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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 | 2024 |
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 | 1/21/2025 4:58:28 PM |
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 expired.
Home Infusion - Shared concerns regarding changes to Medicare reimbursement for certain Home Infusion Treatments, encouraged passage of the Preserving Patient Access to Home Infusion Act (S.1976/H.R.4104)
Issues related to hospital and provider payment
Medicaid Disproportionate Share Hospital (DSH) Program - Urged Congress to avert the cuts to Medicaid DSH payments set to take place at the end of the year; encouraged passage of legislation to preserve DSH payments on a longer-term basis, endorsed passage of the Supporting Safety Net Hospitals Act (H.R.2665)
Medicare Drug Price Negotiation Program (MDPNP) - Responded to the Centers for Medicare & Medicaid Services (CMS) on CMSs ICR on implementation of Medicare Drug Price Negotiation Program. Encouraged the agency to continue considering provider perspectives as it works to implement the MDPNP
Medicare Prospective Payment System Updates - Urged Congress to consider additional financial support for hospitals beyond increases in the IPPS and OPPS payment rules to more adequately adjust for increased provider costs.
PAYGO Budget Cuts - Encouraged congress to act to avert statutory Pay-As-You-Go (PAYGO) cuts set to go into effect in 2025
Physician Payment - Encouraged Congress to avoid enacting the reimbursement reduction for physicians and other clinicians treating Medicare patients included in the CY 2025 Medicare Physician Fee Schedule (MPFS) Proposed Rule; 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 Medicare Advantage (MA) organizations and Medicaid managed care plans. Endorsed legislation to streamline the prior authorization process in the Improving Seniors Timely Access to Care Act (S.4532/H.R.8702)
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. Monitoring development of the Lower Costs, More Transparency Act (H.R. 5378)
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.
Children's Hospital Graduate Medical Education (CHGME) - Continued to urge Congress to reauthorize CHGME 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. Continued supporting passage of The Drug Shortage Prevention Act (H.R. 3008) and The Drug Origin Transparency Act (H.R. 3810)
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. Monitored development of the Lower Costs, More Transparency Act (H.R. 5378)
Medical Device Sterilization - Conducted education and outreach on the potential negative impact on the healthcare supply chain of pending regulations limiting the use of Ethylene Oxide as a medical device sterilant.
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.
Pandemic and All Hazards Preparedness Act (PAHPA) - Encouraged the reauthorization of PAHPA
Payer-mandated White Bagging - Urged support for policy updates related to payer-mandated white bagging for medications.
Rural healthcare - Encouraged passage of the Save Rural Hospitals Act (S. 803) ; the Rural Hospital Closure Relief Act (S. 1571) and the Assistance for Rural Community Hospitals Act (H.R. 6430)
Social Determinants of Health - Encouraged Congress and agencies to ensure tools like the Vizient Vulnerability Index are being utilized to understand and identify social drivers of health at the neighborhood level.
Specifications, Standards and Ecolabels for Federal Purchasing - Responded to the Environmental Protection Agency (EPA) on EPAs Recommendations of Specifications, Standards and Ecolabels for Federal Purchasing. Encouraged EPA to use a standard, ecolabel or certification that is recognized by the Environmental Sustainability Program.
Telehealth - Continued supporting passage of the CONNECT for Health Act (S. 2016/H.R. 4189). Continued to advocate for the adoption of permanent telehealth policies to extend flexibilities beyond the current 2024 expiration date.
Telemedicine prescribing - Encouraged Congress to pass a two-year extension of Drug Enforcement Administration (DEA) prescribing flexibilities without requiring an in-person medical evaluation
Workforce - Monitored development of the Bipartisan Primary Care and Health Workforce Act (S.2840) ; Encouraged passage of the Safety from Violence for Healthcare Employees (SAVE) Act (S. 2768/H.R. 2584) ; the Dr. Lorna Breen Health Care Provider Protection Reauthorization Act (S. 3679/H.R. 7153) ; the Healthcare Workforce Resilience Act (S.3211/H.R.6205) ; the Resident Physician Workforce Shortage Reduction Act of 2023 (S. 1302/H.R. 2389) ; and the Substance Use Disorder Workforce Act (H.R.7050)
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), Food & Drug Administration (FDA), Centers For Medicare and Medicaid Services (CMS), 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 |
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
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
Sec. 301 China Tariffs - Continued to advocate for clarity around the expiration of tariff exclusions for products necessary to respond to the COVID-19 pandemic. Supported extending exclusions for key healthcare products.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, U.S. Trade Representative (USTR)
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) |