LD-2 Disclosure Form

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

1. Registrant Name Organization/Lobbying Firm Self Employed Individual

CARLOW CONSULTING, LLC

2. Address

Address1

228 Oakland Park Avenue

Address2

City

Columbus

State

Zip Code

43214

Country

USA

3. Principal place of business (if different than line 2)

City

State

Zip Code

Country

4a. Contact Name		b. Telephone Number	c. E-mail
Ms.	Carol Nolan Drake	6145812156	carol@carlowconsulting.com

5. Senate ID#

401104840-12

7. Client Name	Self	Check if client is a state or local government or instrumentality
School Employees Retirement System of Ohio

6. House ID#

440410001

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.

The "End Government Shutdowns Act, which is S. 104, in order to ensure that key federal responsibilities are not impacted, such as Social Security, funding for addressing the opioid crisis, regulatory agencies, i.e., the SEC, and several Cabinet agencies including HHS, DOL and Treasury/IRS as they work on proposed rules.

H.R. 865, a bill introduced by Rep. Bobby Scott (D-VA), to provide for the long-term improvement of public school facilities, and for other purposes, was introduced on January 30. The federal government appropriates money in the Department of Education budget to repair schools in cases of disasters. The majority of school improvements and new building costs remain with the individual states.

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

H.R.658, the National Infrastructure Development Bank Act of 2019, introduced on January 17, by Rep. Rosa DeLauro (D-CT) could be a vehicle to finance a National Infrastructure Development Bank for private and public pension funds to invest up to $300 billion in long duration bonds.

Rep. Joyce Beatty (D-OH) was named the Chairwoman of the new Financial Services Diversity and Inclusion (D&I) Subcommittee to look into diversity and inclusion in the Financial Services Industry. Hearings were held in the Committee on Financial Services an the Subcommittee to consider the issues and discuss ways to improve diversity.

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

The partial shutdown impacted the ability of key regulatory agencies, DOL, HHS and Treasury/IRS
to move forward on reviewing comment letters pertaining to the proposed HRA Excepted Benefits Rule and decide whether to extend Limited Wraparound Plans. Discussions were held to understand the status of the comments received and when decisions might be made.
Rep. David Joyce introduced H.R.383, a bill called, the Continuing Coverage for Preexisting Conditions Act of 2019, on January 9. The bill would amend the Patient Protection and Affordable Care Act to ensure that preexisting condition exclusions with respect to enrollment in health insurance coverage and group health plans continue to be prohibited.
Rep. Joe Courtney (D-CT) introduced a bill on January 24 to repeal the Cadillac tax, the Affordable Care Act's forty percent tax on high-cost health plans. H.R. 748, entitled the Middle Class Health Benefits Tax Repeal Act would amend the Internal Revenue Code of 1986 to repeal the excise tax on high cost employer-sponsored health coverage.
A bill, S.61, the Safe and Affordable Drugs from Canada Act of 2019, sponsored by Senator Chuck Grassley (R-IA), was introduced on January 9. The bill would amend the Federal Food, Drug, and Cosmetic Act to allow for the personal importation of safe and affordable drugs from approved pharmacies in Canada.
S. 489, a bill to establish a State public option through Medicaid to provide Americans with the choice of a high-quality, low-cost health insurance plan, was introduced on February 14 by Senator Brian Schatz (D-HI). A companion bill has been introduced in the House, which is H.R. 1277. Rep. Marcia Fudge (D-OH) is a cosponsor.

S.692, a bill to amend the Internal Revenue Code of 1986 to repeal the excise tax on medical devices, was introduced by Senator Pat Toomey (R-PA) on March 7.
S.684, a bill to amend the Internal Revenue Code of 1986 to repeal the excise tax on high cost employer-sponsored health coverage, the Cadillac Tax was introduced on March 6 by Senator Martin Heinrich (D-NM).
H.R. 1398, a bipartisan bill to delay the re-imposition of the annual fee on health insurance providers, aka the Health Insurance Tax (HIT) until after 2021 was introduced on February 27. The bill was introduced by Rep. Ami Bera (D-CA). Rep. Steve Stivers (R-OH) introduced H.R. 1366, the Responsible Additions and Increases to Sustain Employee Health Benefits Act, RAISE Act to put flexibility back in Flexible Spending Accounts and to help families pay for out of pocket health care costs.
On February 5, H.R. 965, the CREATES Act, was reintroduced in Congress by Rep. David Cicilline (D-RI). The bill would promote competition in the market for drugs and biological products by facilitating the timely entry of lower-cost generic and biosimilar versions of those drugs and biological products.

Senator Rob Portman (R-OH) introduced the Biologic Patent Transparency Act. The bill would require companies to publicly disclose the web of patents that protect their biologics, making it easier for competitors to evaluate and plan for the development of generic versions of these drugs.
S.516, the Prescription Drug Monitoring Act of 2019, was introduced by Senator Amy Klobuchar (D-MN) on February 14. The bill would require the use of prescription drug monitoring programs.
Another Senate bill, S.475, the RxCAP Act of 2019, was introduced by Senator Ron Wyden (D-OR) on February 13. The bill would amend title XVIII of the Social Security Act to prevent catastrophic out-of-pocket spending on prescription drugs for seniors and individuals with disabilities.

Senator Sherrod Brown introduced S. 378, the Stop Price Gouging Act. The bill would penalize pharmaceutical companies that engage in price gouging without cause, leading to price spikes for patients who rely on medication to treat illnesses. H.R. 1091 is the companion House bill, which has been cosponsored by Rep. Marcy Kaptur (D-OH).

On February 7, Senator Sherrod Brown introduced legislation to address prescription drug affordability. The bill, S. 377, entitled, "The Medicare Negotiation and Competitive Licensing Act," would authorize the Secretary of Health and Human Services to negotiate drug prices and if a drug company refuses to negotiate in good faith, the secretary would be enabled to issue a competitive, compulsory license to another company that is willing and able to produce the medication as a generic.

On February 13, Senator Ron Wyden (D-OR) introduced S.476, a bill for Creating Transparency to Have Drug Rebates Unlocked (C-THRU) Act of 2019. Senator Sherrod Brown is one of the cosponsors. The bill would amend titles XI and XVIII of the Social Security Act to provide greater transparency of discounts provided by drug manufacturers.

At the end of January 2019, the Health and Human Services Department issued a proposed rule, Fraud and Abuse; Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and Creation of New Safe Harbor Protection for Certain Point-of-Sale Reductions in Price on Prescription Pharmaceuticals and Certain Pharmacy Benefit Manager Service Fees. The proposed rule has been interpreted to eliminate safe harbor protection for rebates paid by drug manufacturers to pharmacy benefit managers (PBMs), Medicare Part D plans and Medicaid managed care plans; create a new safe harbor for drug discounts offered to patients at the point of sale, and
create a new safe harbor for PBM fees charged to drug manufacturers.

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Centers For Medicare and Medicaid Services (CMS), Internal Revenue Service (IRS), Labor - Dept of (DOL), Treasury - Dept of, Health & Human Services - Dept of (HHS)

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

H.R. 860, the Social Security 2100 Act, to protect our Social Security system and improve benefits for current and future generations, was introduced. The bill would provide an across-the-board benefit increase equivalent to about 2 percent of the average Social Security benefit amd make other substantial changes.
S.521, the Social Security Fairness Act, was introduced by Senator Sherrod Brown (D-OH) on February 14. The bill has eight cosponsors and would amend title II of the Social Security Act to repeal the Government pension offset and windfall elimination provisions.
H.R. 141, the companion bill, was introduced.

Rep. Richard Neal (D-MA), the new chairman of the House Ways and Means Committee, introduced H.R.397, the Rehabilitation for Multiemployer Pensions Act on January 9. The House Committee on Education and Labor, Subcommittee on Health, Employment, Labor, and Pensions, held a hearing entitled, The Cost of Inaction: Why Congress Must Address the Multiemployer Pension Crisis, on Thursday, March 7. (It is important to distinguish private and public multiemployer pension plans.)

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

H.R. 1346, a bill to amend title XVIII of the Social Security Act to provide for an option for individuals who are ages 50 to 64 to buy into Medicare, to provide for health insurance market stabilization, and for other purposes, was introduced on February 25. The bill, the Medicare Buy-In and Health Care Stabilization Act of 2019, was sponsored by Rep. Brian Higgins (D-NY).

Senator Sherrod Brown has cosponsored S.470, the Medicare at 50 Act, which was introduced on February 13 by Senator Debbie Stabenow (D-MI). The bill would amend title XVIII of the Social Security Act to provide for an option for any citizen or permanent resident of the United States age 50 to 64 to buy into Medicare.
Medicare for All plan, which would establish a national health insurance program. H.R. 1381 was introduced on February 27, by Rep. Pramila Jayapal (D-WA).

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.

23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client

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

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

First Name	Last Name	Suffix	Covered Official Position (if applicable)	New
Carol	Nolan Drake		Federal Liaison

First Name	Last Name	Suffix	Covered Official Position (if applicable)	New
Carol	Nolan Drake		Federal Liaison

First Name	Last Name	Suffix	Covered Official Position (if applicable)	New
Carol	Nolan Drake		Federal Liaison

First Name	Last Name	Suffix	Covered Official Position (if applicable)	New
Carol	Nolan Drake		Federal Liaison

First Name	Last Name	Suffix	Covered Official Position (if applicable)	New
Carol	Nolan Drake	Carlow	Federal Liaison