STANDARD INSURANCE COMPANY

STANDARD INSURANCE COMPANY A Stock Life Insurance Company 900 SW Fifth Avenue Portland, Oregon 97204-1282 Brown County ABSENCE MANAGEMENT OPERATIONS MANUAL SCHEDULE 1 FMLA Administration of federal Family and Medical Leave Act (FMLA) Standard will administer leaves under the Family Medical Leave Act as follows: 1. Initiation of Leave. A. Once an employee learns about the need for a leave of absence, employee or their representative will follow Client s regular leave notification process and notify the Client. B. Employee or Client will contact Standard s Intake Team. Leave requests may be made by: i) calling a Standard toll free telephone number between the hours of 7:00 am to 8:00 pm (Eastern time) Monday through Friday; or ii) accessing a secure Internet site, available "24/7", established by Standard. C. Standard will not require leave requests to be submitted in writing. 2. Leave Eligibility. A. For leaves initiated by phone, Standard s Intake Team will determine whether FMLA is applicable to the leave requested. If an employee is found to be ineligible for FMLA, the leave request will be escalated to a member of Standard s Absence Management Service Center (AMSC) staff to confirm ineligibility. Once ineligibility has been confirmed, Standard will send a notice to the employee of their ineligibility and a reason that they are ineligible. B. For leaves initiated by web intake, an employee or employee s representative will be asked to identify the reason a leave is being requested. C. Standard will rely on data provided in the eligibility file feed provided by Employer in order to make an eligibility determination. [See: Schedule 6 Eligibility Feed Specifications.] (1) If Employer has not provided Standard with sufficient information to make an eligibility determination, such as hire date and hours worked in the last 12 months, Standard will contact Employer for necessary information. (2) Standard will not be responsible for delays in providing employee notifications pending receipt of information requested from Employer. 1

Brown County will provide the most recent hire date and hours worked in the last 12 months on their eligibility file. The Standard will ask employees about prior periods of employment, which may impact eligibility, at the time of a leave request, and contact Brown County to validate. 3. Evaluation of Employee Notice Requirements. A. At the Employer s option, Standard can administer employee notice requirements as follows: (1) Option 1: Administration of employee notice requirements a. For foreseeable leaves leaves requested prior to initiation of leave 1. If the notice from the employee is received by Standard [30] days prior to the date of the leave, the leave will be processed in the normal course. 2. If Standard receives notice less than [30] days prior to the need for a foreseeable leave, Standard will make an initial determination as to whether notice from employee was timely. i. If timely, leave will be processed in the normal course ii. For leaves that appear untimely, Standard will contact Employer for further instruction on how to proceed prior to leave designation b. For unforeseeable leaves leaves requested after leave has commenced 1. If the notice from the employee is provided more than [2] days from the date the leave commenced, and the employee has not yet returned to work, Standard will notify Employer of possible late notice and request instruction prior to designating the leave. 2. If employee provides notice of leave more than [2] days after returning to work, Standard will notify the Employer of possible late notice and request instruction prior to designating the leave. 4. Initial Notices/Correspondence Provided. A. For employees found to be eligible for FMLA, Standard will send its Employee Packet via mail the next business day. The Employee Packet may contain the following: (1) Eligibility notice (always provided) (2) Rights and Responsibility Notice (always provided) (3) Certification or other supporting documentation (if required) (4) Request for any other documentation (e.g. birth certificate, court document, etc.) (5) Authorization form permitting Standard to contact employee s health care provider (6) Health Advocacy information (if applicable) (7) Employer s own leave policies, as agreed upon by Standard and Employer (8) Other information as agreed upon by Standard and Employer (e.g. EAP) 2

B. For employees found to be ineligible for FMLA, Standard will send denial notice to employee within 5 business days. C. Within 1 business day of determining eligibility, Standard will notify Employer via email of the eligibility determination. 5. Obtaining Certification/Other Supporting Documentation. A. When appropriate, Standard will request a medical certification or other supporting documentation to verify the need for the leave. B. Standard does not require documentation of family relationships, including proof of marriage or registration supporting domestic partnerships, civil unions or reciprocal beneficiaries unless requested by the Employer. C. Standard s best practice is to provide each employee at least [18] calendar days from the date employee eligibility is determined to return any certification or other supporting documentation that was requested. This [18] calendar days includes 15 days (required by FMLA s regulations), and an additional period for mailing. (1) Note in some instances, where the leave date may be dependent on a triggering event (e.g. placement of child, delivery date) the date to return documentation may be modified to be [18] calendar days following the date of the triggering event. Standard will follow our best practice method for Brown County by allowing 18 days for a Certification form to be returned. D. 9 days after initiation of leave, AMSC staff will review to determine whether applicable certification or other supporting documentation for the leave has been received. If certification has not yet been received, AMSC will send a 9-Day Follow-Up letter to employee. E. Standard s correspondence instructs employees to notify the AMSC if the employee will be unable to return certification within the time period provided and the reason they will be unable to return timely certification. If employee notifies Standard of circumstances that prevent them from complying with the deadline, Standard will evaluate whether to extend the period to provide the certification. F. After day [18], if certification or other supporting documentation is not received, and Standard has not been notified by employee of any circumstances that prevented employee from submitting timely certification, Standard may deny leave for failure to provide certification. Certifications received after day [18] or after a period where no additional notice was provided by employee explaining delay will be treated as untimely and will be subject to conditions under section titled Receipt of Untimely Certification below. G. Standard will accept invitational travel orders ( ITOs ) or invitational travel authorizations ( ITAs ) issued to any family member to join an injured or ill service member at his or her bedside as sufficient certification for leave to care for an injured service member. 6. Evaluation of Certification/Other Supporting Documentation. A. Once certification is received, AMSC will evaluate certification to determine whether it is complete, sufficient, and whether it supports the leave request. (1) In evaluating the certification, AMSC may utilize internal Disability Management Resources (DMR) which includes Nurse or Vocational Case Managers in order to 3

assess or understand the certification and to determine whether further investigation is necessary. B. If a certification is determined to be incomplete, insufficient, or requires authentication the employee is notified of the deficiency and is provided [10] calendar days from the date the request is mailed, to return a completed certification. (1) If employee elects to provide Standard with a completed HIPAA-compliant authorization to obtain medical information, Standard may assist in obtaining the certification by contacting the employee s health care provider directly. C. If after day [10], the corrected certification or other supporting documentation is not received, and Standard has not been notified by employee of any circumstances that prevented employee from submitting timely certification, Standard will deny leave for failure to provide certification. 7. Second and Third Opinions. A. If during the evaluation of the certification, and after any appropriate consultation with DMR, if the AMSC determines there is reason to doubt the validity of the certification; the AMSC will consult with the Employer to determine whether a second opinion should be pursued. The costs of second and third opinions will be borne by the Employer. B. If Employer has reason to doubt the validity of a medical certification, Employer must notify Standard if they will require a second or third opinion prior to Standard s designation/approval of the leave. C. When requested, Standard will assist Employer with the selection of health care providers to provide the second and third opinions, and will assist in the scheduling of second and third opinion examinations. D. Upon approval by the Employer, Standard will arrange for the employee to see a health care provider. Standard will notify the employee that pending receipt of the second opinion, the employee is provisionally entitled to protection under FMLA. E. If a second opinion is inconsistent with the original certification provided by the employee, it is Standard s best practice to pursue a third opinion whose decision will be binding. F. If the second or third opinion supports the leave, the leave request will be approved and an email notification will be sent to Employer notifying them of leave approval. An approval letter designating the leave will be sent to the employee within 5 business days. If the third opinion supports denial of the leave, the AMSC will send out a denial letter to the employee. G. If the third opinion does not support the leave, the requested leave will be denied, and a letter will be sent to the employee notifying them of the decision, and Employer will be notified of the denial via email. H. Standard will notify Employer by email of the leave decision following the second or third opinion. I. At the request of an employee, Standard will provide employees with copies of the second and third opinions within 5 business days from the date of the employee s request. J. Second and third opinions cannot be required for leave to care for an injured service member. 4

8. Receipt of Untimely Certification/Other Supporting Documentation. A. If Standard receives untimely certification that supports the entire leave period requested, Standard s recommended Best Practice is to approve the full FMLA leave supported by the certification. 9. Designation of Leave. A. Once the AMSC has determined that it has received sufficient information supporting the leave, they will designate the leave as FMLA. B. The AMSC will send an approval letter to the employee within 5 business days of receiving requested documentation. [Note: the timeframe for sending out an approval letter may be modified under a performance guarantee.] (1) If Employer requires a Fitness for Duty certification, prior to returning to work, Standard will include a Return to Work Authorization Form and other requested information as explained in the Fitness for Duty section 15, below. C. If it is determined that the leave does not meet the requirements of FMLA, Standard will send a denial notice to the employee, informing the employee that the leave will not be designated as FMLA. D. On the day the leave determination is made, the AMSC will send an email notification to Employer notifying them of the decision. 10. Increments of Leave. Standard will track and administer leaves in 15 minute increments. 11. Shared Leave Entitlement A. FMLA allows an employer to require spouses employed by the same employer to share their leave entitlement if leave is being requested by both spouses for the birth or placement of the employees child. B. If Standard is administering this restriction for the Employer, Standard will ask the employee at intake if the employee has a spouse working for the same employer. Standard will rely on the employee s response in administering this restriction. 12. Same Sex Spouse, Domestic Partners, Civil Unions, and Reciprocal Beneficiaries. A. Currently, the following types of relationships are not recognized as spouses under federal FMLA: (1) Same Sex Spouses residing in States that do not legally recognize same-sex marriages (2) Domestic Partnerships (3) Partners in a Civil Union (4) Reciprocal Beneficiaries 5

B. Standard will not provide federal FMLA entitlement for employees who do not qualify for leave under federal FMLA. C. Some states may provide leave for the relationships specified above, or employers may have a policy to extend leaves for employees in these relationships. Standard will apply leaves under applicable state law or consistent with employer policies. Brown County does not recognize domestic partners or offer greater benefits than WIFML. D. Standard assumes that same-sex spouses, and registered domestic partners, partners in a civil union and reciprocal beneficiaries stand in loco parentis to each other s children. 13. Furloughs and Holidays. Standard s recommended best practice is that FMLA entitlement will not be deducted for periods where the company is not open for business. Employer is responsible for notifying Standard of business closures, and providing the name and location of the employees impacted. Brown County observes the following holidays for eligible employees who have been employed for a period of thirty (30) days: New Year's Day, Memorial Day, Independence Day, Labor Day, Thanksgiving Day, Christmas Eve, Christmas Day, and New Year s Eve. For employees who work Monday through Friday schedules, if any of the above mentioned holidays fall on Saturday, the preceding Friday will be observed and if the holiday falls on Sunday, the following Monday will be observed or as determined by the County. Eligible employees shall receive a full day's pay for the above mentioned holidays. After each holiday, The Standard will reach out to Brown County with a list of employees on leave and request confirmation of who was eligible for the holiday. 14. Recertification. A. Standard will request a recertification every 6 months unless: (1) the health care provider is unable to determine the duration of the leave, in which case, Standard will request a recertification every 30 days; (2) the certification provides for a period of leave exceeding 30 days but less than 6 months, in which case, Standard will request a recertification at the end of the certified period. B. Standard will request a recertification from employees who request extensions of a previously approved leave. C. Standard may also request a recertification if they are notified of a significant change in circumstances that may impact the need for or duration of previously approved leave. D. Standard will not request recertification for leave to care for an injured service member. The Standard will not administer FMLA s key employee provision on behalf of Brown County. 15. Fitness for Duty. 6

If Standard is administering Fitness for Duty: A. Standard will provide notice to employee of any obligation to provide a Fitness for Duty certification and will provide a Return to Work Authorization form for that purpose. B. If Employer requires that the Fitness for Duty certification address the employee s ability to perform the essential functions of their job, Standard will also provide a list of the essential functions of the employee s job, subject to Employer meeting its obligations under section 6 of Schedule 6. C. 14 calendar days prior to the anticipated return to work date, Standard will contact the employee to verify that the anticipated return to work date is accurate, and remind employee of employee s obligation to provide a completed Return to Work Authorization form to the Employer. D. 14 calendar days prior to the anticipated return to work date, Standard will send a letter to the employee reminding the employee of their obligation to provide a completed Return to Work Authorization form to the Employer, and provide the employee with a copy of the form. E. 14 calendar days prior to the anticipated return to work date, Standard will send Employer an email notification of employee s expected return to work date. F. Standard will close the leave as of the anticipated return to work date unless employee or Employer has requested an extension of the leave. G. Standard s recommended best practice is to administer the Fitness for Duty process outlined above only for leaves taken for a continuous period. 16. Return to Work. A. 14 calendar days prior to the anticipated return to work date, Standard will send a letter to the employee reminding them of the anticipated return to work date. B. 14 calendar days prior to the anticipated return to work, Standard will send an email to the Employer reminding them of the employee s anticipated return to work date. C. Standard will close the leave as of the anticipated return to work date unless employee or Employer has requested an extension of the leave. 7

SCHEDULE 2 USERRA Administration of the Uniformed Services Employment and Reemployment Rights Act (USERRA) Standard will track leaves under USERRA as follows: 1. Initiation of Leave. A. Once an employee learns about the need for a leave of absence, employee or their representative will follow Employer s regular leave notification process and notify the Employer. B. Employee or Employer contacts Standard s Intake Team. Leave requests may be made by i) calling a Standard toll free telephone number between the hours of 7:00 am to 8:00 pm (Eastern time) Monday through Friday; or ii) accessing a secure Internet site, available "24/7", established by Standard; 2. Leave Eligibility. Standard assumes that all employees requesting military leave are eligible and entitled to take leave that is covered under USERRA. 3. Correspondence Provided. A. Within one day of receiving notice from the employee (or designee) that a leave is needed for military service, Standard will send out a letter confirming the employee s requested leave dates and asking for supporting documentation, and notifying them of their reemployment rights. B. On the same day, Standard will also send an email to the Employer notifying them of the employee s military leave and dates of service. 4. Obtaining Documentation Supporting Need for Leave. A. After 9 days, if Standard has not received documentation supporting the military service, Standard will send a follow-up letter reminding the employee of the outstanding request for documentation. If Standard has not received documentation supporting the military service within [14] days from the date the initial reminder letter is sent, Standard will send an email to the Employer notifying them that the documentation was not received. B. If the documentation is received, Standard will send a letter to the employee confirming the receipt of the documentation to the employee, and an email will be sent to the Employer notifying them of the same. 8

5. Return to Work. A. For leaves with a duration greater than 30 days, Standard will send a letter [30] days prior to the anticipated return to work date notifying employee of their reemployment rights and verifying the anticipated return to work date, and asking for documentation that supports their right to reinstatement. Standard will also send an email to Employer notifying them of the anticipated return to work date. B. If employee notifies Standard that the leave dates need to be extended, Standard will send a letter to the employee confirming the new dates, and an email to the Employer notifying them of the extension. C. If documentation supporting reemployment is received, Standard will forward the documents to the Employer for review 6. Reinstatement. A person reemployed following military service is entitled under USERRA to be credited with hours that would have been worked for the employer, but for the military service, in determining FMLA leave. The Employer remains responsible for updating the feed or providing updated information to Standard upon reemployment following a period of leave for military service. 7. 5-Year Notification. Generally, USERRA provides reemployment rights for a period of 5 years of military service. However, some military services are not applied toward the 5-year period. Standard will notify Employer when an employee s total amount of military service reaches 60 months. However, Employer remains responsible for determining whether an individual employee is still entitled to reemployment rights under USERRA. Standard will continue to administer leave under USERRA for the individual employee unless Employer notifies Standard that they have determined the individual is no longer eligible for reemployment. SCHEDULE 3 Administration of State Family and Medical Leave Laws Generally, unless the terms of a state leave law diverges from the federal law, and when a Employer is subject to both a federal and state mandated leave, Standard will administer the state leave law consistently with the process described in Schedule 1. Where there are differences in the law, we will administer the provision as described below. When the state law is silent on provisions addressed by federal law, except for where specifically addressed below, we will follow the practices described in Schedule 1. 9

In all cases, when an employee is eligible only for a state leave, the terms of the state leave law will govern the administration of the leave. Unless otherwise specified in this Schedule, State laws that provide leave for reasons not provided under federal or state FMLA (e.g. school visitation leave, emergency response leave etc.) will be administered consistent with generally accepted leave handling practices. 1. State Family and Medical Leave Laws Under Administration. Wisconsin Family or Medical Leave Act ENTITLEMENT SUMMARY Wisconsin law provides up to 6 weeks of family leave in a calendar year for the birth of the employee s natural child or the placement of a child with the employee for adoption, or as a precondition to adoption, but not both. For adoptions, Wisconsin law requires the child to live in the residence for 6 months before adoption. Leave may be taken either during this 6 month period, or at the time of the adoption, but not both. Standard will not administer the requirement that adopted children reside with the employee prior to the leave period. ELIGIBILITY PARAMETERS Covered employers employ 50 employees on a permanent basis. Standard will consider all employees on the feed to count toward this requirement. Eligible employees have been employed by the employer for more than 52 consecutive weeks and have worked for the employer for at least 1,000 hours during the preceding 52-week period. Standard will not enforce the requirement that any period of employment be served consecutively. ADVANCE NOTICE Standard will administer notice requirements as outlined in Section 3 of Schedule 1. We will not enforce state variances. CERTIFICATION/VERIFICATION For a Wisconsin leave request that is not associated with a STD (short term disability) claim, Standard will use its WFMLA-compliant certification form. 10

DOMESTIC PARTNERS WFMLA permits leave to care for a domestic partner. Under Wisconsin law, when leaves are requested for this reason, Standard will apply WFMLA, but will not apply FMLA to the requested leave period. 11

SCHEDULE 4 Administration of Other State Leave Laws Standard s leave administration service includes the following types of leave laws: 1. Blood Donation 2. Bone Marrow 3. Court Proceedings 4. Crime Victim 5. Domestic Violence/Sexual Abuse (Personal Protected Leave) 6. Emergency Personnel 7. Emergency Personnel Training 8. Family Military 9. Maternity/Paternity 10. Medical Appointment 11. Organ Donation 12. School Visitation and Event Standard, in its sole discretion, reserves the right to delete or add leaves to the leaves administered under this schedule, based on changes of state laws. Other State Leave laws administered on behalf of the Employer include the following: 1. Wisconsin Emergency Personnel Leave For each of the leaves listed above in this Schedule, Standard s administration of these leave types will be as follows: 1. Applicability to Employer. A. For purpose of determining the amount of leave that must be provided, and whether a Employer is required to provide these types of leaves, Standard assumes that all Employers have over 50 total employees. B. Some states may determine availability of a leave by the number of employees at one location. Standard will rely on the location code provided by Employer to determine the number of employees at the employee s location for the following leaves. If no location code is provided, Standard will determine eligibility based on the number of employees in the employee s work state. 1. Initiation of Leave. A. Once an employee learns about the need for a leave of absence, employee or their representative will follow Employer s regular leave notification process and notify the Employer of an employee s leave request. B. Employee or Employer will contact Standard s Intake Team to provide notification of the need for leave. Leave requests may be made by i) calling a Standard toll free telephone number between the hours of 7:00 am to 8:00 pm (Eastern time) Monday through Friday; or ii) accessing a secure Internet site, available "24/7", established by Standard; 12

(1) Intake of non-fmla type leaves is limited to verifying the reason for leave and the dates requested. (2) For purposes of privacy and safety, Standard may use a shorthand name for leave reasons, rather than the name of the actual leave law when corresponding with the Employer and employee. 2. Evaluation of Notice Requirements. For leaves where no notice period is provided, or a reasonable period is provided, Standard will follow the processes described in administration of federal FMLA leave as described in Schedule 1. 3. Initial Notices/Correspondence Provided. A. Within 3 business days of determining eligibility for leave for a non-fmla leave reason, Standard will send a letter to the employee confirming that the leave request was received and the dates of the leave requested. B. While state leave laws vary on the types of documentation that is acceptable when validating employees entitlement to leave, Standard s request for documentation will conform to specific documentation requirements for each leave law. C. Standard will request documentation that supports an employee s initial entitlement to leave. Standard will not require documentation for subsequent leaves taken for the same leave incident/leave reason. D. Standard will not request documentation for a non-fmla leave when the requested leave does not exceed 3 consecutive business days. 4. Follow-Up on Documentation. Standard will follow up with a request for documentation within 9 calendar days if documentation has not been received. 5. Review Documentation and Designate Leave. Once documentation is received from an employee, Standard will review documentation to ensure that it supports the leave requested. Standard will also determine whether the leave should run concurrently with any other applicable state or family medical leave law and designate the leave appropriately. 13

6. Intermittent Designations. Standard will permit employees to take leaves on an intermittent basis when requested and if the leave request is consistent with the purpose under the state law. 7. Return to Work. Standard s administration for Other State Leave Laws is limited, and will not include administration of Fitness for Duty, or monitoring leave requirements that require an employee to return to work within a specified timeframe. 8. Communicate Determination. A. Standard will send correspondence to an employee confirming that the leave was designated as job-protected leave. B. Standard will send email to Employer confirming that the leave has been designated as job-protected. 9. Tracking and Reporting of Leave Amount Used. Leaves taken for any of the leaves administered will be tracked, and available for Employer to review in the Standard suite of reports offered. SCHEDULE 5 Company-Sponsored Leaves 1. Administration of Employer s Company-Sponsored Leaves. Standard is able to administer a number of company-sponsored leaves on behalf of the Employer. Standard and Employer must mutually agree to specific processes developed to support administration of leaves. (Additional fees may be applicable). 2. Standard Will Administer the Following Employer Policies: Brown County does not have any Company-Sponsored Leaves at this time. A. Standard will administer the policies listed above consistent with the documentation attached. B. Standard has identified the following additional processes that will be necessary in order to administer these leaves. C. Employer understands that Standard will not administer company sponsored leaves without written documentation satisfactory to Standard that describes the terms and conditions of the leave, and has agreed upon processes for administration. 14

3. Notifications of Changes to Employer Policy. Employer remains responsible for timely notification to Standard of any changes to the employer s leave policies that impact the administration of the leaves. 15

SCHEDULE 6 Eligibility Feed Specifications At implementation, Standard s Data Acquisition Team (DAT) will provide Employer with Eligibility Feed Specifications which details the necessary data for processing absence management leaves. Standard relies on data provided by the Employer to ensure accuracy in administration of its Absence Management Service. Employer understands and agrees to the following: 1. Entitlement Calculation Period. A. Under the FMLA, employers must select between four methods to calculate the 12- month period in which the employee is entitled to receive up to 12 workweeks of FMLA leave: i. The calendar year ii. Other fixed 12-month leave year, applied to all Employer s employees iii. The 12-month period measured forward from the employee s first date of leave iv. A rolling 12-month period measured backward from the date an employee uses leave. B. For leaves that do not mandate a specific method of calculating the entitlement calculation period, Standard will use the calculation period method selected by Employer for federal FMLA. Brown County currently uses, and will continue to use, a calendar year method (i). The ADRC will transition to the calendar year (i.) method effective January 1, 2014. 2. Employee Eligibility Data. a. Employer shall provide data feed daily or weekly as determined by the Employer and Standard. b. If an employee reports a leave to Standard, and the name of the employee is not found on the eligibility file feed, Standard will complete the intake request, and contact the Employer in order to obtain eligibility information (i.e. months employed, hours worked, employment status). c. If eligibility data is insufficient to make an eligibility determination, Standard will contact Employer for additional information or clarification of eligibility data. d. Standard will not make eligibility determination until additional information or clarification has been provided by Employer. e. Standard will rely on information provided by the Employer to make a decision on employees leave eligibility. Brown County will be providing a weekly eligibility file. 16

3. Employee Work Schedules. A. Standard recommends that Employer provide work schedules on the eligibility feed. B. If Employer is unable to provide employee work schedules on the eligibility feed, Standard will request the work schedule from the employee at the time the leave is reported. Standard will rely on the work schedule provided by the employee when determining leave entitlement. C. If no work schedule is provided by the employee, and the employee has provided a work schedule during a prior leave, Standard will use the work schedule from a prior leave. D. If no work schedule has been provided by the employee, or if the employee s schedule varies from week to week so much that a schedule is unable to be established, Standard will use a weekly average of the number of hours worked per week during the prior 12 months, spread over a 5-day workweek, Monday through Friday. (1) If an employee has been employed less than 12 months, Standard will use the hours worked, prorated by the number of months worked for the employee s work schedule. Brown County employees work a 37.5 or 40 hour work week, Monday through Friday. Some employees work on the weekend. Schedules for all employees are confirmed at the time of a leave request. 4. Administration of the 50/75 Rule. Federal FMLA regulations and some state laws define an eligible employee, in part as one who is employed at a worksite where 50 or more employees are employed by the employer within 75 miles of that worksite. To enforce this rule, Employer must provide a location code in a report grouping on the file feed for each employee, which will be used to determine the number of employees at the employees worksites. If Employer does not provide a location code, Standard is unable to enforce eligibility requirements that require a minimum number of employees at a particular location. At implementation, Employers may instruct Standard not to enforce or to waive the 50/75 rule requirement. For Employers who instruct Standard not to enforce or to waive the 50/75 rule, Standard will base employee leave eligibility on other eligibility requirements (e.g. months employed by Employer, and hours of service). Brown County is providing the employee s work state on the weekly file feed. Brown County has 50 or more employees in a 75-mile radius. 5. Work State for Employees with No Fixed Worksite. FMLA defines a worksite for employees with no fixed worksite (such as travelling salespersons, or telecommuting employees) as the office to which they report and from which assignments are made. Standard will use the Work State provided by Employer to determine the state leaves that are available to these employees. 6. Administration of Fitness for Duty (if applicable). 17

If Standard is administering Fitness for Duty requirement on the behalf of Employer, and Employer requires the healthcare provider to address an employee s ability to perform essential functions of an employee s job, Employer must provide Standard with a list of applicable job titles and essential functions of those jobs as described in the Eligibility Feed Specifications document, and any other information requested in the Absence Management Implementation Kit. The Standard will administer a simple statement method on behalf of Brown County. The Return to Work Authorization form, a Brown County customized form, should be sent to the employee s supervisor and Standard. Standard will contact the employee s direct supervisor with accommodation requests. SCHEDULE 7 Concurrent Administration with Disability Products Standard will administer leave requests and disability policies in a combined process. This process leverages the resources and disability expertise to administer leaves of absences. The combined process minimizes the paperwork required from the employee by reducing the number of duplicative medical forms, and simplifies communications to the employee by providing all information in one letter. This schedule explains the process used by Standard to administer a leave of absence that is requested for an employee s own serious health condition, or pregnancy disability, it does not document the disability claim administration processes. When employees covered by a disability plan or policy request a leave of absence for their own serious health condition or pregnancy disability, Standard will administer the leave as outlined in Schedule 1, with the following exceptions: 1. Initiation of Leave With Disability Claim. A. At the time the leave is requested, Standard will notify employees of their potential entitlement to disability benefits and will give employees the option of initiating a disability claim. B. For employees choosing to file a disability claim, Standard will request from the employee additional information necessary to initiate the disability claim. Brown County employees who are enrolled in the STD (Short Term Disability) plan will be encouraged to initiate a disability if they may be eligible. 2. Correspondence. Standard will send correspondence that combines information for both the leave administration and disability claim administration. 3. Medical Certification/Documentation. 18

A. When a request for leave is combined with a disability claim, the AMSC will request employees provide a completed Attending Physician s Statement (APS) form as medical support for both the leave and disability claim. B. The AMSC will include an APS form in the Employee Packet and will also fax the APS form to the employees health care provider. C. The AMSC will include an Authorization to Obtain Information in the Employee Packet to allow Standard to obtain information from the employee s health care providers. D. For leave administration, a completed APS is to be returned within the timeframe outlined in Schedule 1. When an APS form is not returned within this timeframe, the AMSC will follow the process outlined in Schedule 1 regarding Receipt of Untimely Certification/Other Supporting Documentation. E. For disability claim administration, a completed APS is to be returned pursuant to the provisions of the disability policy or plan. F. If the employee returns the Authorization to Obtain Information, the AMSC may request additional medical information from an employee s health care providers to investigate the STD claim. 4. Evaluation of Medical Certification/Documentation. A. If the APS is determined to be incomplete, insufficient, or requires authentication, and the employee has provided to Standard the Authorization to Obtain Information, the AMSC will contact the treating health care provider directly to obtain clarification or authentication. B. If a certification is determined to be incomplete, insufficient, or requires authentication, and the employee has not provided Standard with Authorization to Obtain Medical Information, the AMSC will follow the process outlined in Schedule 1 to obtain a complete and sufficient APS. C. Once an APS form is received, the AMSC will evaluate it, and any other documentation obtained to evaluate the disability claim, to determine whether it supports the leave request. (1) In evaluating the APS, the AMSC may utilize internal Disability Management Resources (DMR), including Nurse or Vocational Case Managers, in order to assess or understand the APS and to determine whether further investigation is necessary. 5. Designation of Leave. A. Upon receiving a sufficient APS, once the AMSC has determined that it has received sufficient information supporting the leave, they will designate the leave under applicable leave laws. Note: In the event that the APS is insufficient to approve the disability claim, AMSC will continue to investigate the disability claim. B. The AMSC will send an approval letter to the employee within 5 business days of receiving requested documentation. Note: the timeframe for sending out an approval letter may be modified under a performance guarantee. 19

C. On the day the leave is designated, the AMSC will send an email notification to Employer notifying them of leave approval and the anticipated return to work date. D. If it is determined that the leave does not meet the requirements of any applicable leave laws, Standard will send notice to the employee denying the leave request, and notifying the employee that the leave will not be designated under the applicable leave laws. In the same notice, employee will be notified of the status of the disability claim. 6. Right to Inspect Records. As part of the combined leave and disability process, Standard may obtain information in accordance with disability plans or policies. This information may exceed what may ordinarily be requested to support a leave request. Information obtained as part of the investigation of a disability claim under policies issued by Standard, that exceeds what may ordinarily be requested to support the leave, is subject to insurance and privacy laws that govern Standard and may not be delivered to the Employer without authorization from the employee. Standard Insurance Company 20