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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 601 PENNSYLVANIA AVENUE, NW, SOUTH BUILDING |
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City | WASHINGTON |
State | DC |
Zip Code | 20004 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 1581-12
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6. House ID# 306290000
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TYPE OF REPORT | 8. Year | 2008 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
10. Check if this is a Termination Report | Termination Date | |
11. No Lobbying Issue Activity |
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
Signature | Digitally Signed By: Julie Simon Miller, Senior Associate Counsel |
Date | 10/20/2008 |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code HCR
16. Specific lobbying issues
HCR (LEGISLATIVE ISSUES): H.R. 506: Health Partnership Through Creative Federalism Act (Baldwin) (continued)
H.R. 1368: Personalized Health Information Act (Kennedy); H.R. 2184: Enhanced Health Care Value for All Act (provisions relating to comparative effectiveness research) (Allen); H.R. 2406: Healthcare Information Technology Enterprise Integration Act (Gordon); H.R. 2497: Fair and Reliable Medical Justice Act (Cooper); H.R. 2580: Help Efficient, Accessible, Low-cost, Timely Healthcare Act (Gingrey); H.R. 2638: Consolidated Security, Disaster Assistance, and Continuing Appropriations Act (provisions relating to high risk pool funding, comparative effectiveness research funding); H.R. 3014: Health Equity and Accountability Act (provisions relating to health care disparaties) (Solis); H.R. 3341: Quality Health Care Coalition Act (Paul) (provisions relating to physician collective bargaining); H.R. 5348: American Health Benefits Program Act (Langevin-Shays); H.R. 6357: Protecting Records, Optimizing Treatment, and Easing Communication through Healthcare Technology Act (Dingell-Barton); H.R. 6444: Healthy Americans Act (Wasserman Schultz) (provisions relating to insurance reforms and subsidies); H.R. 6898 Health-e Information Technology Act (Stark) (provisions relating to standards and incentives for health information technology; privacy and security protections); S. 243: Medical Care Access Protection Act (Ensign); S. 244: Healthy Mothers and Healthy Babies Access to Care Act (Gregg); S. 325: Health Partnership Act (Bingaman); S. 334: Healthy Americans Act (Wyden); S. 1198: Catastrophic Health Coverage Promotion Act (Smith); S. 1456: Federal Employees Electronic Personal Health Records Act (Carper); S. 1481: Fair and Reliable Medical Justice Act (Baucus); S. 1490: Federal Employees Electronic Personal Health Records Act (Carper); S. 1693: Wired for Health Care Quality Act (Kennedy); S. 2041: False Claims Act Amendments (Grassley); S. 3230: Labor-HHS-Education Appropriations Act (provisions relating to high risk pool funding, comparative effectiveness research funding); and S. 3408: Comparative Effectiveness Research. Act (Baucus) and
HCR (Regulatory Issues):
HIPAA administrative simplification issues, including privacy, security, electronic transactions, code sets, and identifiers; FEHBP enrollment data clearinghouse initiative; issues relating to health insurance plan participation in FEHBP, including contract requirements related to interoperability of health information technology, community rating policies, and similarly sized subscriber group (SSSG) requirement; implementation of the health savings account provisions of the Medicare Act; issues related to Medicare Secondary Payer requirements; issues related to implementation of the National Health Information Infrastructure; issues relating to market consolidation; issues relating to quality improvement; issues related to potential priority research topics for the effective health care program; issues related to provider conscience requirements; issues relating to the national health data stewardship; issues relating to hospital outpatient measurement and reporting, and issues relating to service provider disclosure.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Executive Office of the President (EOP), Centers For Medicare and Medicaid Services (CMS), Health & Human Services - Dept of (HHS), Labor - Dept of (DOL), Treasury - Dept of, Federal Trade Commission (FTC), Office of Personnel Management (OPM), Agency for Health Care Policy & Research, Internal Revenue Service (IRS)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Carmella |
Bocchino |
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Elizabeth |
Brooks |
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Jill |
Dowell |
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Behrends |
Foster |
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Lindy |
Hinman |
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Karen |
Ignagni |
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Alethia |
Jackson |
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Scott |
Keefer |
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Jeff |
Lemieux |
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Sue |
Rohan |
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Candace |
Schaller |
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Scott |
Styles |
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Jeanette |
Thornton |
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Kelly |
Vogel |
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Thomas |
Wilder |
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Duane |
Wright |
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Marilyn |
Zigmund Luke |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code MMM
16. Specific lobbying issues
MMM (Legislative Issues): H.R. 4: Medicare Prescription Drug Price Negotiation Act (Dingell); H.R. 976: Childrens Health Insurance Program Reauthorization Act (Rangel) (continued)
H.R. 1990: Medicare Cost Contract Extension and Refinement Act (Pomeroy); H.R. 2945: Medicare Advantage Truth in Advertising Act (Stark); H.R. 3025: Medicare Prescription Drug Savings for Our Seniors Act (Doggett); H.R. 3061: Medicare Part D Drug Class Protection Act (Doggett); H.R. 3162: Childrens Health and Medicare Protection Act (Dingell); H.R. 3932: Medicare Prescription Drug Savings and Choice Act (Berry); H.R. 3963: Childrens Health Insurance Program Reauthorization Act (Dingell); H.R. 4296: Medicare Electronic Medication and Safety Protection Act (Schwartz); H.R. 5268: Medicaid FMAP (Pallone); H.R. 5480: Medicare Funding Warning Response Act (Hoyer-Boehner); H.R. 5613: Protecting the Medicaid Safety Net Act (Dingell); H.R. 5683: GAO Act (provisions relating to access to Medicare part C/part D data) (Davis); H.R. 5998: Protecting Children's Health Coverage Act (Pallone); H.R. 6331: Medicare Improvements for Patients and Providers Act (provisions relating to Medicare Advantage, Medicare Part D, Medigap, Medicaid, health care disparities, and electronic prescribing) (Rangel-Dingell); H.R. 6388: GAO Improvement Act (provisions relating to access to Medicare part C/part D data) (Waxman); H.R. 6359: Medicare Beneficiary Protection Act (Biggert); H.R. 6365: Medicare Special Needs Plans Extension and Amendments Act (Kind); H.R. 7077: QI Program Supplemental Funding Act (Dingell) (provisions relating to cost sharing assistance for low-income Medicare beneficiaries); H.Res. 1368 (provisions relating to Medicare Funding Warning); S. 3: Medicare Prescription Drug Price Negotiation Act (Reid); S. 130: Medicare Cost Contract Extension and Refinement Act (Allard); S. 706: Medicare Advantage Stabilization Fund (Feingold); S. 799: Community Choice Act (Harkin); S. 1102: Part D Equity for Low-Income Seniors Act (Bingaman); S. 1103: Helping Fill the Medicare Rx Gap Act (Bingaman); S. 1107: Home and Community Services Copayment Equity Act (Smith); S. 1108: Medicare Part D Outreach and Enrollment Enhancement Act (Smith); S. 1200: Indian Health Care Improvement Act (includes Medicaid/MA provisions); S. 1507: Access to Medicare Data Act (Grassley); S. 1544: Medicare Quality Enhancement Act (Gregg); S. 1827: Pharmacist Access and Recognition in Medicare Act (Cochran); S. 1893: Childrens Health Insurance Program Reauthorization Act (Baucus); S. 1954: Pharmacy Access Improvement Act (Baucus); S. 2219: Medicare Prescription Drug Savings and Choice Act (Durbin); S. 2408: Medicare Electronic Medication and Safety Protection Act (Kerry); S. 2620: Medicaid FMAP (Rockefeller); S. 2662: Medicare Funding Warning Response Act (Baucus-Gregg); S. 2795: Small Business Health Options Program Act (Durbin-Snowe); S. 2819: Economic Recovery in Health Care Act (provisions relating to Medicaid funding) (Rockefeller); S. 3101: Medicare Improvements for Patients and Providers Act (provisions relating to Medicare Advantage, Medicare Part D, Medigap, Medicaid, health care disparities, electronic prescribing) (Baucus); S. 3560: QI Program Supplemental Funding Act (Baucus) (provisions relating to cost sharing assistance for low-income Medicare beneficiaries); S. 3604: Emergency Supplemental Appropriations Act (provisions relating to Medicaid FMAP); and S.J.Res. 44 (provisions relating to blocking implementation of SCHIP requirements).
MMM (Regulatory Issues)
Ongoing implementation issues for the Medicare Advantage (MA) and Medicare Part D prescription drug programs, including risk adjustment methodology and data issues, (including audit and encounter data issues) bidding and payment issues (including MA coding intensity, Part D reinsurance, low income subsidies, application process, and audits), application process, and audits, benefit design rules, SSA and CMS premium withhold processing issues, systems issues affecting enrollment and disenrollment processing, enrollment rules, marketing materials review and approval, marketing activities, including conduct and compensation of brokers and agents and plan sponsor marketing staff, measurement and oversight of plan performance including Special Needs Plans (SNPs); grievance and appeals processes, compliance/fraud and abuse training, and Medicare/Medicaid integration issues for Special Needs Plans (SNPs); Federal premption of State authority over MA and Part D plans, Part D prescription drug event data reporting, Part D formulary rules, Part D pharmacy access standards, and other operational issues; Medicare creditable drug coverage reporting requirements; implementation issues for the Medicare Retiree Drug Subsidy program; functionality of the Medicare Personal Plan Finder and Drug Plan Finder; National Medicare Education program; ongoing implementation issues for the Medicare cost plan program including enrollment, marketing materials review and approval, systems issues affecting enrollment and disenrollment processing, payment and other operational issues; Medicare demonstration program on performance-based payments for physician groups; physician quality reporting inititiative; issues relating to Medicare coverage policy and national coverage decisions; Medicare clinical trials; Medicaid managed care regulations and policies, including the Medicaid managed care actuarial soundness standard, quality oversight, grievance and appeals processes, beneficiary information requirements, treatment of Medicaid health plan member hospital days in the upper payment limit calculation; policies affecting State Medicaid funding, including intergovernmental transfers (IGTs); coordination of benefits with state Medicaid programs; Medicaid prescription drug cost/rebate issues affecting Medicaid health plans; health plan-related State Childrens Health Insurance Program (SCHIP) issues, including eligibility and outreach issues; implementation of Medicaid changes made in Deficit Reduction Act of 2005, including documentation of citizenship requirements, state benefit flexibility options, and Medicaid managed care organization provider tax issues; standards for electronic prescribing; and health information technology standards and policies.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Executive Office of the President (EOP), Centers For Medicare and Medicaid Services (CMS), Health & Human Services - Dept of (HHS)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Carmella |
Bocchino |
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Jill |
Dowell |
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Behrends |
Foster |
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Karen |
Ignagni |
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Alethia |
Jackson |
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Jeff |
Lemieux |
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Sue |
Rohan |
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Candace |
Schaller |
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Scott |
Styles |
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Kelly |
Vogel |
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Howard |
Weiss |
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Thomas |
Wilder |
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Duane |
Wright |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code PHA
16. Specific lobbying issues
PHA (Pharmacy) (Legislative): H.R. 971: Community Pharmacy Fairness Act (Weiner); H.R. 1038: Access to Life-Saving Medicine Act (Waxman); H.R. 5629: Pathway for Biosimilars Act (Eshoo-Barton) (continued)
PHA (Legislative) (continued): S. 316: Preserve Access to Affordable Generics Act (Kohl); S. 623: Access to Life-Saving Medicine Act (Schumer); S. 885: Community Pharmacy Fairness Act (Isakson); S. 1505: Affordable Biologics for Consumers Act (Gregg); S. 1695: Biologics Price Competition and Innovation Act (Kennedy)
PHA (Regulatory):
Issues relating to long term safety and effectiveness of medical devices and drugs, including registries; issues relating to post-market surveillance of drugs and medical devices; issues relating to access for investigational drugs; and issues related to electronic prescribing requirements; issues relating to e-prescribing of DEA controlled substances.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Executive Office of the President (EOP), Food & Drug Administration (FDA), Centers For Medicare and Medicaid Services (CMS), Health & Human Services - Dept of (HHS), Office of Personnel Management (OPM), Drug Enforcement Administration (DEA)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Carmella |
Bocchino |
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Jill |
Dowell |
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Behrends |
Foster |
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Karen |
Ignagni |
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Alethia |
Jackson |
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Candace |
Schaller |
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Scott |
Styles |
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Kelly |
Vogel |
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Howard |
Weiss |
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Thomas |
Wilder |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code INS
16. Specific lobbying issues
INS (Legislative): H.R. 241: Association Health Plans (Johnson); H.R. 758: Breast Cancer Patient Protection Act (DeLauro) (continued)
INS (Legislative) (cont.)
H.R. 1081: Insurance Industry Competition Act (DeFazio); H.R. 1282: Medigap Access Improvement Act (English); H.R. 1424: Paul Wellstone Mental Health and Addiction Equity Act (Kennedy); H.R. 2412: Equity in Prescription Insurance and Contraceptive Coverage Act (Lowey); H.R. 2676: Access to Cancer Clinical Trials Act (Pryce); H.R. 2842: Childrens Health Protection Act (Schwartz); H.R. 2851: Michelles Law (Hodes) (provisions relating to continuity of coverage for college students on medical leave); H.R. 3001: Community Living Assistance Services and Supports Act (Pallone); H.R. 3195: ADA Amendments Act (Hoyer); H.R. 3200: National Insurance Act (provisions relating to regulatory reform) (Bean); H.R. 3425: Cancer Screening Coverage Act (Maloney); H.R. 4460: Health Care Choice Act (provisions relating to health insurance reforms in individual market) (Shadegg); H.R. 5550: Coverage for Young Adult Dependents of Federal Employees (Davis); H.R. 5781: Federal Employees Paid Parental Leave Act (Maloney) (provisions relating to disability study); H.R. 5840: Insurance Information Act (Kanjorski) (provisions relating to federal Office of Insurance Information); H.R. 5938: Identity Theft Enforcement and Restitution Act (Conyers); H.R. 6049: Energy Improvement and Extension Act (provisions relating to mental health parity); H.R. 6071: Health Care Consumer Protection Act (Forbes) (provisions relating to reinstatement of health insurance following nonpayment of premiums); H.R. 6142: Lawsuits Against Employer-Sponsored Disability Benefit Plans (Andrews); H.R. 6210: Small Business Health Options Program Act (Kind-English); H.R. 6528: Health Insurance Coverage Protection Act (Eshoo) (provisions relating to limitations on lifetime limits); H.R. 6582: Small Business CHOICE Act (Velazquez) (provisions relating to health insurance); H.R. 6908: Health Insurance Restrictions and Limitations Clarifications Act (Burgess) (provisions relating to disclosure rules for coverage exclusions); H.R. 6983: Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act (Kennedy) (provisions relating to mental health parity); S. 40: National Insurance Act (provisions relating to regulatory reform) (Sununu); S. 46: Affordability in the Individual Market Act (provisions relating to HSAs) (Ensign); S. 239: Notification of Risk to Personal Data Act (Feinstein); S. 400: Michelle's Law (provisions relating to continuity of coverage for college students on medical leave) (Sununu); S. 459: Breast Cancer Patient Protection Act (Snowe); S. 495: Personal Data Privacy and Security Act (Leahy); S. 558: Mental Health Parity Act (Domenici); S. 616: HIPAA Recreational Injury Technical Correction Act (Collins); S. 618: Insurance Industry Competition Act (Leahy); S. 1076: HIPAA Recreational Injury Technical Correction Act (Burgess); S. 1178: Identity Theft Protection Act (Inouye); S. 1260: Data Security Act (Carper); S. 1298: Healthy Businesses, Healthy Workers Reinsurance Act (Kerry); S. 1588: Children's Access to Reconstructive Evaluation and Surgery Act (Landrieu); S. 1758: Community Living Assistance Services and Supports Act (Kennedy); S. 1814: Health Information Privacy and Security Act (Leahy); S. 2168: Identify Theft Enforcement and Restitution Act (Leahy); S. 2236: Preexisting Condition Exclusion Patient Protection Act (Rockefeller); S. 2268: Long Term Care Insurance Integrity Act (Klobuchar); S. 2477: Health Care Choice Act (DeMint); S. 2706: Health Insurance Coverage Protection Act (Dorgan); S. 2795: Small Business Health Options Program Act (Durbin-Snowe); S. 2818: Small Business Health Plans Act (Enzi); S. 2948: Small Business Empowerment Act (Brown) (provisions relating to health coverage for small employers); S. 2999: Access to Cancer Clinical Trials Act (Brown); S. 3068: Equity in Prescription Insurance and Contraceptive Coverage Act (Snowe); S. 3115: Childrens Health Protection Act (Lautenberg); S. 3335: Jobs, Energy, Families, and Disaster Relief Act (provisions relating to mental health parity); S. 3554: Affordable Coverage for Small Employers Act (Smith) (provisions relating to insurance reforms, tax credits); S. 3559: Continuing Coverage Act (Coleman) (relating to third party review for rescission decisions).
INS (Regulatory)
Insurance regulatory reform; issues related to the coordination of private and public disability income benefits; disability risk management; issues relating to the coordination of benefits between private health insurance plans and Medicaid; crossover fees for Medigap claims; Medigap carrier recoveries related to CMS fraud and abuse enforcement activities, and issues related to Medigap educational materials.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Executive Office of the President (EOP), Health & Human Services - Dept of (HHS), Labor - Dept of (DOL), Treasury - Dept of, Social Security Administration (SSA)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Carmella |
Bocchino |
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Elizabeth |
Brooks |
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Jill |
Dowell |
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Behrends |
Foster |
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Lindy |
Hinman |
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Karen |
Ignagni |
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Alethia |
Jackson |
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Scott |
Keefer |
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Jeff |
Lemieux |
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Candace |
Schaller |
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Scott |
Styles |
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Jeanette |
Thornton |
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Kelly |
Vogel |
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Thomas |
Wilder |
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Duane |
Wright |
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Marilyn |
Zigmund Luke |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TAX
16. Specific lobbying issues
TAX (Tax) (Legislative): H.R. 914: Tax Equity and Affordability Act (Ryan); H.R. 2302: Health Insurance Affordability Act (King); H.R. 2582: Qualified Long-term Care Fairness Act (Brown-Waite) (continued)
(TAX (Tax) Legislative continued) H.R. 2639: Promoting Health for Future Generations Act (provisions relating to HSAs) (Boustany); H.R. 3088: Long-Term Care Act (Terry); H.R. 3234: HSA Improvement and Expansion Act (Cantor); H.R. 3306: Flexible Health Savings Act (Royce); H.R. 3363: Long-Term Care Affordability and Security Act (Pomeroy); H.R. 3920: Trade and Globalization Assistance Act (provisions relating to health care tax credits, COBRA continuation coverage, health insurance reforms) (Rangel); H.R. 5559: Long-Term Care and Retirement Security Act (Putnam); H.R. 5719: Taxpayer Assistance and Simplification Act (HSA provision); H.R. 6237: Tax Relief for Long-Term Care Act (Courtney); H.R. 7095: Comprehensive Long-Term Care Support (Sandlin) (provisions relating to LTC tax deduction); H.R. 7148: Beneficiary Freedom to Choose Act (Johnson) (provisions relating to HSA improvements); S. 397: Tax Equity and Affordability Act (Martinez); S. 504: Long-Term Care Trust Account Act (Smith); S. 897: Alzheimer's Family Assistance Act (Mikulski); S. 1809: Long-Term Care Act (Thune); S. 2237: Long-Term Care Affordability and Security Act (Grassley); S. 2835: Health Care Equity Act (DeMint); and S. 3626: Family Retirement and Health Investment Act (Hatch) (provisions relating to HSA improvements).
TAX (Tax) Regulatory: Issues relating to Health Savings Accounts; issues relating to application of rules regarding excise tax reporting; and issues relating to withholding of government contract payments.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Executive Office of the President (EOP)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Behrends |
Foster |
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Karen |
Ignagni |
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Alethia |
Jackson |
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Scott |
Keefer |
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Scott |
Styles |
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Kelly |
Vogel |
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Thomas |
Wilder |
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Marilyn |
Zigmund Luke |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address: http://www.ahip.org/content/default.aspx?bc=31|42|54
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
1 | 3 | 5 |
2 | 4 | 6 |
FOREIGN ENTITIES
27. Add the following foreign entities:
Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
1 | 5 | 9 |
2 | 6 | 10 |
3 | 7 | 11 |
4 | 8 | 12 |