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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 799 9th St NW |
Address2 | Suite 210 |
| City | WASHINGTON |
State | DC |
Zip Code | 20001 |
Country | USA |
3. Principal place of business (if different than line 2)
| City | Irving |
State | TX |
Zip Code | 75062 |
Country | USA |
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5. Senate ID# 40021-00012
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6. House ID# 313240000
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| TYPE OF REPORT | 8. Year | 2025 |
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 |
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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. | ||||||||
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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 |
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| Signature | Digitally Signed By: Shoshana Krilow |
Date | 10/20/2025 10:26:49 AM |
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
Acute Hospital Care at Home - Recommended Congress make certain flexibilities related to the Acute Hospital Care at Home Program permanent or, pass an extension before flexibilities expire.
Issues related to hospital and provider payment - Supported increasing hospital reimbursement to ensure continued access to care for vulnerable populations, highlighted the criticality of Medicaid to sustaining vital healthcare services.
Medicaid Disproportionate Share Hospital (DSH) Program - Urged Congress to avert the cuts to Medicaid DSH payments set to take place, encouraged passage of legislation to preserve DSH payments on a longer-term basis
Medicaid Program; Preserving Medicaid Funding for Vulnerable Populations- Closing a Health Care-Related Tax Loophole Proposed Rule (CMS- 2448-P) - Responded to various issues and proposals provided in the Proposed Rule and encouraged the agency to identify alternative approaches that would be less disruptive to state Medicaid programs.
Medicare and Medicaid Programs; CY 2026 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; Quality Reporting Programs; Overall Hospital Quality Star Ratings; and Hospital Price Transparency (CMS-1834-P) proposed rule - Responded to various issues and proposals provided in the Proposed Rule and offered our responses to the agencys various requests for information.
Medicare and Medicaid Programs; CY 2026 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program (CMS-1832-P) proposed rule - Responded to various issues and proposals provided in the Proposed Rule and offered our responses to the agencys various requests for information.
Medicare Program; Implementation of Prior Authorization for Select Services under the WISeR Model (CMS-5056-N) - Offered recommendations to strengthen transparency, reduce administrative burden and ensure provider perspectives inform implementation and oversight
Monitored development and passage of the One Big Beautiful Bill Act (H.R.1)
Physician Payment - Urged Congress to consider long-term legislative solutions to refine the current Medicare physician payment system
Prior Authorization - Provided feedback to improve prior authorization (PA) processes for various plans and payers, including MA organizations and Medicaid managed care plans. Monitored development of the Medicare Advantage Prompt Pay Act (H.R.5454)
Rural Emergency Hospital (REH) Designation - Urged corrective action to allow REHs to bill both the Medicare and Medicaid programs. Advocated for increased eligibility among REHs to allow for future Medicaid DSH payments to certain hospital facilities.
Site-Neutral Payment Policies - Opposed adoption of site-neutral payment policies for drug administration and increased fines related to price transparency requirements for hospitals. Urged Congress to redirect its focus from site-neutral payment policies to reducing administrative burdens and increasing, rather than reducing, payments for care delivery in rural areas.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, 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 |
Shoshana |
Krilow |
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Jenna |
Stern |
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Darren |
Webb |
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Alexandria |
Icenhower |
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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 HCR
16. Specific lobbying issues
340B Drug Pricing Program - Continued to urge action to ensure covered entities have access to 340B discounted prices through contract pharmacies. Highlighted critical importance of the 340B program for hospitals.
340B Program Notice: Application Process for the 340B Rebate Model Pilot Program (HHS Docket No. HRSA-2025-14619) - Provide feedback to the Health Resources and Services Administration (HRSA) Office of Pharmacy Affairs (OPA) notice and request for comments (RFC) regarding the application process for the 340B Rebate Model Pilot Program
Drug shortages - Supported elements to increase transparency in prescription drug supply chain and increase reimbursement for generic prescription drugs; issues related to compounding; issues related to buffer inventory. Encouraged improved stakeholder communication and increased notification by manufacturers for a surges in demand
Endorsed passage of the Mapping Americas Pharmaceutical Supply (MAPS) Act (S.1784/H.R.4191)
Endorsed passage of the Biosimilar Red Tape Elimination Act (S.1954)
Endorsed passage of the Resident Physician Shortage Reduction Act of 2025 (S.2439/H.R.3890/H.R.4731)
Endorsed passage of the Protect Medicaid and Rural Hospitals Act (S.2279)
Endorsed passage of the Protecting Health Care and Lowering Costs Act (S.2556)
Hospital Group Purchasing - Advocated to highlight the value that hospital group purchasing organizations provide to hospitals and suppliers. Provided education on how GPOs work in the healthcare supply chain and the role they play in delivering value to healthcare providers, as well as key differences between traditional GPOs and PBMs.
Hospital Price Transparency - Responded to CMS Hospital Price Transparency Accuracy and Completeness Request for Information (RFI), urge the agency to alleviate excessive administrative burden on providers.
Monitored development and passage of the One Big Beautiful Bill Act (H.R.1)
Mental and Behavioral Health - Highlighted the need for legislation to address significant challenges to mental and behavioral health treatment, including increased demand for services, limited access to treatment, and clinician shortages.
Non-medical drivers of health outcomes - Encouraged Congress and agencies to ensure tools like the Vizient Vulnerability Index are being utilized to understand data about disparities in health. Highlighted opportunities for the increased use of secondary health data in a clinical setting.
Payer-mandated White Bagging - Urged support for policy updates related to payer-mandated white bagging for medications
Rural healthcare - Advocated for policies and initiatives that address the challenges of rural communities by promoting access to care and strengthening healthcare infrastructure
Telehealth - Continued to advocate for the adoption of permanent telehealth policies to extend flexibilities beyond the current expiration date.
Ultra-Processed Foods; RFI (Docket No. FDA-2025-N-1793) - Responded to FDA and USDAs request for information encouraging efforts to consider a uniform, science-based definition of UPFs through coordinated federal efforts
Workforce - Advocated for strengthening the health workforce through policies that support education, training, recruitment, and retention efforts. Continued monitoring and encouraged passage of the Save Healthcare Workers Act (S.1600/H.R.3178). Hosted congressional briefing educating Senate and House staff on the education and training needs to address healthcare worker shortages, burnout and workplace violence.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Health & Human Services - Dept of (HHS), Centers For Medicare and Medicaid Services (CMS), Agriculture - Dept of (USDA), Health Resources & Services Administration (HRSA)
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 |
Shoshana |
Krilow |
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Jenna |
Stern |
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Darren |
Webb |
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Alexandria |
Icenhower |
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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
Monitored development and passage of the One Big Beautiful Bill Act (H.R.1)
Not-for-Profit Hospital Tax-exemption - Provided education and information on hospital tax exemption and what is required to justify and maintain tax-exempt status.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
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 |
Shoshana |
Krilow |
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Jenna |
Stern |
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Darren |
Webb |
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Alexandria |
Icenhower |
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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 TAR
16. Specific lobbying issues
Imports of personal protective equipment (PPE), medical consumables, and medical equipment, including Devices: Monitored and provided feedback on U.S. Department of Commerces Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices (Docket No: 250924-0160; XRIN 0694-XC134)
Monitored development of the Medical Supply Chain Resiliency Act (S.998/HR.2213)
United States and European Union Cooperation Agreement on Reciprocal, Fair and Balanced Trade - Monitored Implementation and passage of agreement, with focus on tariff barriers.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Commerce - Dept of (DOC)
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 |
Shoshana |
Krilow |
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Jenna |
Stern |
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Darren |
Webb |
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Alexandria |
Icenhower |
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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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21. Client new principal place of business (if different than line 20)
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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:
| Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
| 1 | 2 | 3 |
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 | 3 | 5 |
| 2 | 4 | 6 |
CONVICTIONS DISCLOSURE
29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery,
extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
| Lobbyist Name | Description of Offense(s) |