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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 555 WEST 57TH STREET |
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City | NEW YORK |
State | NY |
Zip Code | 10019 |
Country | USA |
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5. Senate ID# 16830-12
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6. House ID# 324950000
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TYPE OF REPORT | 8. Year | 2016 |
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. | ||||||||
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: David Rich |
Date | 1/18/2017 10:00:04 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 HCR
16. Specific lobbying issues
Organ donation issues, including the liver transplant allocation system and in support of new proposed UNOS system; support Ebola funding for hospital preparedness and treatment activities, including NY delegation letter to HHS and calls to HHS and meetings with Administration officials; Ebola funding language including in the Consolidated Appropriations Act of 2016 (Omnibus legislation/Senate amendment to H.R. 2029) - support; support for Zika supplemental funding; The Living Donor Protection Act of 2016 (H.R.4616/S.2584) - support; The Standard Merger and Acquisition Reviews Through Equal Rules Act (H.R. 2745) - support; proposed changes to regulation of Laboratory Developed Tests (FDA-2011-D-0360-Draft Guidance for Industry, Food and Drug Administration Staff and Clinical Laboratories: Framework for Regulatory Oversight of Laboratory Developed Tests) - oppose; Congressional letter supporting reforms to the liver transplant allocation system - support; discussions with HHS regarding how to handle cybersecurity issues; hospital issues related to repeal and replace of the Affordable Care Act; Senate Finance Committee guidance on concurrent surgeries.
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), Health Resources & Services Administration (HRSA), Centers For Disease Control & Prevention (CDC), Centers For Medicare and Medicaid Services (CMS), Office of Management & Budget (OMB), White House Office, Food & Drug Administration (FDA)
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 |
Kenneth |
Raske |
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David |
Rich |
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Jonathan |
Cooper |
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Susan |
Waltman |
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Elisabeth |
Wynn |
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Bruce |
Vladeck |
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Lloyd |
Bishop |
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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
Graduate Medical Education (GME) issues (including Resident Physician Shortage Reduction Act (H.R.2124/S.1148) - support); provided comments to Congress in response to Energy and Commerce Committee request for input on GME; amendments to the Medicare hospital re-admissions penalty program methodology (providing SES adjustments, fixing the formula flaw), H.R.1343/S.688 - support; proposals to amend the 2 midnight policy - support; hospital issues included in President Obama's FY 16 budget - oppose; hospital issues included in H.R.2, the Medicare Access and CHIP Re-authorization Act of 2015 - support; legislation to create a comprehensive Medicare home infusion benefit (H.R.605/S.275) - support; Strengthening Medicare Advantage through Innovation and Transparency for Seniors (H.R.2570) - oppose; Medicare Inpatient Prospective Payment System FY 2016 proposed rule (CMS 1632-P) - detailed comment letter; legislation to improve the recovery audit contractor program (H.R.2156); Audit and Appeal Fairness, Integrity and Reforms in Medicare Act (AFIRM) - provided comments to the Senate Finance Committee; Ensuring Seniors Access to Local Pharmacies Act of 2015 (H.R.793/S.1190) - support; Pharmacy and Medically Underserved Areas Enhancement Act (H.R.592/S.314) - support; MAC Transparency Act (H.R.244) - support; Medication Therapy Management Act (S.776) - support; CMS-4159-F2 - comments on daily dispensing fees; Medicare Independence at Home Medical Practice Demonstration Improvement Act of 2015 (P.L.114-39) - support; provided comments on the proposed Medicare outpatient prospective payment system rule (CMS-1633-P); Medicare IME Pool Act of 2015 (H.R.3292) - oppose; Strengthening DSH and Medicare through Subsidy Recapture and Payment Reform Act (H.R.3288) - oppose; Medicare Crosswalk Hospital Code Development Act (H.R. 3291) - oppose; sign-on letter to CMS urging it to reconsider negative update for CY 2016 (CMS-1633-P) - support; proposed Medicare and Medicaid cuts as offsets to pay for budget increases, raising the debt ceiling, etc. - oppose; site neutral hospital outpatient cuts and other hospital related provisions included in the Bipartisan Budget Act of 2015 (H.R. 1314) - oppose; legislative proposals (H.R. 5273)and Congressional letters to amend the Bipartisan Budget Acts site neutral hospital outpatient payment cut to grandfather sites under development as well as other legislative changes (support) - advocated for their inclusion in the Consolidated Appropriations Act of 2016 (Omnibus legislation/Senate amendment to H.R. 2029); provided comments to Congress regarding provisions in the Mental Health Reform Act of 2015 (S. 1945), that would reform how health care information for substance abuse patients is shared; met with HHS officials on Medicare and Medicaid issues of importance to the Commonwealth of Puerto Rico and Puerto Rican health care providers; submitted comments on Medicare and Medicaid Programs: Reform of Requirements for Long-Term Care Facilities (CMS-3260-P); Stopping Medication Abuse and Protecting Seniors Act of 2015 (S.1913) - support (with some concerns about pharmacy lock-in policy); hospital issues included in House FY 17 budget - oppose; hosptial issues included in President Obama's FY 17 budget proposal - oppose; provided comments in response to Energy and Commerce Committee request for input on hospital site-neutral issues; Medicaid provisions included in the Common Sense Savings Act of 2016 (H.R.4725) - oppose; provided comments to CMS and Congress regarding the Hospital Compare Star Ratings for hospitals - support for delay and fixing measures; The Fair Medicare Hospital Payments Act of 2016 (H.R. 4428) - oppose; provided comments to CMS on hospital site-neutral proposals - argued for flexibility in the anticipated OPPS proposed rule; provided comments to CMS on the FY 17 IPPS proposed rule (CMS-1655-P) with a focus on opposition to the proposed Medicare DSH policy and provided input to Capitol Hill and the Administration;submitted comments on Medicaid Program,Covered Outpatient Drugs (CMS-2345-FC); asked Congressional members to urge CMS to finalize its 2014 proposed guidance to Part D drug plans and PBMs regarding consistent reporting of Direct and Indirect Remuneration (DIR); Improving Transparency & Accuracy in Medicare Part D Spending (S.3308/H.R.5957) - support; testified at House Ways and Means Health Subcommittee hearing entitled "Incentivizing Quality Outcomes in Medicare Part A" in support of streamlining hospital measures and reporting; provided comments regarding the Medicare OPPS CY2017 proposed rule (81 FR 45603), in particular in opposition to implementation of site-neutral proposals; provided comments on Merit Based Incentive Payment System (MIPS)and Alternative Payment Models (APMs) under MACRA 2015 (81 FR 28161); discussions with CMS regarding priority categories for redistribution of Medicare-funded residency slots; discussions with CMS to encourage consistency in hospital surveys; submitted comments on the Part B Drug Payment Model proposed rule (CMS-1670-P) - serious concerns; submitted comments on the SNF PPS proposed rule (CMS-1645-P) - serious concerns; Texas proposed Medicaid State Plan Amendment (15-005) in response to the CMS Covered Outpatient Drug Rule (CMS-2345-FC) - concerns; submitted comments to CMS about its proposal to expand testing of mandatory, risk-based bundled payments for acute episodes of care - oppose; 21st Century Cures Act (H.R. 34, now P.L.114-255) provisions that apply to site neutral, readmissions, and other hospital reimbursement issue - support.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, White House Office, Health & Human Services - Dept of (HHS), Centers For Medicare and Medicaid Services (CMS)
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 |
Kenneth |
Raske |
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David |
Rich |
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Jonathan |
Cooper |
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Karen |
Heller |
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Elisabeth |
Wynn |
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Timothy |
Johnson |
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Kathleen |
Shure |
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Aisling |
Zaccarelli |
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Lee |
Perlman |
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Laura |
Alfredo |
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Shara |
Siegel |
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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
Reducing the costs of pharmaceuticals, medical devices, and supplies for consumers and health care providers, including implementation of the Drug Quality and Security Act (P.L.113-54) and P.L.112-144; support medical device pricing transparency and prohibition on medical device price "gag clauses"; preserving access to group purchasing organizations (GPOs) and protecting the GPO safe harbor; educating policymakers on hospital drug shortages and significant drug price increases and support draft reform legislation; pharmaceutical labeling of generic drugs (FDA-2013-N-0500); legislation to create a comprehensive Medicare home infusion benefit (H.R.605/S.275) - support; support reforming the durable medical equipment competitive bidding program; supporting "any willing pharmacy" legislation; promoting access to biosimilars (labeling/interchangeability); 21st Century Cures Act (H.R.6) - general support for overall bill, support final pharmacy lock-in policy, oppose PPSA weakening of existing requirements, oppose Section 4004 treatment of infusion drugs furnished through durable medical equipment, oppose use of savings from home infusion payment reform for purposes other than creating a Medicare home infusion benefit; Ensuring Seniors Access to Local Pharmacies Act (H.R.793/S.1190) - support; Pharmacy and Medically Underserved Areas Enhancement Act (H.R.592/S.314) - support; MAC Transparency Act (H.R.244) - support; Medication Therapy Management Empowerment Act (S.776) - support; Strengthening Medicare Advantage Through Innovation and Transparency for Seniors - oppose; FDA-2014-D-1524-0002 - comments, Administration and Capitol Hill meetings on draft guidance on repackaging of certain human drug products by pharmacies and outsourcing facilities; FDA-2014-N-1459 - comments and Capitol Hill meetings on draft MOU addressing certain distributions of compounded human drug products between states and the FDA; proposed changes to the 340B prescription drug program - oppose; 21st Century Cures Act (H.R.6, now P.L.114-255) - support, but with serious concerns about the misalignment of implementation dates for two home infusion provisions - oppose implementation of Section 5004 (a) without aligning the start date of the new Medicare home infusion service benefit in Section 5012; proposed amendments to 340b program (not ultimately included in H.R.6) - oppose; provide comments on proposed 340b omnibus guidance (RIN 0906 AB08); Stopping Medication Abuse and Protecting Seniors Act of 2015 (S.1913)- support (with some concerns about pharmacy lock-in policy); submitted comments on Management Standards for Hazardous Waste Pharmaceuticals (EPA-HQ-RCRA-2007-0932); meeting with DEA on Controlled Substances Act (21 USC 802); proposed changes to regulation of Laboratory Developed Tests (FDA-2011-D-0360-Draft Guidance for Industry, Food and Drug Administration Staff and Clinical Laboratories: Framework for Regulatory Oversight of Laboratory Developed Tests) - oppose; Comprehensive Addiction and Recovery Act of 2016 ((S.524), monitoring for pharmacy lock-in policy, which includes exemption for LTC) - support; Increasing Competition in Pharmaceuticals Act (S.2615/H.R.4784) - support; CREATES Act addressing REMS abuses (S.3056) - support; submitted comments in response to HRSA proposed rule establishing an Administrative Dispute Resolution (ADR) Process for the 340B Drug Purchasing Program (81 Fed. Reg. 53,381).
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), Food & Drug Administration (FDA), Health & Human Services - Dept of (HHS), Health Resources & Services Administration (HRSA), Drug Enforcement Administration (DEA), Environmental Protection Agency (EPA)
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 |
Kenneth |
Raske |
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Lee |
Perlman |
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Aisling |
Zaccarelli |
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David |
Rich |
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Jonathan |
Cooper |
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Shara |
Siegel |
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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 BUD
16. Specific lobbying issues
House and Senate Budget Resolutions, provisions relating to Medicare reductions - oppose (H.Con.Res. 27, S.Con.Res.11)
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 |
Kenneth |
Raske |
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David |
Rich |
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Jonathan |
Cooper |
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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 LBR
16. Specific lobbying issues
The Standard Merger and Acquisition Act of 2016 (H.R.4616/S.2584) - support.
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 |
Jonathan |
Cooper |
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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 VET
16. Specific lobbying issues
State Veterans Home Adult Day Health Care Improvement Act of 2016 (H.R.2460/S.3198) - support.
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 |
Jonathan |
Cooper |
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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.
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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: www.gnyhaventures.com
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GNYHA Ventures, Inc. |
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GNYHA Services, Inc. |
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Innovatix, LLC |
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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:
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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 |