PROCALCITONIN: ADVANCING DECISION MAKING IN SEPSIS Sean-Xavier Neath, M.D., Ph.D. Assistant Clinical Professor of Medicine Department of Emergency Medicine University of California, San Diego OBJECTIVES • • • • Explore the scope of sepsis, its costs and effects on the healthcare system Identify the difficulties associated with the rapid diagnosis of sepsis with a focus on the differentiation of bacterial from nonbacterial causes of SIRS Utilize the performance characteristics of the biomarker procalcitonin (PCT) as a marker of sepsis or significant bacterial infection Interpret PCT levels and understand current PCT utilization in the hospital 2 DISCLOSURES 1) Consultant relationships with biomedical companies working on biomarkers in acute disease states Thermo Fisher Scientific BRAHMS 2) Employed by the University of California, San Diego Medical Center as an Assistant Professor of Clinical Medicine, Department of Emergency Medicine 3 WHAT IS SEPSIS? • Whole Body Inflammatory State plus Infection 4 SYSTEMIC INFLAMMATORY RESPONSE SYNDROME (SIRS) • • • • • Systemic inflammatory response to a variety of severe clinical insults. Manifested by two or more of the following: Temperature >38ºC or <36ºC Heart rate >90 beats/min Respiratory rate >20 breaths/min or PaCO2 <32 mm Hg WBC >12,000/mm3, <4000/mm3, or >10% immature (band) forms ACCP/SCCM Consensus Statement. Chest. 1992;101:1644-1655. 5 SEPSIS: ACCP/SCCM DEFINITIONS • Sepsis • Systemic response to infection – i.e., confirmed or suspected infection plus 2 SIRS criteria • Severe Sepsis • Sepsis associated with organ dysfunction, hypoperfusion, or hypotension • Septic Shock • Severe Sepsis that cannot be resuscitated or stabilized with IV fluids alone ACCP/SCCM Consensus Statement. Chest. 1992;101:1644. 6 Slide Parasite Virus Infection Fungus Severe Sepsis shock SIRS Sepsis Severe SIRS Trauma Bacteria BSI Adapted from SCCM ACCP Consensus Guidelines Burns POPULATION ADJUSTED INCIDENCE OF SEPSIS (USA) Martin GS et al. NEJM 2003;348:1346 8 CASES OF SEPSIS BY PATHOGEN (USA) Martin GS et al. NEJM 2003;348:1346 9 INFECTION SOURCE IN SEVERE SEPSIS 10.8% 6.0% 8.0% 44.0% 2.2% 6.6% 8.6% 9.1% Respiratory Bacteremia GU Abdomen Soft tissue Device CNS Endocarditis Other 17.3% Angus DC et al. Crit Care Med. 2001; 29:1303 10 DETERMINANTS OF MORTALITY • • • Source control is most vital factor Resuscitation/re-establish perfusion in 6 hrs Appropriate antibiotic therapy within 1 hr of hypotension 11 TREATMENT OF SEPTIC SHOCK • • • • • Source Control When Possible Based on Early Goal Directed Therapy Broad, high dose, rapid administration of antibiotics Consider Activated Protein C Minimal role for steroids Surviving Sepsis Campaign: International guidelines for management of severe sepsis and septic shock, 2008. Critical Care Med 12 DIFFICULTIES IN DIAGNOSIS AND TREATING SEPSIS IN THE EMERGENCY DEPARTMENT • Differentiation between sepsis and non-infectious causes of SIRS is complicated • The large number of patients presenting to the ER at the same time can limit the ability to obtain comprehensive histories and physical examinations 13 DIFFICULTIES IN DIAGNOSIS AND TREATING SEPSIS IN THE EMERGENCY DEPARTMENT • Scoring systems and commonly available diagnostic tools provide limited value in determining which patients will have a poor outcome • Initial vital signs can be incomplete, an accurate core temperature can be lacking • These limitations often result in the delayed diagnosis of sepsis which in turn delays treatment, increases hospital length-of-stay, increases costs and leads to increased preventable mortality 14 DURATION OF HYPOTENSION BEFORE INITIATION OF EFFECTIVE ANTIMICROBIAL THERAPY IS THE CRITICAL DETERMINANT OF SURVIVAL IN HUMAN SEPTIC SHOCK Kumar A. et al., Crit Care Med 2006, 34:1286 15 FAILURE TO INTERVENE QUICKLY CAN BE FATAL Sebat CCM 2007; 35: 2568 16 Key Areas of Sepsis Management • • • • • • • • • Initial Resuscitation Diagnosis Antibiotic therapy Source Control Fluid therapy Vasopressors Inotropic Therapy Steroids Recombinant Human Activated Protein C (rhAPC) [drotrecogin alfa (activated)] Blood Product Administration Mechanical Ventilation Sedation, Analgesia, and Neuromuscular Blockade in Sepsis Glucose Control Renal Replacement Bicarbonate Therapy Deep Vein Thrombosis Prophylaxis Stress Ulcer Prophylaxis Limitation of Support Dellinger, et. al. Crit Care Med 2004, 32: 858-873. 17 ROLE OF PROCALCITONIN IN INITIAL SEPSIS MANAGEMENT WHY PROCALCITONIN? Integrated use of PCT with other clinical and laboratory information permits: • Increased accuracy of clinical diagnosis of relevant bacterial infection / sepsis • Improved clinical decision making and patient management 19 PROCALCITONIN – A BIOMARKER FOR THE ASSESSMENT OF CRITICALLY ILL PATIENTS AT RISK FOR SEVERE BACTERIAL INFECTION AND SEPSIS • • • Simple blood test specific for bacterial infection During severe bacterial infections and sepsis, blood levels rise rapidly (up to x100K) – no elevation from viral infections Is the Standard of Care for much of Europe in the management of infection and sepsis Morgenthaler N. et al., Clin Lab 2002, 48: 263-270 20 PROCALCITONIN – NORMALLY AN INTERMEDIATE PRODUCT IN THE SYNTHESIS OF CALCITONIN Thyroid After P. Linscheid, Endocrinology 2003 N-Pro Calcitonin Katacalcin N C 1 57 60 91 96 116 LOW PCT values in the blood of healthy persons: 46.7 pg/ml (97.5 percentile); median = 12.7 pg/ml* Morgenthaler N. et al., Clin Lab 2002, 48: 263-270 21 PROCALCITONIN – PRESENCE OF BACTERIAL INFECTION STIMULATES PCT PRODUCTION Alternative synthesis of PCT • Bacterial toxins (gram+/-) and cytokines stimulate production of PCT in all parenchymal tissues • PCT is immediately released into bloodstream • This process can be blocked during viral infections Adapted from Christ-Crain et al. 2005 22 HIGHLY SPECIFIC INDUCTION AND RELEASE OF PCT DUE TO BACTERIAL INFECTION Calcitonin: Sources of production in healthy people Healthy Sepsis PCT: Sources of Production in Septic Patients • In bacterial infection, PCT is produced and released into circulation from the entire body Müller B. et al., JCEM 2001 23 PCT LEVEL INCREASE = INCREASED SIGNIFICANCE OF BACTERIAL INFECTION 2 ng/ml 0.5 ng/ml 0.05 ng/ml Healthy Individuals • • • Local Infections Systemic Infections (Sepsis) Severe Sepsis Septic Shock In critically ill patients, PCT levels elevate in correlation to the severity of bacterial infection In healthy people, PCT concentration are found below 0.05ng/ml Concentrations exceeding 0.5ng/ml can be interpreted as abnormal 24 HIGHLY SPECIFIC INDUCTION AND RELEASE OF PCT DUE TO BACTERIAL INFECTION • IFN- released in viral infection, blocks the activation of PCT production, therefore in viral infection PCT levels remain normally low Adapted from Christ-Crain et al. 2005 25 BENEFITS AND LIMITATIONS OF OTHER SEPSIS DIAGNOSTIC TOOLS Microbiology (Blood Culture) Standard of care, time to result, ?Sens., ? Spec. Imaging (X-Ray, Hr-CT) Availability, costs, variability of source detection Molecular Biological Testing Availability, costs, time to results Biopsy Invasive, relatively expensive Biomarker Testing (PCT) Easy to measure, not invasive, relatively inexpensive C-Reactive Protein (CRP) Slow kinetics , high impact of inflammation (specificity), suppressed by corticosteroids, relatively inexpensive 26 DIAGNOSTIC ACCURACY OF PCT COMPARED TO OTHER BIOMARKERS USED IN SEPSIS Sensitivity: 89% Specificity: 94% NPV: 90% / PPV: 94% • • PCT levels accurately differentiate sepsis from noninfectious inflammation* PCT has been demonstrated to be the best marker for differentiating patients with sepsis from those with systemic inflammatory reaction not related to infectious cause Simon L. et al. Clin Infect Dis. 2004; 39:206-217. 27 ADDING PCT RESULTS TO CLINICAL ASSESSMENT IMPROVES THE ACCURACY OF THE EARLY CLINICAL DIAGNOSIS OF SEPSIS AUC with PCT: 0.94 AUC without PCT: 0.74 • When PCT is used as a reference, the sensitivity and specificity of sepsis diagnosis can be significantly increased compared with conventional clinical parameters. Harbarth S et.al. AM J Resp Crit Care Med. 2001; 164:396-402 28 PCT LEVELS INCREASE • • • ACCORDING TO SEVERITY OF SEPSIS PCT can aid in the diagnosis and severity stratification in patients suspected of sepsis, severe sepsis, and septic shock. In multiple studies, PCT has demonstrated a high sensitivity and specificity for the differentiation of sepsis from SIRS (Systemic Inflammatory Response Syndrome) PCT levels can be useful for the management of patients after surgery or transplant and in peritonitis Harbarth S et al. Am J Respir Crit Care Med 2001, 164: 396-402 ; Meisner M et al., Critical Care 1999, 3(1): 45-50 ; Krüger S. et al., Eur Respir J 2008; 31: 349–355 29 ADDING PCT RESULTS TO CLINICAL ASSESSMENT IMPROVES THE ACCURACY OF THE EARLY CLINICAL DIAGNOSIS OF INFECTION POST ORGAN TRANSPLANT PCT plasma concentrations in 16 patients without postoperative complications after LiverTransplantation, Tx: day of transplantation. PCT plasma concentrations in infection and rejection (n = 11), day 0: day of diagnosis • PCT used in early detection of infection after liver transplantation – differentiation from rejection Kuse ER et al., Crit Care Med 2000; 28: 555-559 30 PCT KINETICS PROVIDE IMPORTANT INFORMATION ON PROGNOSIS OF SEPSIS PATIENTS • • Clinical symptoms alone are often insufficient for early and accurate diagnosis PCT levels, can be observed within 3-6 hours after an infectious challenge with a peak - up to 1000 ng/ml - after 6-12 hrs. Half-life: ~24hrs • Specific to bacterial origin of infection and reflects the severity of the infection Brunkhorst FM et al., Intens. Care Med (1998) 24: 888-892 31 INTERPRETING PROCALCITONIN VALUES 32 PCT RELEASE IN THE ABSENCE OF INFECTION • Newborn < 48hr - increased PCT values (physiological peak) • On 3rd day after birth, normal adult reference ranges apply • Primary inflammation syndrome following trauma: multiple trauma, extensive burns, major surgery (cardiac, transplant, abdominal) • Rapid decrease (half-life 24hr) in the absence of bacterial infection • Medullary C-cell cancers of the thyroid, pulmonary small-cell carcinoma and bronchial carcinoma • Prolonged circulatory failure (e.g.. cardiogenic shock, hemorrhagic shock, thermal shock) • Treatments that can cause a cytokine storm e.g. OKT3, anti-lymphocyte globulins, etc. 33 ADDING PCT RESULTS TO CLINICAL ASSESSMENT IMPROVES THE ACCURACY OF THE EARLY CLINICAL DIAGNOSIS OF SEPSIS IN NEONATES UNINFECTED PCT (ng/ml) INFECTED PCT (ng/ml) Time (hours) Time (hours) • In early onset neonatal sepsis PCT provides a clear differentiation of infected from uninfected neonates in the first 2 days of life • In neonates the PCT values are physiologically and in relation to their age increased. • A peak is reached at 24 h with Median at 2 ng/ml and 95%-Percentile at 20 ng/ml. • After 3 days the normal values for children and adults apply. C Chiesa et al. CID 1997 34 CONDITIONS OF BACTERIAL INFECTION WHERE PCT MAY BE LOW IN THE PRESENCE OF BACTERIAL INFECTION Low PCT levels in the presence of bacterial infection may occur: • • • Early course of infection: Re-measure in 6-12hrs Subacute Endocarditis Localized infections 35 INTERPRETATION OF PCT LEVELS • PCT values must always be interpreted within the clinical context of each individual patient • Serial measurement is preferred to assess the situation in realtime • Always pay attention to conditions that may influence the PCT level • Always consider the dynamics of the disease process (which affect onset of PCT production) 36 PCT KINETICS AFTER AN INFECTIOUS CHALLENGE Brunkhorst FM et al., Intens. Care Med (1998) 24: 888-892 • • • • Rapid kinetics: detectable 3 hours after infection has begun, with a peak after 6-12 hrs. Peak values up to 1000 ng/ml Half-life: ~ to 24 hrs Non or minor dependence on renal function Brunkhorst FM et al., Intens. Care Med (1998) 24: 888-892 37 PCT REFLECTS THE RESPONSE OF THE ORGANISM TO THE BACTERIAL CHALLENGE • Elevated / rising PCT levels • Systemic response to the infection - indicates that infection is developing or is outside the control of the immune system • Risk for further progression • Low PCT levels despite clinical signs and symptoms • Self-limiting bacterial infection • Non-infectious cause • Early phase of infection 38 PROCALCITONIN UTILIZATION TO IMPROVE PATIENT CARE IN THE HOSPITAL 39 NO PCT INCREASE IN BACTERIAL CONTAMINATION, ONLY IN REAL BACTERIAL INFECTION • In addition to clinical and microbiological parameters, PCT may help discriminate blood stream infections from blood culture contamination due to coagulasenegative staphylococci • At a cut-off of 0.1ng/ml sensitivities and specificities were • Day –1 of BC: • Day 0 of BC: 86% 100% and and 60% 86% • CRP could discriminate only on day +1, but not as clear-cut as PCT Schuetz P. et al., Infection 2007;35 (5): 352-5 40 PCT LEVELS PREDICT BACTEREMIA IN PATIENTS WITH COMMUNITY ACQUIRE PNEUMONIA (CAP) • Current guidelines recommend blood culture sampling from hospitalized patients with suspected CAP. Is there a way to reduce the patient harm, costs and errors associated with these recommendations? • Prospective cohort study with derivation and validation set including 925 patients with CAP who underwent blood culture sampling on hospital admission. Muller et al. CHEST July 2010 41 PCT PREDICTS BACTEREMIA IN PATIENTS WITH CAP: PATIENT FLOW IN DERIVATION AND VALIDATION COHORTS Muller et al. CHEST July 2010 42 PCT CUTOFF OF 0.1 ENABLES REDUCTION OF BLOOD CULTURES BY 12.6% AND IDENTIFIES 99% OF POSITIVE BLOOD CULTURES Muller et al. CHEST July 2010 43 PCT LEVELS PREDICT BACTEREMIA IN PATIENTS WITH COMMUNITY ACQUIRE PNEUMONIA • PCT levels accurately predicted blood culture positivity in patients with CAP. • PCT measurement demonstrated the potential to reduce the number of blood cultures drawn in the ED to better implement resources • The use of PCT in targeting rational blood culture utilization allows for more directing allocation of limited health-care resources. Muller et al. CHEST July 2010 44 PCT RESULTS PROVIDE IMPORTANT INFORMATION ON PROGNOSIS OF CAP PATIENTS IN EMERGENCY ROOM Mortality by PCT level 12% 10% PCT ≥ 0.1 Mortality, % 8% 6% 4% PCT < 0.1 2% 0% 0 5 10 15 20 25 30 Day • • PCT can be used for Risk stratification of patients with CAP Low PCT levels identify patients presenting in the ED with Pneumonia that have a low risk for mortality (N=1,651). Huang, et.al., Annals of Emergency Medicine, Vol 51, March 2008 46 SERIAL MEASUREMENT OF PCT PROVIDES A CLEARER PICTURE OF THE PATIENT’S RESPONSE TO ANTIBIOTIC TREATMENT. • • • Decreasing PCT levels in patients with sepsis indicate effective treatment of the underlying infection Persistently elevated PCT levels indicate a possible treatment failure When integrated into the management of septic patients, PCT can help clinicians to manage septic patients more efficiently Stueber, F. University of Bonn, Lecture at ISICEM, Brussels 2001 47 PCT GUIDANCE IN ANTIBIOTIC USAGE EFFECTS ON LENGTH OF STAY • Effect of PCT-guided management in patients with sepsis on ICU length of stay Nobre V. et alAM Resp Crit Care Med 2008: 177:498-505 48 PCT GUIDANCE ON EFFECT ON LENGTH OF ICU STAY • Effect of PCT-guided management in patients with sepsis on ICU length of stay Nobre V. et alAM Resp Crit Care Med 2008: 177:498-505 49 PCT GUIDANCE IN ANTIBIOTIC USAGE HAS BEEN SHOWN TO SIGNIFICANTLY SHORTEN THE TIME PATIENTS NEED TO BE ON ANTIBIOTICS KEY TAKEAWAY: Tailoring of AB treatment using PCT to the individual patient needs safely led to a reduction of average treatment duration from 12 to 5 days with same outcome Nobre V. et al AM Resp Crit Care Med 2008: 177:498-505 50 EFFECT OF PCT TESTING ON ANTIBIOTIC USE – A MULTICENTER, RANDOMIZED CONTROL TRIAL The ProHOSP Trial • Lower respiratory tract infections (LRTI) • Most frequent indication for antibiotic prescriptions in the Northwestern hemisphere • 75% of patients are treated with antibiotics • Predominantly viral origin of infection • Procalcitonin (PCT) algorithm • Reduced antibiotic use in patients with LRTIs Schuetz P et al. J Am Med Assoc. 2009;302:1059-66. 51 51 STUDY DESIGN • Multicenter, noninferiority, randomized controlled trial • Patients • Randomized to administration of antibiotics based on PCT algorithm • Cutoff ranges for initiating or stopping antibiotics (PCT group) or standard guidelines (control) • Serum PCT was measured locally • Main Outcome Measures • Composite adverse outcomes of death, intensive care unit admission, disease-specific complications, or recurrent infection within 30 days • Antibiotic exposure and adverse effects from antibiotics Schuetz P et al. J Am Med Assoc. 2009;302:1059-66. 52 52 RATES OF COMBINED ADVERSE OUTCOMES AND MORTALITY BY RANDOMIZATION GROUP No. (%) of Patients Group All patients (intention-to-treat) PCT Group Control Group Risk Difference, % (95% CI) (n = 671) (n = 688) 103 (15.4) 130 (18.9) −3.5 (−7.6 to 0.4) Death 34 (5.1) 33 (4.8) 0.3 (−2.1 to 2.5) ICU admission 43 (6.4) 60 (8.7) −2.3 (−5.2 to 0.4) Recurrence/rehospitalization 25 (3.7) 45 (6.5) −2.8 (−5.1 to −0.4) Per-protocol population (n = 633) (n = 650) Overall adverse outcome 95 (15.0) 123 (18.9) −3.9 (−8.2 to 0.03) Death 29 (4.6) 31 (4.8) −0.2 (−2.6 to 2.0) Community-acquired pneumonia (n = 460) (n = 465) Overall adverse outcome 74 (16.1) 94 (20.2) −4.1 (−9.1 to 0.9) Death 24 (5.2) 26 (5.6) −0.4 (−3.3 to 2.6) Overall adverse outcome 53 Schuetz P et al. J Am Med Assoc. 2009;302(10):1059-66. Antibiotic Exposure in Patients Receiving Antibiotic Therapy PCT Control All Patients (n = 1359) Community-acquired Pneumonia (n = 925) Patients Receiving Antibiotic Therapy, % 100 80 60 40 20 0 0 1 2 5 7 9 11 >13 Time After Study Inclusion, d No. of Patients PCT 506 484 410 306 207 138 72 46 Control 603 589 562 516 420 324 157 100 0 1 2 5 7 9 11 >13 Time After Study Inclusion, d 417 410 359 272 161 126 64 461 453 444 428 361 292 146 41 91 Schuetz P et al. J Am Med Assoc. 2009;302(10):1059-66. Antibiotic Exposure in Patients Receiving Antibiotic Therapy PCT Control Exacerbation of COPD (n = 228) Acute Bronchitis (n = 151) Patients Receiving Antibiotic Therapy, % 100 80 60 40 20 0 0 1 2 5 7 9 11 >13 Time After Study Inclusion, d No. of Patients PCT 56 47 30 23 16 6 4 2 Control 79 78 67 56 40 20 5 4 PCT: Procalcitoin COPD: Chronic Obstructive Pulmonary Disease 0 1 16 41 11 38 2 5 7 9 11 >13 Time After Study Inclusion, d 9 35 3 19 3 8 1 3 1 0 1 0 Schuetz P et al. J Am Med Assoc. 2009;302(10):1059-66. Adverse Outcomes PCT Control 0 10 20 30 0.2 0.1 0.0 Proportion with Combined Adverse Outcome 0.1 0.2 CAP (n = 925) 0.0 Proportion with Combined Adverse Outcome All Patients (n = 1359) 0 Days Since Randomization 20 30 Days Since Randomization No. at Risk PCT Control 10 No. at Risk 671 688 605 598 579 576 568 558 PCT Control 460 465 408 396 394 383 386 371 Schuetz P et al. J Am Med Assoc. 2009;302(10):1059-66. CONCLUSIONS • An algorithm with PCT cutoff ranges was noninferior to clinical guidelines in terms of adverse outcomes in CAP: • Reduced antibiotic exposure • Reduced associated adverse effects • In countries with higher antibiotic prescription rates, PCT guidance may have clinical and public health implications Schuetz P et al. J Am Med Assoc. 2009;302:1059-66. 57 57 PROCALCITONIN: CASE STUDIES FROM THE EMERGENCY DEPARTMENT 58 CASE STUDY- H.C. • • • • 31 year old female w/ multiple sclerosis on weekly plasmapheresis Hospitalized in early July for possible catheter infection Catheter removed, only 1 blood culture growing coagulase negative staph. Transitioned from vancomycin to ofloxacin then to doxycycline 59 CASE STUDY- H.C. • • • • Seen in ER June 8 the night of hospital discharge. Patient still concerned about redness and itchiness near former line site Given empiric dose of vancomycin after drawing blood cultures, CBC, PCT. Discharged home to be followed by PCP and dermatology next day to determine if broad spectrum antibiotics needed to be continued. June 9 dermatology clinic visit suggests patient w/ contact dermatitis; continues previous course of doxy 60 CASE STUDY H.C. • • Procalcitonin 0.11 PCT level provides reassurance that: • • recurrence of systemic infection unlikely, present narrow-spectrum antibiotic choice likely effective providing better antimicrobial stewardship 61 CASE STUDY E.P. • • • • • “classic” PCT benefit case 72 yo male w/ valvular heart disease, sick sinus syndrome s/p pacemaker* to ED w/ acute SOB on July 8th middle of night shift. Not known to our system, his primary hospital ER was on bypass, no old records or previous imaging available O2, bronchodilators, empiric broad spectrum antibiotics after blood cultures, labs including PCT Admitted to intermediate care unit for high flow O2, antibiotics, monitoring, bronchodilators, trial of diuretics. *increasing prevalence of elderly patients with pacemakers or on betablockers reduces clinical vital sign effectiveness in diagnosis SIRS and Sepsis since heart rate may be artificially blunted 62 CASE STUDY E.P. • • Within 24 hours he required transfer to the ICU and intubation for respiratory distress and sepsis PCT was 3.45 from ED draw but due to his nighttime arrival was not available until after admitted to floor. 63 CASE STUDY E.C. • • • • • • • 63 yo male w/ fever, chills, atrial fibrillation with RVR (HR 140s) Treated with diltiazem and broad spectrum antibiotics Symptoms resolved within two days and patient discharged home on azithromycin Emergency department PCT was 0.12 Record review show patient's previous admission for afib with RVR was attributed to documented influenza A No virology studies during this admission, only "positive" microbiological finding was a coag negative staph blood culture on hospital day 2. Should patient have had virology screening done even though it was not flu season? 64 INFORMATION FROM PCT ADDS TO THE QUALITY OF THE CLINICAL DECISION MAKING • Understand the kinetics and limitations of any test in order to optimize its utilization! • Guidance of therapy • Decision on antibiotic initiation • Guidance of duration of therapy • Risk stratification of patients • Admission to hospital • Admission to ICU • Escalation of therapy • Guidance of diagnosis • More appropriate selection of who might need invasive diagnostic tests • Rational utilization of advance imaging modalities • Improved direction in choice of microbiology and virology studies 65 THANK YOU! QUESTIONS? COMMENTS? 66