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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 |
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| City | WASHINGTON |
State | DC |
Zip Code | 20005-1700 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 4675-12
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6. House ID# 312420000
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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. | ||||||||
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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: RALPH P. KASS |
Date | 1/18/2022 3:17:51 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
Build Back Better Act (BBBA) - retirement savings provisions
Infrastructure Investment and Jobs Act (IIJA) - defined benefit pension stabilization option provision
Automatic Retirement Plan Act (ARPA)
Enhancing Emergency and Retirement Savings Act of 2021 - S. 1870
ABLE Employment Flexibility ACT (AEFA) - H.R. 4672
Womens Retirement Protection Act (WRPA) - S. 2446/H.R. 4678
Encouraging Americans to Save Act (EASA_ - S. 2452/H.R. 2913
Improving Access to Retirement Savings Act - S. 1703
Retirement Savings Lost and Found Act - S. 1730
Retirement Parity for Student Loans Act - S. 1443/H.R. 2917
Financial Factors in Selecting Retirement Plan Investment Act - S. 1762
Retirement Security and Savings Act of 2021 - S. 1770
Enhancing Emergency and Retirement Savings Act of 2021 - S. 1870
Securing a Strong Retirement Act - H.R. 2954
Retirement Security Flexibility Act - S. 2602
Emergency Pension Plan Relief Act - H.R. 409
Emergency Pension Plan Relief Act - H.R. 423
Cybersecurity
Environmental, Social and Governance (ESG) principals in investing
ERISA Uniformity
Financial wellness
Mortality Tables - improvements
Pension Benefit Guaranty Corporation (PBGC) premiums
Tax Incentives for 401 (k) contributions
Telework practices
Extension of spousal consent to defined contribution plans
Regulatory
DOL - sub-regulatory guidance - reduction of cybersecurity risks for retirement plan sponsors
Consolidated Appropriations Act of 2021 - H.R. 133 (Public Law 116-260) - employer-sponsored retirement and other benefit plans - implementation issues
American Rescue Plan Act of 2021 - H.R. 1319, (Public Law 117-2) - PBGC, IRS - IFR - new assistance program for financially troubled multiemployer plans
DOL/IRS/PBGC - Form 5500 reporting requirements - proposed rules and forms revisions
PBGC/IRS - Missing Participants - request for clarifying guidance on missing participant benefits
DOL - best practices for missing participants
IRS - final regulations - automatic postponements during Federally declared disasters
DOL - Environmental, Social and Governance (ESG) investment and proxy voting guidance, temporary non-enforcement policy
DOL (EBSA) - guidance on maximum duration of relief extending certain participant and plan deadlines resulting from COVID-19
Treasury/IRS - safe harbor correction method for automatic contribution arrangements
IRS -Employee Plans Compliance Resolution System (EPCRS) - updated
IRS - mandatory 60-day postponement of certain tax-related deadlines
Treasury/IRS - Notice 2021-48 - guidance on single-employer pension plan relief included in the American Rescue Plan Act of 2021 (ARPA)
DOL/Treasury/IRS - Pooled Employer Plans (PEPs) and Multiple Employer Plans (MEPs) - comments on registration requirements, service crediting guidance and other issues
DOL (EBSA) - investment advice guidance and related prohibited transaction exemptions
Treasury/IRS - Remote notarization
DOL - Interim Final Rule on Lifetime Income Illustration Requirements - temporary frequently asked questions (FAQs) - timing clarification
DOL - redefinition of fiduciary
DOL -de-risking of defined benefit pension plans
Emergency savings
Executive compensation
ERISA Uniformity
EEOC - workplace diversity data deadline (EEO-1) Component 1 data)
Mortality Tables - improvements
Multiemployer pension plan issues
Paid leave proposals and issues
State retirement plan initiatives
Student loan repayment benefit
PBGC/IRS - withholding issue for terminating plans
IRS Tax Forms W4-P and W4-R (suggesting changes)
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), White House Office, Equal Employment Opportunity Commission (EEOC)
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 |
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Lynn |
Dudley |
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Diann |
Howland |
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Janet |
Jacobson |
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Jill |
Randolph |
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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
Legislative
Employer-sponsored health coverage - robust COVID-19 testing and vaccine distribution, COBRA subsidies, telehealth, primary care and worksite clinics and more comprehensive coverage of chronic disease prevention measures
Build Back Better Act (BBBA) - health care coverage and affordability issues, prescription drugs, paid family and medical leave
Treat and Reduce Obesity Act - S. 596/H.R. 1577
Telehealth Expansion Act - S. 1706
FAMILY Act - H.R. 804/S.248 - Paid Family Leave
American Families Plan - national comprehensive paid family and medical leave program
Building an Economy for Families Act (BEFA) -universal paid family and medical leave
Infrastructure Investment and Jobs Act (IIJA) - H.R. 3684- health care provision
Dependent Care Flexible Spending Accounts (FSAs)
Health Flexible Spending Accounts (FSAs)
Health Savings Accounts (HSAs)
Quality, Cost & Transparency - Lower Health Care Costs Act (S. 1895, 116th Congress)
Public health insurance option - Request for Information (RFI)
Mental Health - Request for Information
Prescription drug legislation
Elijah E. Cummings Lower Drug Costs Now Act - H.R. 3
Surprise billing regulations
Regulatory
American Rescue Plan Act of 2021 - H.R. 1319, (Public Law 117-2) - implementation
White House - COVID-19 Action Plan - announcements regarding vaccinations, testing requirements for private employers, and vaccination requirements for federal contractors
Departments of Labor, Treasury and HHS - FAQs about Affordable Care Act (ACA) and Consolidated Appropriations Act, 2021 (CAA) Implementation - Part 49 - delay of several transparency requirements for group health plans, and other guidance
Executive Order - Promoting Competition in the American Economy
HHS - Comprehensive Plan for Addressing High Drug Costs
Treasury, HHS & Labor - guidance (FAQs) on coverage requirements for HIV-related medications
Labor/HHS/Treasury - proposed regulations regarding air ambulance reporting for group health plans and insurers
Mental health parity requirements for group health plans and insurers, including under the CAA
Treasury & IRS - IRS Notice 2021-46 - additional guidance on COBRA subsidy provisions under the American Rescue Plan Act (ARPA)
Treasury/DOL/HHS - implementation of surprise billing provisions under the CAA - interim final regulations (IFR) part 1 and part 2
DOL - submission of data to state all-payer claims databases by self-insured employers; State All Payer Claims Database Advisory Committee under the CAA
EEOC - vaccine incentive and mandate guidance for employers
DOL/Treasury/HHS - transparency in coverage - final regulations
DOL/Treasury/HHS - transparency provisions under the CAA
HHS - Enforcement of Hospital Price Transparency Rules, and health care inequities - Medicare Outpatient Prospective Payment System (OPPS) rule for 2022
Treasury/IRS - request for guidance on repurposing of welfare benefit fund assets
Treasury/IRS/DOL/HHS - Request for information (RFI) - group health plan prescription drug reporting requirements under the CAA
White House - National Strategy for the COVID-19 Response and Pandemic Preparedness
EEOC - wellness programs under the Americans with Disabilities Act (ADA) and the Genetic Information Nondiscrimination Act (GINA)
DOL/Treasury/HHS- guidance on maximum duration of relief extending certain participant and plan deadlines resulting from COVID-19
ERISA uniformity
High Deductible Health Plans (HDHPs)
Health Savings Accounts (HSAs)
State health care requirements affecting self-insured plans
Telehealth
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), Equal Employment Opportunity Commission (EEOC)
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 |
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Lynn |
Dudley |
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Diann |
Howland |
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Jill |
Randolph |
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Ilyse |
Schuman |
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Senate HELP Committee, Chief Labor Counsel, Minority Staff Director, Chief Counsel |
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Kathryn |
Johnson |
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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) |