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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 1000 NORTH OAK AVENUE |
Address2 |
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City | MARSHFIELD |
State | WI |
Zip Code | 54449-5777 |
Country | USA |
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5. Senate ID# 57830-12
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6. House ID# 352550000
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TYPE OF REPORT | 8. Year | 2018 |
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: Brent V. Miller |
Date | 1/17/2019 10:15:07 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 BUD
16. Specific lobbying issues
BUD (Budget and Appropriations)
National Farm Safety
We requested support for occupational safety and health funding for Fiscal Year 2019. The National Institute for Occupational Safety and Health (NIOSH) is the primary federal agency responsible for conducting research and making recommendations for the prevention of work-related illness and injury. NIOSH provides leadership to avert workplace illness, injury, disability, and death and supports programs to improve the health and safety of workers. NIOSH funds the National Childrens Center for Rural and Agricultural Health and Safety. Marshfield Clinic urges support for this important program.
AmeriCorps Funding
We supported continued Funding of the AmeriCorps program in fiscal year 2019.
Market Stability in budget reconciliation or continuing resolution legislation
We urged Congress to take steps to improve and repair health coverage in the areas where the ACA was falling short, and to also maintain the gains that the ACA has provided to assure that no one, especially those near poverty, fall through the cracks:
Stabilizing the market - Regulatory relief offered earlier this year by HHS gave health insurers tools to better manage their ACA individual population, but those reforms didnt go far enough to fully stabilize the market. We believe that the suggestions below will improve the ACA and ensure coverage for vulnerable populations.
a. Cost sharing reduction payments - SHPs ACA individual population is heavily reliant on the cost sharing reduction (CSR) subsides paid monthly to help our members lower their out-of-pocket costs. Nearly half of the total enrollment in SHPs ACA products is eligible and enrolled in this important program. We recommend that Congress should fully fund CSR payments to health insurance carriers for 2018 and beyond and allow states that have already reached their filing deadline to reopen carriers bids to allow for an adjustment to rates.
b. Extension of the reinsurance program - The transitional reinsurance program established by the ACA helped to hold down premiums in 2014, 2015 and 2016. Our Plans experience shows that premiums would have been nearly 20 percent higher in 2014 and 6 percent higher in 2015, had this program not been in effect. We recommend that Congress create a reinsurance program similar to the program that expired in 2017 to stabilize premiums in the ACA individual market for the long term.
c. Continuous coverage provision - The ACA provisions that provide for a three-month grace period and avoid tax penalties has created a perverse incentive for enrollees to stay insured for just enough time to avoid the penalty. We recommend that Congress should create a continuous enrollment provision or late enrollment penalty similar to Medicares Part B and Part D to incentivize 12 month enrollment in the ACA individual market.
d. Risk adjustment program enhancements - We recommend that HHS risk adjustment program should pay carriers a capitation for members whose risk scores exceed a certain predefined value. Lower-than-current future rate increases would reduce expenditures for the advanced premium tax credits.
e. Federal funding for enrollee outreach - Health insurance and the subsidies available to help area residents afford coverage is a complex and confusing topic. We recommend that navigator services should be re-instated and funds prioritized to rural areas for community outreach.
Challenges of serving rural Wisconsin. We serve about 1 million residents in our rural area Subsidization of health coverage for low income Wisconsinites has helped mainstream tens of thousands into traditional commercial coverage through the Health Insurance Marketplace. This has been vital to the health of our patients enabling us to educate patients and include them in prevention programs.
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)
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 |
Brent |
Miller |
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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
Many aspects of the Affordable Care Act promote changes that are consistent with the mission of the Marshfield Clinic:
Extends health insurance to the uninsured
Calls for Value Based Purchasing for all providers
The following are key elements of the health policy agenda of the Marshfield Clinic Health System:
Medicare Access and CHIP Reauthorization Act
With passage of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), Medicare physician payments will transition to an incentive-based system based on value and accountability. Starting in 2019, Medicare physician payment will be based on the Merit-Based Incentive Payment System (MIPS). Physicians who perform well on quality, value and IT metrics will be rewarded with higher pay rates and those who perform poorly will face penalties. Because the language of the statute is not specific, the Centers for Medicare and Medicaid Services (CMS) is developing metrics that will be used to determine the bonus payments and penalties that will start in 2019. The proposed metrics simplify and consolidate the existing measurements employed under the Meaningful Use Incentive Program, the Physician Reporting System (PQRS), and the Value-Based Modifier (VBM) to streamline the reporting burden for physician practices. MIPS will then pay physicians based on four weighted performance categories: Quality, Advancing Care Information; Clinical Practice Improvement Activities; and Resource Use. Having a source of credible data as the foundation of CMS metrics is critical both to fair payment and maintaining access to medical services in rural areas. We expressed concerns about the dilution of incentives payments for good performance, due to the increased number of exceptions from MACRA requirements.
Federal funding for children with complex medical needs
We asked for assistance in funding care coordination for children with complex medical needs.
Medicare Advantage
The Medicare Advantage program provides a full-risk, capitated reimbursement to health plans for all Medicare benefits provided to enrolled beneficiaries. We believe that mechanisms for rewarding value in the Medicare Advantage program should offer incentives for those plans that demonstrate superior patient care performance. We recommend that performance bonuses should be provided for plans that: Achieve predetermined quality performance targets; Adopt health information technology; Meet standards for care coordination; and Provide data on comparative effectiveness.
The Medicare Advantage Benchmark Cap - ACA SEC. 3201. (b) (4) By authorizing Quality Incentive Payments for MA plans with star ratings of 4 stars and above, Congress made a significant policy change towards value-based purchasing in the MA program. If a plan is eligible for a Quality Incentive Payment, it receives it in the form of a 5 percent increase to its benchmark. However, Congress also authorized a new methodology for calculating benchmarks, and mandated that benchmarks under the new methodology cannot be greater than what they would have been under the old benchmark methodology. This is the benchmark cap. The benchmark cap reduces or even eliminates Quality Incentive Payments.
The policy issue is that the cap weakens the incentive for plans to attain higher star ratings and undermines the shift towards paying for performance in the MA program. We do not think that Congress intended to take away with one provision (the cap) the significant policy change towards paying for value that it enacted in the ACA. This change will have a significant negative impact on Medicare Advantage beneficiaries. CMS has indicated that it wants to remove the cap administratively, and we believe that HHS and CMS have the discretionary authority under law to make the necessary changes. If HHS and CMS do not make the change, then a statutory change will be necessary in the 115th Congress. The benchmark cap costs Medicare Advantage enrollees in Security Health Plans population more than $25 more in their monthly premium.
We supported HR 4952 introduced by Rep Ron Kind that calls for an HHS study and report of the effects of the inclusion of quality increases in the determination of blended benchmark amounts under part C of the Medicare Program.
Graduate Medical Education
MCHS is concerned about having a sufficient supply of primary care physicians to meet the demands of an expanding and aging population. This is doubly true for patients and health systems in rural settings. Currently only about 10% of physicians practice in rural areas while 25% of the population resides there. While 36% allopathic residents and 50% osteopathic residents who are trained in a rural residency end up practicing in a rural area, only 4% of the residency training actually occurs in rural areas. Currently there are more US medical students graduating from medical school than there are GME slots. An increase in GME primary care training positions is essential to maintaining high-quality, accessible, and cost efficient care.
Teaching hospitals in rural locations provide an environment for residents to learn and faculty to serve as educators, providers and researchers. These roles advance the broad mission of preparing each generation of physicians, provide critical patient care and specialized services, often to the disadvantaged, facilitate the discovery of new therapies and treatments, and enable residents to acclimate to the rural setting. As new payment and delivery models emphasize primary care to improve patient outcomes and reduce costs, and as more care shifts to outpatient settings, teaching faculty and residency programs must increase access to ambulatory residency rotations to serve Americans who live in areas with an under-supply of primary care physicians including Geriatrics and Psychiatry. The purpose and value of residency training in clinical settings and the financial support needed to sustain physician education will only increase as the U.S. population lives longer with more complex health conditions. To ensure GME can meet the future needs of the newly insured and aging population, Congress must commit to the consistent GME funding and lift Medicares limit on funded residency positions. We support the Teaching Health Center funding in the Medicare Access and CHIP Reauthorization ACT (MACRA) for Community Health Centers but request you extend funding beyond 2017.
Geographic Adjustment of Physician Payments
Recent findings by the Institute of Medicine (IOM) and the Medicare Payment Advisory Commission have demonstrated significant shortcomings in the data utilized to geographically adjust physician payments. The IOM and MedPAC studies have confirmed that the data sources currently relied upon for geographic adjustment bear no correlation to physician earnings. CMS officials have admitted that the proxies utilized for the purpose of geographic adjustment have never been validated, and there never has been a new data source utilized in the twenty years since the fee schedule was implemented. MedPAC data show that the geographic adjustment reference occupations predict earnings of rural physicians to be 25-30% less than physicians in metropolitan areas. MedPAC data show that earnings of primary care physicians in rural areas are, in fact, 13% higher than physicians in metropolitan areas. Since there is no statistical basis of support for disparities in payment we strongly recommend that Congress require CMS to correct this inequity immediately. These corrections are necessary to assure the credibility of the changes enacted in MACRA. We supported congressional requests for additional research by the GAO to understand the discrepancies in rural costs and reimbursement.
Telemedicine in Medicare
Changes to Medicare law and regulation are needed to improve equity in access for Medicare beneficiaries to services delivered via TeleHealth. Medicare beneficiaries should be allowed to receive services in telemedicine sites located in urban areas. The necessary changes would remove restrictions on originating sites by removing the rural requirement and the list of originating sites and allowing any certified Medicare facility to provide the services; current requirements that physician must bill for services from the originating site should be removed; restrictions on eligible practitioners should be removed to allow all Medicare approved practitioners to provide telemedicine services; and there should be no restrictions on which Medicare services may be provided through telemedicine. We recommend that the Medicare requirement for non-MSA geographic location of the patient be expanded to allow all Medicare certified organizations as originating sites regardless of rural or metropolitan statistical area designation.
In addition, MCHS supports the CONNECT for Health Act that contains a provision which would permit Medicare Advantage plans to use telehealth or remote patient monitoring technologies to provide basic Medicare benefits, without the restrictions that limit originating sites, geographic locations, store-and-forward technologies, and types of health care provider. We believe that telehealth is a different way of delivering an already covered service, and that Medicare should treat remote access technologies as an alternative modality or complementary means of providing clinical services, and not a service itself. In other words, telehealth should not be seen as simply a supplement or complement to face-to-face encounters. Patients increasingly expect their health plans to provide the access to services and convenience that remote technologies facilitate. These technologies can increase communication between providers and patients, enhance care coordination, and help physicians and patients work together to treat illness and maintaining health.
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)
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 |
Brent |
Miller |
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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
HCR (Health Issues)
National Farm Safety
Support for occupational safety and health funding for Fiscal Year 2015. The National Institute for Occupational Safety and Health (NIOSH) is the primary federal agency responsible for conducting research and making recommendations for the prevention of work-related illness and injury. NIOSH provides leadership to avert workplace illness, injury, disability, and death and supports programs to improve the health and safety of workers. NIOSH funds the National Childrens Center for Rural and Agricultural Health and Safety. Marshfield Clinic urges support for this important program.
Accountability in Drug Pricing
MCHS and Security health Plan have supported the FAIR Drug Pricing Act Introduced by U.S. Senators Tammy Baldwin (D-WI) and John McCain (R-AZ) and U.S. Representative Jan Schakowsky (D-IL). The legislation takes the first step in addressing skyrocketing prescription drug prices by requiring transparency for pharmaceutical corporations that plan to increase drug prices.
Overdose Prevention and Patient Safety (OPPS) Act, H.R. 6082
This bill amends the Public Health Service Act to align federal privacy standards for substance use disorder (SUD) patient records more closely with standards under the Health Insurance Portability and Accountability Act (HIPAA). Specifically, the bill authorizes the disclosure of SUD patient records without a patient's written consent to: (1) a covered entity for the purposes of treatment, payment, and health care operations, as long as the disclosure is made in accordance with HIPAA; and (2) a public health authority, as long as the content of the disclosure meets HIPAA standards regarding de-identified information. Current law authorizes disclosure of SUD patient records without a patient's written consent only to medical personnel in a medical emergency, to specified personnel for research or program evaluations, or pursuant to a court order.
The House bill, the SUPPORT for Patients and Communities Act, H.R. 6, and the Senate bill, the Opioid Crisis Response Act represent critical steps in addressing the nations opioid epidemic. We strongly urge you to include the Overdose Prevention and Patient Safety (OPPS) Act, H.R. 6082, in the final opioid agreement. This language will bolster the effectiveness of other key provisions in the package that promote coordinated care and expand access to treatment.
Part 2, federal regulations that govern confidentiality of drug and alcohol treatment and prevention records, sets requirements limiting the use and disclosure of patients substance use records from certain substance use programs. Patients are required to give multiple consents, creating a barrier for integration and coordination of health care. A lack of access to the full scope of medical information for each patient can result in the inability of providers and organizations to deliver safe, high-quality treatment and care coordination. The barriers presented by Part 2 can result in the failure to integrate services and can lead to potentially dangerous medical situations for patients.
As Congress works to reconcile both chambers opioid bills, the inclusion of provisions to align Part 2 with HIPAA for TPO is critical. Modifying Part 2 to ensure that HIPAA-covered entities have access to a patients entire medical record will improve patient safety, treatment, and outcomes across the care delivery spectrum, enhancing the entire opioid package.
MCHS believes that the modernization of privacy regulations and medical records for persons with substance use disorders is a critical component for tackling the opioid crisis and will improve the overall coordination of care in the United States. We urge you to include H.R. 6082 in the final opioids agreement sent to the President.
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)
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 |
Brent |
Miller |
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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
VA Choice program
We have asked for assistance to resolve administrative problems with Health Net Federal Services in the VA Choice program.
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 |
Brent |
Miller |
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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 (Insurance)
Market Stability in budget reconciliation legislation
HR 1628, the American Health Care Act (AHCA) and the Better Care Reconciliation Act (BRCA) will result in a large number of individuals covered under the Affordable Care Act (ACA) with preexisting conditions to lose the necessary coverage to maintain their health. MCHS recommended opposition to the AHCA, BRCA, and any changes to the coverage afforded by the ACA. The changes proposed under the AHCA and BRCA will undermine what works in the ACA without improving on the circumstances, coverage and care of Wisconsin residents in the individual and small group market.
We urged Congress to take steps to improve and repair health coverage in the areas where the ACA was falling short, and to also maintain the gains that the ACA has provided to assure that no one, especially those near poverty, fall through the cracks:
Stabilizing the market - Regulatory relief offered earlier this year by Secretary Tom Price at HHS gave health insurers tools to better manage their ACA individual population, but those reforms didnt go far enough to fully stabilize the market. We believe that the suggestions below will improve the ACA and ensure coverage for vulnerable populations.
a. Cost sharing reduction payments - SHPs ACA individual population is heavily reliant on the cost sharing reduction (CSR) subsides paid monthly to help our members lower their out-of-pocket costs. Nearly half of the total enrollment in SHPs ACA products is eligible and enrolled in this important program. We recommend that Congress should fully fund CSR payments to health insurance carriers for 2018 and beyond and allow states that have already reached their filing deadline to reopen carriers bids to allow for an adjustment to rates.
b. Extension of the reinsurance program - The transitional reinsurance program established by the ACA helped to hold down premiums in 2014, 2015 and 2016. Our Plans experience shows that premiums would have been nearly 20 percent higher in 2014 and 6 percent higher in 2015, had this program not been in effect. We recommend that Congress create a reinsurance program similar to the program that expired in 2017 to stabilize premiums in the ACA individual market for the long term.
c. Continuous coverage provision - The ACA provisions that provide for a three-month grace period and avoid tax penalties has created a perverse incentive for enrollees to stay insured for just enough time to avoid the penalty. We recommend that Congress should create a continuous enrollment provision or late enrollment penalty similar to Medicares Part B and Part D to incentivize 12 month enrollment in the ACA individual market.
d. Risk adjustment program enhancements - We recommend that HHS risk adjustment program should pay carriers a capitation for members whose risk scores exceed a certain predefined value. Lower-than-current future rate increases would reduce expenditures for the advanced premium tax credits.
e. Federal funding for enrollee outreach - Health insurance and the subsidies available to help area residents afford coverage is a complex and confusing topic. We recommend that navigator services should be re-instated and funds prioritized to rural areas for community outreach.
Challenges of serving rural Wisconsin . We serve about 1 million residents in our rural area Subsidization of health coverage for low income Wisconsinites has helped mainstream tens of thousands into traditional commercial coverage through the Health Insurance Marketplace. This has been vital to the health of our patients enabling us to educate patients and include them in prevention programs.
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 |
Brent |
Miller |
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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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LOBBYIST UPDATE
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ISSUE UPDATE
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
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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
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