Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

9. Check if this filing amends a previously filed version of this report

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.

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

Medicare Advantage (MA) - Offered recommendations to CMS as related to AI guardrails, provider directories, medical loss ratio (MLR) standards, health equity, and prior authorization and utilization management in MA plans.

PAYGO Budget Cuts - Encouraged congress to act to avert statutory Pay-As-You-Go (PAYGO) cuts set to go into effect

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.

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

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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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, highlighted the critical importance of the 340B program for hospitals.

Children's Hospital Graduate Medical Education (CHGME) - Continued to urge Congress to reauthorize the 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. Encouraged improved stakeholder communication and increased notification by manufacturers for a surges in demand

Health Insurance Portability and Accountability Act (HIPAA) Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information - Urged the HHS Office for Civil Rights (OCR) to reconsider finalizing the Proposed Rule as currently drafted; encouraged the agency to reconsider proposed data standards and implementation specifications.

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.

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.

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 - 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.

Telemedicine prescribing - Encouraged DEA to finalize a telemedicine prescribing framework that is more similar to the flexibilities that have been in place since the COVID-19 PHE

Workforce - Advocated for strengthening the health workforce through policies that support education, training, recruitment, and retention efforts

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

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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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

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

Implementation of Additional Duties on Products of the Peoples Republic of China, EO 14256 - Advocated for clarity around the implementation of tariffs on pharmaceuticals, medical supplies and other healthcare products; supporting exclusions for key healthcare products.

Implementation of Additional Duties on Products of Canada, EO 14193 - Advocated for clarity around the implementation of tariffs on pharmaceuticals, medical supplies and other healthcare products; supporting exclusions for key healthcare products.

Implementation of Additional Duties on Products of Mexico, EO 14194 - Advocated for clarity around the implementation of tariffs on pharmaceuticals, medical supplies and other healthcare products; supporting exclusions for key healthcare products.

Monitored development of the Medical Supply Chain Resiliency Act (S.998)

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, U.S. Trade Representative (USTR), Homeland Security - Dept of (DHS), White House Office, Commerce - Dept of (DOC)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

21. Client new principal place of business (if different than line 20)

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

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

FOREIGN ENTITIES

27. Add the following foreign entities:

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization

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?
No Yes