you know, we had, there was a not great decision this week, but it wasn't the end.

Mara: Yeah. All is definitely not lost. I mean, I think, you know, it is, it is very troublesome that this is what we're dealing with. It is not shocking that this is what we're dealing with because we know the makeup of the court. Right. But you know, it, I think it can be easy for folks to think…um, particularly folks who aren't, you know, in the weeds with the court to have seen the headlines on June Medical and to have seen the headlines on Title VII and not think about the court as something that they need to necessarily care about and think, “well, maybe things really aren't that bad up there.” This isn't all lost. This is the direction that, that things are going in terms of, you know, creating exemptions. And that is, that is really worrisome, right. This opens the door for that.

Jennie: Yeah. And you know, it was a callback to Title VII, right? Like that was a good decision, but that mean that there couldn't be people coming in having, trying to carve out religious exemptions. And this is kind of a flag that the court might have.

Mara: Absolutely. I mean, you know, that was a, it was a great decision and there is a line in it that says religious exemptions were not on the table here in front of us. That's the case for another day. And you know, it will be a case for another day. They will be hearing that case. It would be my prediction, you know? So I think that is that's where things are headed, you know, today's birth control and, and there'll be trying it in other places…

Jennie: Kind of a bummer to end on. But it's kind of what we're…

Mara: I mean, I think, you know, I think people should know like 61.4 million women have the birth control coverage, thanks to the birth control benefit, right? Like that's in one year they have that coverage, there will be several hundred thousand women who likely will lose coverage because of the Trump rules when they go into effect. So, you know, most people, because they work for businesses that do not have an objection or, you know, it's a business, so they don't have like beliefs like that, which is, I think probably most businesses don't have beliefs like that. Um, or they work for a business that proactively says, yes, this is good for our employees. This is good for our workplace for people to be able to have the healthcare they need. Right. Like that is what most people, their reality is going to be is that they, they are going to have this coverage, but you know, it could be someone, you know, who takes a job somewhere. And there's nothing about that company that would tell you before you get there that there's going to be an objection to your birth control coverage. And what do you do? Right? Like particularly in this economic crisis, jobs are going to be hard to come by. And if you need to take a job, you need to take a job. And everyone, no matter where they work should have that coverage. So I think it's, you know, affirming to people and broadly stating that, you know, this is not something that we are going to compromise on. This is something that needs to be part and parcel of anything moving forward. Right. If we're talking about broad changes to our healthcare system and our health coverage system, if we're talking about, you know, changes to these rules specifically, you know, people need birth control coverage. It's not rocket science, but this has made it much more complicated. And I guess the other thing I would say is, you know, we, we, for a long time have been running a hotline for people who have issues with their birth control coverage, often it's folks, you know, the plan's not covering the brand that they want, or they had posturing for their IUD insertion, but the IUD was not covered. And it's called CoverHer. Or, and if people have questions about what is happening with their coverage or they know someone who's having issues around their coverage that they think might be related to, uh, you know, an objection by an employer or a university, we are more than happy to talk with them. And, and that website and, you know, emails and forms and stuff are really good way to reach out to us so we can help them figure out what's going on.

Jennie: Well, that feels like a good place to stop. And we'll make sure to include that in the show notes. Thank you, Mara. Thank you so much for doing this again.

Mara: Of course, and I hope folks are, are taking care of themselves. It's been a rough few months. Um, and you know, we're, I'm glad to have this case behind us and that we're able to sort of like move forward with the next steps. So thank you.

Jennie: Thanks for listening everybody, that was the last of the Supreme Court cases that we have been waiting on. So that will be the end to some of these special bonus episodes for right now, we have maybe one more coming up about a bill that's going to be introduced that I'm really excited to talk about. So that'll be coming up in a couple of weeks, so stay tuned, but otherwise take care of yourselves, make sure we're being considerate and wearing masks.

Jennie: Thanks for listening everyone. And we'll see you on our next episode of RePROS Fight Back. For more information, including show notes from this episode and previous episodes, please visit our website at reprosfightback.com. You can also find us on Facebook and Twitter at RePROS Fight Back, or on Instagram at reprosfb. If you like our show, please help others find it by sharing it with your friends and subscribing, rating and reviewing us on iTunes. Thanks for listening.

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