|
LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 1501 M STREET, N.W., Suite 600 |
Address2 |
|
City | WASHINGTON |
State | DC |
Zip Code | 20005-1700 |
Country | USA |
3. Principal place of business (if different than line 2)
City | WASHINGTON |
State | DC |
Zip Code | 20005 |
Country | USA |
|
5. Senate ID# 4675-12
|
||||||||
|
6. House ID# 312420000
|
TYPE OF REPORT | 8. Year | 2023 |
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 |
|
11. No Lobbying Issue Activity |
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
---|---|---|---|---|---|---|---|---|---|
12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
|
|
||||||||
|
|
||||||||
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: Jill H. Randolph |
Date | 10/19/2023 1:07:47 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 RET
16. Specific lobbying issues
LEGISLATIVE
TECHNICAL CORRECTIONS AND ROTH CATCH-UP DELAY. SECURE 2.0 technical corrections, delay of effective date of Roth Catch-up provision and guidance
AUTO RE-ENROLLMENT. Automatic retirement plan re-enrollment, S. 2512, July 24, 2023, letter of support to sponsors Sens. Kaine and Cassidy
ENVIRONMENTAL, SOCIAL, GOVERNANCE. Environmental Social and Governance (ESG) factors in retirement plan investments, HR 5339, HR 5337, HR 5340, HR 5338, HR 4008
MINIMUM PARTICIPATION REQUIREMENTS. Retirement plan minimum participation requirements
DE-RISKING. Pension Plan De-risking, annuities, lump sum distributions
RETIREE HEALTH PLANS. Retiree health plans, excess assets, Section 401(h) accounts
SEC PROPOSALS AFFECTING RETIREMENT PLANS. Predictive Data Analytics, Open-End Fund Liquidity Risk Management Programs and Swing Pricing
RETIREMENT PLAN BROKERAGE WINDOWS. Brokerage window investment options offered by retirement plans and whether there is a duty to monitor investments inside a brokerage window
DEFINED BENEFIT PLANS. Defined Benefit Plans, e.g., overfunded plans, PBGC premiums
CITs FOR 403(b) PLANS. Collective Investment Trusts and separate accounts for Section 403(b) charities and educational entities, HR 3063
LITIGATION. Litigation and enforcement affecting retirement plans, including pleading standards
STATE PLANS. ERISA preemption, state retirement plan mandatory Roth IRA plans covering private sector employers
REGULATORY
ROTH CATCH-UP DELAY. SECURE 2.0 Section 603 Roth Catch-up Delay transition period
SECURE 2.0 GUIDANCE. SECURE 2.0 Guidance, Roth Catch-up contributions, overpayments of benefits, IRC Section 420 transfers, pension-linked emergency savings, student loan, SEP and SIMPLE Roth IRAs, start-up credits, safe harbor for corrections, ERISA notices and disclosures, annual funding notice, pension risk transfer, lost and found registry etc.
RMDs. Retirement Plan Required Minimum Distributions
FIDUCIARY RULE. Re-proposal of Retirement Plan Fiduciary rule
ERISA NOTICES AND DISCLOSURES. Retirement plan notices and disclosures and response to EBSA RFI, e.g., paper benefit statements, notices for unenrolled participants, elimination of certain notices, consolidation of certain notices, pooled employer plans, annual funding notice, 88 Fed. Reg. 54511
PENSION PLAN DE-RISKING. Report by DOL on Defined Benefit Pension Plan De-risking in consultation with the ERISA Advisory Council
CAMT. Corporate Alternative Minimum Tax (15% Tax) application to defined benefit pension plans and certain other employee benefit plans
PREDICTIVE DATA ANALYTICS, and OPEN-END LIQUIDITY RISK MANAGEMENT PROGRAMS AND SWING PRICING. Predictive Data Analytics by Broker- Dealers and Investment Advisors, Open-End Fund Liquidity Risk Management Programs and Swing Pricing, 88 Fed. Reg. 53960, 87 Fed. Reg 77172
RETIREMENT PLAN AUDITS. Audits for missing participants, cybersecurity standards for audits and duration of audits
SPIN OFFS. Retirement Plan spin-off and funding rules
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Treasury - Dept of, Labor - Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), Securities & Exchange Commission (SEC)
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 |
James |
Klein |
|
|
|
Lynn |
Dudley |
|
|
|
Diann |
Howland |
|
|
|
Jill |
Randolph |
|
|
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
LEGISLATIVE
DRUG PRICING. Drug pricing, pharmacy benefit managers (PBMs), drug cost transparency and competition, rebates, biosimilars, Rx drug supply chain, claw backs and medical management, litigation to overturn ERISA preemption in states and in Congress, Lower Costs and More Transparency, HR 5378, Health Care Price Transparency Act HR 4822, Pharmacy Benefit Manager Transparency Act S. 127
MENTAL HEALTH. Mental Health Coverage by Private Sector Employer-Provided plans, substance use disorders, provider networks, network tiers, provider shortages, mental health data, ghost networks, treatment limitations, SUPPORT for Patients and Communities Reauthorization Act S. 2433
HEALTH SAVINGS ACCOUNTS. Health Savings Accounts (HSAs) high deductible health plan expansion, HSAs and telehealth, HSAs and chronic disease management, Bipartisan HSA Improvement Act HR 5866, HSA Modernization Act HR 5687
HEALTH CARE PRICE TRANSPARENCY. Price transparency for Rx drugs, hospitals, out-patient providers, health insurers, mandatory reporting for health-related ownership information, clinical diagnostic laboratory tests, Transparency in Health Care HR 4509, Transparency in Coverage Act HR 4507, The PATIENT Act HR 3561, Lower Costs, More Transparency Act HR 5378, Transparency in Billing Act HR 4509, Hidden Fee Disclosure Act HR 4508, Health Care Price Transparency Act HR 4822
SURPRISE MEDICAL BILLING. Hospital billing, hospital consolidation and its impact on health care costs, anti-competitive pricing, site-neutral payment systems
TELEHEALTH EXPANSION. Making telehealth benefits permanent for employer plans; licensing of providers across state lines, Telehealth Expansion Act S. 1001 / HR 1843, Telehealth Benefit Expansion For Workers Act HR 824
PAID LEAVE. Bipartisan Paid Leave Coalition in the House of Representatives
ERISA PREEMPTION. Uniformity of rules applicable to private sector ERISA plans
REGULATORY
HEALTH CARE PRICE TRANSPARENCY, PRESCRIPTION DRUG COSTS AND SITE NEUTRAL PAYMENT SYSTEMS. 88 Fed. Reg. 49552, Comment letter to CMS dated September 11, 2023
MENTAL HEALTH PARITY. 88 Fed. Reg. 51552, Webinar with DOL speaker on Mental Health Parity September 11, 2023
FIXED INDEMNITY HEALTH BENEFIT PLANS. 88 Fed. Reg 44596, Short-term, Limited Duration, Independent Non-coordinated Excepted Benefits Coverage; and Tax Treatment of Certain Accident and Health Insurance. Comment letter to the tri-agencies dated September 11, 2023
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Treasury - Dept of, Centers For Medicare and Medicaid Services (CMS), Health & Human Services - Dept of (HHS), White House Office, Labor - Dept of (DOL), Office of Management & Budget (OMB), Justice - Dept of (DOJ)
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 |
James |
Klein |
|
|
|
Diann |
Howland |
|
|
|
Jill |
Randolph |
|
|
|
Ilyse |
Schuman |
|
Senate HELP Committee, Chief Labor Counsel, Minority Staff Director, Chief Counsel |
|
Kathryn |
Johnson |
|
|
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
Address |
|
||||||
City |
|
State |
|
Zip Code |
|
Country |
|
21. Client new principal place of business (if different than line 20)
City |
|
State |
|
Zip Code |
|
Country |
|
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
|
|
||||||||
1 |
|
3 |
|
||||||
2 |
|
4 |
|
ISSUE UPDATE
24. General lobbying issue that no longer pertains
|
|
|
|
|
|
|
|
|
AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
Name | Address |
Principal Place of Business (city and state or country) |
||||||||||||
| ||||||||||||||
|
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 | ||||||||||
| ||||||||||||||
|
% |
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) |