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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 | 4/22/2024 6:08:26 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
21st Century Cures Act: Establishment of Disincentives for Health Care Providers That Have Committed Information Blocking Proposed Rule - Urged CMS to refrain from finalizing the Proposed Rule. Encouraged CMS, ONC and OIG to provide additional clarity regarding several policies under consideration.
Contract Year 2025 Policy and Technical Changes To The Medicare Advantage (MA Or Part C) and Medicare Prescription Drug Benefit (Part D) programs Proposed Rule - Encouraged CMS to consider the Vizient Vulnerability Index as the agency considers other potential social risk factors and urged CMS to continue monitoring patients out-of-pocket costs as formulary changes occur.
Issues related to hospital and provider payment.
Issues related to pharmacy benefit managers; monitoring the Modernizing and Ensuring PBM Accountability (MEPA) Act (S.2973).
Lower Costs, More Transparency Act (H.R. 5378) - 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.
Medicaid Disproportionate Hospital (DSH) payment cuts - Urged Congress to avoid Medicaid Disproportionate Share Hospital (DSH) payment cuts scheduled to begin in FY 2024. Supported temporary delay of Medicaid DSH cuts in Consolidated Appropriations Act, 2024 (H.R. 4366).
Medicare-supported Graduate Medical Education - Supported passage of the Resident Physician Shortage Reduction Act (H.R. 2389/S. 1302).
The Medicare Dependent Hospital (MDH) program and the Low Volume Hospital Payment Adjustment (LVA) - Supported passage of the Assistance for Rural Community Hospitals (ARCH) Act (H.R 6430).
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. Responded to the discussion draft of the Supporting Underserved and Strengthening Transparency, Accountability, and Integrity Now and for the Future of 340B Act (SUSTAIN 340B Act) and supplemental request for information (RFI).
Buffer inventory - Engagements with CMS on reimbursement for hospitals that stockpile buffer supplies of essential medicines.
Children's Hospital Graduate Medical Education (CHGME) - Continued to urge Congress to reauthorize CHGME program through the Childrens Hospital GME Support Reauthorization Act of 2023 (H.R. 3887). Offered support for providing $738 million in funding 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. Engaged on recent FTC/HHS joint Request for Information related to generic drug shortages, as well as the January Senate Finance Committee White Paper Preventing and Mitigating Generic Drug Shortages: Policy Options Under Federal Health Programs. Continued supporting passage of The Drug Shortage Prevention Act (H.R. 3008) and The Drug Origin Transparency Act (H.R. 3810) and engaged on the Stop Drug Shortages Act (McMorris Rodgers, No Bill Number) discussion draft.
Endorsed passage of legislation to address patent thickets (H.R. 6986/S.3583).
Endorsed passage of the Affordable Prescriptions for Patients Act (S.150).
Endorsed passage of the Mapping Americas Pharmaceutical Supply (MAPS) Act (H.R. 6992).
Healthcare Workforce - Endorsed passage of the Safety from Violence for Healthcare Employees (SAVE) Act (H.R. 2584/S. 2768). Monitored development of the Bipartisan Primary Care and Health Workforce Act (S.2840).
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.
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.
Payer-mandated White Bagging - Urged support for policy updates related to payer-mandated white bagging for medications.
Preparing for All Hazards and Pathogens Reauthorization Act (H.R. 4421) and Preparedness and Response Reauthorization Act (H.R. 4420) - Supported timely passage of legislation to reauthorize the Pandemic and All Hazards Preparedness Act. Advocated for including provisions to increase transparency in the healthcare supply chain and improve hospital and health system emergency preparedness.
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.
Supported an increase in the Physician Fee Schedule conversion factor in Consolidated Appropriations Act, 2024 (H.R. 4366) to offset recent administrative payment cuts.
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.
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)
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) |