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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 25 Massachusetts Avenue, NW, Suite 700 |
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City | WASHINGTON |
State | DC |
Zip Code | 20001 |
Country | USA |
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5. Senate ID# 2002-12
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6. House ID# 321900000
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TYPE OF REPORT | 8. Year | 2021 |
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: Robert Doherty |
Date | 1/19/2022 9:01:08 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
The Affordable Care Act (P.L. 111-148, P.L. 111-152): Expanding coverage and improving Medicare benefits; Providing needed protections to guard against insurance practices that unfairly limit, deny or rescind coverage based on health status; public and private health insurers should encourage preventive health care by providing full coverage, with no cost-sharing, for preventive services recommended by an expert advisory group, such as the U.S. Preventive Services Task Force; Ensuring access to primary care physicians; and beginning to bend the cost curve; Prohibiting insurers from excluding or charging excessive rates to children based on pre-existing conditions, which later will be expanded to all persons; Covering young adults on their parents' plans; Eliminating lifetime and annual limits on health insurance coverage; Requiring that health insurers spend more on patient care and less on administration; support enactment of S. 248, the Empowering States to Innovate Act, which amends the Patient Protection and Affordable Care Act (ACA) to: (1) allow states to apply for waivers of certain health insurance coverage requirements in such Act (including requirements for the establishment of qualified health plans and health insurance exchanges) for plan years beginning on or after January 1, 2014 (currently, January 1, 2017), and (2) require the waiver application process to begin not later than 180 days after the enactment of this Act; Phasing out the Medicare Part D doughnut hole; Eliminating patient cost-sharing for preventive services offered by Medicare or private insurers; Increasing Medicare and Medicaid payments to primary care physicians; Supporting the Patient-Centered Outcomes Research Institute to help physicians and patients make care decisions based on the best available evidence; Supporting the Center on Medicare and Medicaid Innovation to fund pilots of delivery models to improve outcomes and reduce costs, including patient-centered medical homes; Advocated against a December 2018 ruling by a federal judge in Texas that the entire Affordable Care Act (ACA) is unconstitutional.
Access to Primary Care in the Context of Comprehensive Healthcare Reform Legislation (H.R. 3962/H.R. 3590/H.R. 4872): Provide sliding scale subsidies based on income to buy coverage from qualified plans; Qualified plans should: provide evidence-based benefits, including preventive services; and be prohibited from excluding persons with pre-existing conditions, charging them more, cherry-picking enrollees, or cancelling or failing to renew coverage; Expand Medicaid to cover all persons below the Federal Poverty Level and ensure fair payments to participating physicians; As coverage becomes affordable, all persons should participate and coverage should be guaranteed; Responsibility for financing should be shared by individuals, employers and government.
Medicare payment models that re-align incentives to support effective, efficient, patient-centered, coordinated care. Priority should be given to models designed to support the value of services provided by primary care physicians as well as to models that would create incentives, across physician specialties and sites of services, to improve the quality, effectiveness, and efficiency of care provided. Policy criteria for selecting the most promising models for pilot testing should be developed, in consultation with outside experts; The Patient-Centered Medical Home (PCMH), which has shown great promise in meeting the policy objectives suggested above, should be among the models selected for broader testing on a national pilot basis; the use of the medical home model for treatment or services under private health plans, the requirement of health plans to provide incentives to promote and report on medical home services provided, the establishment of community health teams and a primary care extension program to educate and support primary care practices in the delivery of medical home services, and the establishment of a demonstration project to educate physicians and other clinicians in training in the competencies required to deliver care consistent with the medical home care model.
Medicare Payments to Physicians: Urged that Congress provide incentives to physicians who transform their practices into Advanced Alternative Payment Models and continue to provide stability for physicians in the MIPS program. Specifically, Congress should extend the five percent Qualified Alternative Payment Model participant bonus beyond the 2022 performance year, replace the zero percent baseline payment updates under Medicare with positive updates. Urged congressional committees with jurisdiction over Medicare to exercise their oversight authority and urge CMS to expedite approval of more Advanced APMS, particularly those that work for small and specialty practices and to simplify the scoring structure and reporting requirements under the Merit-Based Incentive Payment System (MIPS) in order to fulfill Congress intent of a more streamlined program that reduces burdens on physicians; Supported S.2648, the Rural ACO Improvement Act, amends title XVIII of the Social Security Act to improve the benchmarking process for the Medicare Shared Savings Program (MSSP) to ensure that all ACOs have an equal opportunity to share in savings regardless of their geographic location; Provided recommendations to CMS on the Merit-based Incentive Payment System Value Pathway (MVP), which aims to reduce reporting burden and complexity within MIPS while improving the accuracy and effectiveness of performance measurement. The College noted specifically that a robust, multi-year transition period will be critical to the success of the MVP, that it does not support making the MVP mandatory, that CMS should continue to support numerous reporting mechanisms, including qualified registries and clinical data registries, which have been instrumental in developing specialty-specific performance measures, among other things. Urged support for H.R. 8505, a bill to provide for a one-year waiver of budget neutrality adjustments under the Medicare physician fee schedule; Urged that any legislation to hold some Medicare physician payment codes harmless from budget neutrality do so for just one year and to allow evaluation and management increases, along with GPC1X codes to go into effect. Regarding CMS 2022 Medicare Physician Fee Schedule and Quality Payment Program (QPP) rules, expressed support for extending some of the services and increased flexibility for telehealth through the end of 2023, namely some audio-only services that were allowed during the COVID-19 public health emergency (PHE), support for collecting additional data on health equity issues to analyze disparities that occur across their programs, support for including chronic care management as one of the seven MIPS Value Pathways (MVPs) for 2023.
FY2022 Appropriations: Urged Congress to support $10 billion for the Centers for Disease Control and Preventions programs in the FY 2022 Labor, Health and Human Services, Education and Related Agencies Appropriations bill as well as $50 million in funding shared evenly between the U.S. Centers for Disease Control and Prevention (CDC) and the National Institutes of Health (NIH) to conduct public health research into firearm morbidity and mortality prevention. Advocated for: Health Resources Services Administration (HRSA), $9.2 billion; Title VII, Section 747, Primary Care Training and Enhancement (PCTE), Health Resources and Services Administration (HRSA), $71 million; National Health Service Corps (NHSC), $860 million in total program funding; Agency for Healthcare Research and Quality (AHRQ), $500 million; Centers for Medicare and Medicaid Services (CMS), Program Operations for Federal Exchanges, $296.5 million. Also, urged support for the VA, Veterans Health Administration (VHA), $103.1 billion, which includes the following within the VHA -- VA, VHA, Medical Services, $66.2 billion, VA, VHA, Medical Community Care, $20.7 billion, VA, VHA, Medical and Prosthetic Research; $902 million.
COVID-19: Urged congressional appropriators to provide the highest possible funding level for research, prevention, control, and treatment of illnesses associated with the virus that is commensurate with the public health emergency that the virus represents. Urged the administration to explore regulatory and other actions that would make COVID-19 testing free-of-charge to patients covered by both public and private insurance plans, including ACA-compliant plans offered through the insurance exchanges, and to waive co-pays and deductibles for patients seeing physicians for symptoms that may be indicative of COVID-19 or who are hospitalized for treatment. Urged CMS to utilize a national disaster recovery program that would pay doctors 110% of Medicare rates for caring for uninsured patients who have been infected with SARS-CoV-2. Expressed support to Congress and the administration for a variety of COVID-related bills from the 116th Congress as follows: the Families First Coronavirus Response Act, H.R. 6201, and other stimulus reforms related to COVID-19 including: Emergency paid leave benefits, paid sick days for public health emergencies, coverage of testing for COVID-19, waiving of cost sharing under Medicare, Medicare Advantage, Medicaid, and CHIP, increasing the federal FMAP under Medicaid, providing reimbursement for CPT codes 99441 - 99443, which are telephone evaluation and management services, expediting entrance of international medical graduates who are citizens of other nations (non-US IMGs) into the country and ensuring that lawfully present non-U.S. IMGs are not negatively impacted by the COVID-19 pandemic, funding for physician practices under the Public Health and Social Service Emergency Fund (PHSSEF), providing tax relief, grants, and loans to small and medium size practices impacted by COVID-19, increasing funding for personal protective equipment (PPE), ensuring Medicaid pay parity with Medicare for primary care services; Urged support for the Student Loan Forgiveness for Frontline Health Workers Act, H.R. 6720, introduced May 5, 2020 by Representative Carolyn B. Maloney (D-NY) which would eliminate graduate school debt for healthcare workers, including physicians and medical students, who are providing direct patient care in response to the COVID-19 pandemic; Urged support for H.R. 7059, the Coronavirus Provider Protection Act, which extend liability protections to those who provide care in good faith during the COVID-19 public health emergency (plus a reasonable time, such as 60 days, after the emergency declaration ends), and not in situations of gross negligence or willful misconduct. The College also urged that pay parity between telephone claims and in-person visits and between all telehealth and in-person visits be maintained after the PHE is lifted. This extension-either continued by CMS or mandated by Congress-should last at least through the end of 2021, or until such a time when effective vaccines and treatments are widely available, with an option to extend it even further, or consider making permanent, based on the experience and learnings of patients and physicians who are utilizing these visits. Urged congress to mitigate the impact of covid across racial and ethnic minority populations by collect covid-19 and racial disparity data, equitably distribute covid-19 vaccines and treatments, protect essential workers, permanently expand access to family and medical leave, address environmental and social drivers of health, integrate primary care and behavioral health, improve mental health parity with increased federal oversight and enforcement, make naloxone more available to prevent overdose, expand medication-assisted treatment (mat) for physicians, establish a national prescription drug monitoring program (PDMP); urged support for administering COVID-19 vaccinations to all eligible immigrants in Customs and Border Protection (CBP) custody. Urged CMS to support increasing COVID-19 vaccine uptake by ensuring clinicians are appropriately paid for vaccine counseling for beneficiaries of Medicaid and Medicare.
American Rescue Plan (ARP) Act (H.R. 1319): Urged support for various provisions within the ARP to provide incentives for states to expand Medicaid by temporarily increasing the states base FMAP by five percentage points for two years for states that newly expand Medicaid. Urged support for allowing states, for five years, to extend Medicaid eligibility (and CHIP eligibility) to women for 12 months postpartum. Urged support to require Medicaid coverage of COVID-19 vaccines and treatment without beneficiary cost sharing with vaccines matched at a 100 percent federal medical assistance percentage (FMAP) through one year after the end of the PHE. Urged support for $46 billion to HHS to detect, diagnose, trace, and monitor COVID-19 infections, and for other activities necessary to mitigate the spread of COVID-19. Urged support to subsidize the health coverage of people earning up to 150 percent of the federal poverty level (FPL) under the ACA and those on unemployment insurance for a period of two years. Urged support for waiving VA cost sharing and copayments for medical treatment until September 30, 2021.
Womens Health: Urged Congress to support, H.R. 958, the Protecting Moms Who Served Act, which would provide critical support for maternity care coordination programs to address the clinical and nonclinical perinatal needs of veterans and ensure effective coordination between VA and non-VA facilities in the delivery of maternity care and other health care services. Urged HHS to promptly finalize new Title X regulations that ensure unencumbered access to affordable, comprehensive, evidence-based reproductive health care; eliminates medically unnecessary restrictions and inappropriate political interference in the patient-physician relationship; and protects funding for and ensures consistent treatment of qualified service sites. Urged support for mandatory, permanent extension of postpartum Medicaid coverage, from 60 days to 12 months after delivery. Urged support for the Womens Health Protection Act of 2021 (H.R. 3755 and S. 1975), bills that would protect a persons ability to determine whether to continue or end a pregnancy and to protect the health care clinicians ability to provide abortion services free from medically unnecessary restrictions such as waiting periods, biased counselling and admitting privilege requirements for clinicians.
Expand Health Coverage and Affordability: Urged Congress to support H.R. 340, the Incentivizing Medicaid Expansion Act of 2021, to expand federal matching assistance for states that choose to expand Medicaid, regardless of when such expansion takes place. Introduce and pass the companion bill in the Senate and H.R. 369, the Health Care Affordability Act of 2021, to permanently expand eligibility for higher premium tax credits under the ACA.
Train and Support Frontline Physicians during and after COVID-19: Urged Congress to support H.R. 2256/S. 834, the Resident Physician Reduction Shortage Act of 2021, to increase the number of GME slots by at least 2,000 per year over seven years (14,000 slots) for specialties facing shortages, including internal medicine; H.R. 1554 (116th Congress), the Resident Education Deferred Interest Act, to allow borrowers to qualify for interest-free deferment on their student loans while serving in a medical or dental internship or residency program; S. 948, the Conrad State 30 and Physician Access Reauthorization Act (116th Congress) and S. 3599 (116th Congress), the Healthcare Workforce Resilience Act, to support the COVID-19 response workforce by expediting visas for international medical graduates (IMGs) to enter the U.S. for training and patient care, permanently authorizing the Conrad 30 Program, and providing a pathway for IMGs and their families already in the U.S to obtain permanent residency status; H.R. 2418, the Student Loan Forgiveness for Frontline Health Workers Act, to forgive student loans for physicians and other clinicians who are on the frontlines of providing care to COVID-19 patients or helping the health care system cope with the COVID-19 public health emergency; H.R. 1667/S. 610, the Dr. Lorna Breen Health Care Provider Protection Act, to address the behavioral health and well-being of physicians, including depression, suicides and burnout.
Support the Value of Primary and Comprehensive Care: Urged Congress to Continue to fund the 3.75 percent increase to all physicians services that was approved by Congress at the end of last year to prevent CY2022 budget neutrality cuts for physician services, including primary care visits and other evaluation and management services; Ensure that any legislation that addresses budget neutrality treats all services fairly and equitably; Pass H.R. 1025, the Kids Access to Primary Care Act, to increase access to health coverage for Medicaid patients by achieving payment parity for primary care services under Medicaid and Medicare; Extend the five percent bonus that physicians receive if they meet performance expectations in Advanced APMs that is set to expire at the end of 2022; Act before the end of CY2021 to prevent scheduled cuts for physician services, including primary care, resulting from budget sequestration and pay-as-you go budget rules. Voiced support for H.R. 6020, bipartisan legislation to extend the 3.75 percent update to the conversion factor for an additional year.
Improve Access to Prescription Drugs and Reduce Costs: Urged Congress to support S. 898, the Fair Drug Pricing Act, to require drug companies to disclose and provide more information about imminent drug-price increases, including data about research and development costs; S. 833, the Empowering Medicare Seniors to Negotiate Drug Prices Act of 2021, to help to reduce drug prices and out-of-pocket costs by allowing the federal government to negotiate lower drug prices on behalf of Medicare beneficiaries; S. 141, the End Taxpayer Subsidies for Drug Ads Act, to end the federal tax deduction that pharmaceutical companies use to pay for drug advertising; S. 464/H.R. 2163, the Safe Step Act, to ensure patient access to appropriate treatments based on clinical decision-making and medical necessity rather than arbitrary step therapy protocols.
Promote Health Equity, Social Justice, and Eliminate Disparities: Urged Congress to support H.R. 1280, the George Floyd Justice in Policing Act of 2021, to overhaul qualified immunity for law enforcement, prohibit racial profiling on the part of law enforcement and ban no-knock warrants in federal drug cases and chokeholds and carotid holds at the federal level; H.R. 5, the Equality Act, to prohibit discrimination based on sex, sexual orientation and gender identity in public accommodations and facilities, education, federal housing credit and the jury system; H.R. 666/S. 162, the Anti-Racism in Public Health Act of 2021, to establish within the CDC a National Center on Anti-racism and Health for data collection and research and a law enforcement violence prevention program; H.R. 959/S. 346, the Black Maternal Health Momnibus Act of 2021, to reduce preventable maternal mortality and severe maternal morbidity in the U.S. and close disparities in maternal health outcomes, particularly among pregnant minority women.
Expand Access to Telehealth Services and Promote Patient Safety/Privacy; Urged Congress to support H.R. 2903/S. 1512, the CONNECT for Health Act, to remove arbitrary barriers to telehealth services such as geographic and site of service restrictions; S. 168/H.R. 708, the Temporary Reciprocity to Ensure Access to Treatment Act or the TREAT Act, to ensure that telehealth services can be provided across states lines after the public health emergency ends; Urged appropriators to include adequate funding in FY2022 to support expansion of broadband capabilities nationwide, especially to rural and underserved communities, and to remove the ban on adoption of a national unique health identifier standard.
Veterans Administration: Expressed concerns to the VA about its efforts to develop National Standards of Practice for physicians and other health professionals that supersede state scope of practice and licensure laws; expressed that the VA has not provided a transparent process by which public stakeholders are provided an adequate opportunity to review and provide meaningful input into the standards of practice. Expressed concern that the VA is moving forward too quickly and with too little stakeholder input on the VA supremacy Project. Urged support for provisions in any final FY2022 National Defense Authorization Act to prevent cuts to the military medical workforce without requiring appropriate congressional oversight and review.
Surprise Medical Billing: Voiced support for the decision of CMS to provide protections for patients from surprise bills in situations where they need an ambulance, especially in a perceived emergency; voiced support for CMS approach that emergency services provided by out-of-network emergency facilities and out-of-network provider organizations, and certain non-emergency services furnished by out-of-network provider organizations at certain in-network facilities, must be calculated based on a recognized amount which is generally the lesser of the Qualifying Payment Amount (QPA) - the plans median in-network rate for the item or service, or an all-payer model agreement between CMS and the state; urged CMS to include in the Independent Dispute Resolution process described in future sub-regulatory guidance that health plans have an affirmative obligation to pay fairly and appropriately for services provided in and out of network.
Substance Use Disorders: Urged Congress to support for the Comprehensive Addiction Resources Emergency (CARE) Act in the 117th Congress, which offers increased access to treatment and will improve care for individuals with substance use disorders (SUDs), specifically $1 billion per year to expand access to overdose reversal drugs (Naloxone) and provide this life-saving medicine to states to distribute to first responders, public health departments, and the public.
The Build Back Better Act (H.R. 5376): Urged support in Congress for the following provisions: provide temporary enhanced ACA Marketplace cost-sharing reduction assistance to individuals with household incomes below 138 percent of the federal poverty level (FPL) for calendar years (CY) 2022 through 2025 and specify that individuals with household incomes below 138 percent of the FPL with access to employer-sponsored coverage or a qualified small employer health reimbursement arrangement can still receive credits; the 400 percent federal poverty level premium tax credit eligibility cap should be eliminated, and the amount of premium tax credits for all income levels should be enhanced; establish a health insurance affordability fund, with $10 billion made available annually for states to establish a state reinsurance program or use the funds to provide financial assistance to reduce out-of-pocket costs; permanently reauthorize CHIP and provide states the option to increase Medicaid and CHIP eligibility levels for children up to 300 percent of FPL without receiving a waiver.
Mental and Behavioral Health: Urged Congress to support H.R. 5218, the Collaborate in an Orderly and Cohesive Manner Act (CoCM) that would provide grants through the Department of Health and Human Services to primary care physicians that choose to deliver behavioral health care through the Collaborative Care Model (CoCM). CoCM involves a primary care physician working collaboratively with a psychiatric consultant and a care manager to manage the clinical care of behavioral health patient caseloads. Urged support for retaining all services added to the Medicare telehealth services list on a temporary, Category 3 basis until the end of CY23. CMS should maintain coverage of audio-only mental health visits even after the PHE is lifted. This extension should last at least through the end of 2023 with an option to extend it even further or consider making it permanent, based on the experience and learnings of patients and physicians who utilize these visits. Urged support for expanding access to mental and behavioral health services, including allowing beneficiaries to access services from home, or if the technology is not available at home, from a rural health clinic or hospital.
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), President of the U.S., Centers For Disease Control & Prevention (CDC), Homeland Security - Dept of (DHS), Food & Drug Administration (FDA), State - Dept of (DOS), Veterans Affairs - Dept of (VA)
18. Name of each individual who acted as a lobbyist in this issue area
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Crowley |
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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
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
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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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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?
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