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

9. Check if this filing amends a previously filed version of this report

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

Discussions on drug pricing, 340b, and price transparency policies, as well as the International Pricing Index ANPRM; Discussions about the work of Aligning for Health to address social determinants of health; Support HR 1041 / S 586,Critical Access Hospital Relief Act of 2019, a bill to amend title XVIII of the Social Security Act to remove the 96-hour physician certification requirement for inpatient critical access hospital services; Support S 895, Rural Hospital Regulatory Relief Act of 2019, a bill to provide for a permanent extension of the enforcement instruction on supervision requirements for outpatient therapeutic services in critical access and small rural hospitals; Support S 948,Conrad State 30 and Physician Access Reauthorization Act, a bill to provide incentives to physicians to practice in rural and medically underserved communities, and for other purposes; Discussions in support of the Rural Emergency Medical Center Act (REACH) Act; Support for extension of the Rural Community Hospital Demonstration Program; Support for extension of the Frontier Community Health Integration Project Demonstration program; Discuss changes with House and Senate committees to Section 8122 of the SUPPORT for Patients and Communities Act; Letter of support to Energy and Commerce Committee for the hearing on legislation to strengthen our health care system and ACA market stability; Support HR 1781/ S 801, Payment Commission Data Act of 2019, a bill to amend titles XVIII and XIX of the Social Security Act to provide the Medicare Payment Advisory Commission and the Medicaid and CHIP Payment and Access Commission with access to certain drug payment information, including certain rebate information; Support S 551 Recovering Excessive Funds for Unused and Needless Drugs Act of 2019 or the REFUND Act of 2019, a bill to amend title XVIII of the Social Security Act to require manufacturers of certain single-dose vial drugs payable under part B of the Medicare program to provide rebates with respect to amounts of such drugs discarded, and for other purposes; Support S 824/ HR 1767, Excellence in Mental Health and Addiction Treatment Expansion Act, a bill to increase the number of States that may conduct Medicaid demonstration programs to improve access to community mental health services; Statement submitted to Senate Finance Committee on the implementation of the Quality Payment Program (QPP) created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA); Support HR 2552Protecting Local Access to Care for Everyone Act of 2019 or the PLACE Act of 2019, a bill to direct the Secretary of Health and Human Services to prevent certain payment reductions for clinic visit services furnished at excepted off-campus outpatient departments of a provider under the Medicare program; Support HR 3022, Patient Access Protection Act, a bill to amend title XIX of the Social Security Act to repeal the reductions in Medicaid DSH allotments, and for other purposes; Letter of support to the Ways and Means Committee in support of legislation to improve the quality of an access to services for Medicare beneficiaries, help train the physician workforce and reduce administrative burden on rural hospitals; Support HR 3431, HEARTS and Rural Relief Act, a bill to provide for the extension of the enforcement instruction on supervision requirements for outpatient therapeutic services in critical access and small rural hospitals through 2021; Support HR 3417,Beneficiary Education Tools, Telehealth, and Extenders Reauthorization Act of 2019 or the BETTER Act of 2019, a bill to amend title XVIII of the Social Security Act to provide for patient improvements and rural and quality improvements under the Medicare program; Oppose HR 1384, Medicare for All Act of 2019, a bill to establish an improved Medicare for All national health insurance program; Oppose S 1129, Medicare for All Act of 2019, a bill to establish a Medicare-for-all national health insurance program; Letter to House Committee on Ways and Means for the hearing on Pathways to Universal Health Coverage addressing concerns with Medicare for All and believe that the variety of proposals that often are used interchangeably under that name are not the solution; Oppose HR 2452, Medicare for America Act of 2019, a bill to amend the Social Security Act to establish a Medicare for America health program to provide for comprehensive health coverage for all Americans; Letter to House Committee on Budget for the hearing on the Congressional Budget Offices (CBO) Key Design Components and Considerations for Establishing a Single-Payer Health Care System addressing concerns with Medicare for All; Oppose S 1261/ HR 2463, Choose Medicare Act, a bill to provide for the establishment of Medicare part E public health plans, and for other purposes; Oppose S 981/ HR 2000Medicare-X Choice Act of 2019A bill to establish a public health plan; Oppose S 1033/ HR 2085, CHOICE Act, a bill to amend the Public Health Service Act to establish a public health insurance option, and for other purposes; Oppose S 470, Medicare at 50 Act, a bill to 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; Oppose HR 1346, Medicare Buy-In and Health Care Stabilization Act of 2019, 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; Submitted Statement to the House Committee on Rules for the Hearing Medicare for All Act of 2019; Comment on provisions of HR 2328,Reauthorizing and Extending Americas Community Health (REACH) Act, support for the Medicaid disproportionate share hospital(DSH) program provisions included in Title III; comments on Title IV, which contains provisions of the No Surprises Act and concern with the legislations approach to determining reimbursement for out-of-network providers; Support HR 3107 Seniors Timely Access to Care Act of 2019, this legislation would establish requirements for the use of prior authorization under Medicare Advantage plans; Meeting with the Senate finance committee to discuss changes to drug bill; Meeting with CMS to discuss changes to prior authorization; Meeting with Department of Labor to discuss issues with ERISA health plans; Met with CMS staff on rural hospital issues; Regulatory burden related to new CMS guidance on documenting Crossover bad debt; Sent a Comment letter to CMS on a final rule on program integrity enhancements to the provider enrollment process for Medicare, Medicaid and Children's Health Insurance Programs; Oppose S. 2860 Patient Access to Higher Quality Health Care Act of 2019, a bill to repeal changes made by health care reform laws to the Medicare exception to the prohibition on certain physician referrals for hospitals, and for other purposes; Support HR 4996, Helping MOMS Act of 2019, a bill amend title XIX of the Social Security Act to provide for a State option under the Medicaid program to provide for and extend continuous coverage for certain individuals, and for other purposes; Addressing hospital concerns about HR 3 Lower Drug Costs Now Act, a bill to establish a fair price negotiation program, protect the Medicare program from excessive price increases, and establish an out-of-pocket maximum for Medicare part D enrollees, and for other purposes; Sent comment letter requesting that CMS withdraw the proposed regulation related to Medicaid Program: Medicaid Fiscal Accountability Regulation ( MFAR) financing and supplemental payments. Given that the proposal would severely curtail the availability of health care services to millions of individuals and because many of its provisions are not legally permissible; Discussion with CMS for rural hospitals and critical access hospitals about the Medicare accelerated payment program, which is intended to provide necessary funds to providers, including rural hospitals and critical access hospitals, when there is a disruption in claims submission and/or claims processing; Submitted comments on CMSs proposed rule on Medicare Advantage and Part D prescription drug program for Contract Years 2021 and 2022. The letter focuses on several proposals addressing network adequacy; Letter sent to HHS, CDC, CMS, and SAMHSA requesting specialized guidance and assistance for providers who care for patients with behavioral health disorders; Support resetting the Improving Medicare Post- Acute Care Transformation (IMPACT) Act of 2014 in the next COVID-19 relief package. The IMPACT Acts implementation is behind schedule and does not take into account extensive payment reforms already underway in each post-acute care setting; Letter urging HHS to release substantial additional emergency funds to all hospitals in an expedited manner. This second wave of funding to all hospitals, targeted relief is necessary for hospitals in hot spots, hospitals with a high percentage of payments under Medicare Advantage, hospitals caring for high numbers of Medicaid patients, and rural hospitals; Support HR 6693 Critical Access Hospital Expansion Act of 2020, a bill to amend title XVIII of the Social Security Act to allow States to certify certain hospitals as necessary providers for purposes of designating such hospitals as critical access hospitals under the Medicare program; Support HR 6753/ S 3615 Rural Community Hospital Demonstration Extension Act of 2020, a bill to amend the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 to extend the rural community hospital demonstration program; Letter urging CMS to use its authority to extend to LTCHs the existing 20% hospital add-on payment for Medicare beneficiaries diagnosed with COVID-19; Letter to CMS urging the agency to temporarily extend certain waivers and make others permanent beyond the COVID-19 public health emergency to allow hospitals to provide better and more cost effective care to their patients and communities; Sent comment letter to CMS about our concerns with the timeline proposed for implementation as well as the potential for penalties for noncompliance within this timeline on the Medicare Program: Electronic Prescribing of Controlled Substances; Sent comment letter on the FY 2021 Inpatient PPS proposed rule addressing CMS proposals related to payer-specific negotiated rate data collection, Medicare DSH payments, CAR T, bad debt, MS-DRG classifications, and quality programs, among other topics. Letter requesting that the CMS delay the implementation of the Appropriate Use Criteria for Advanced Diagnostic Imaging Services program to allow providers the opportunity to implement and test operational changes and acquire the education necessary to achieve compliance with the program; Sent comments to the CMS on the agencys long-term care hospital prospective payment system proposed policy changes and fiscal year 2021 rates; Letter to CMS asking for a delay in the start of repayments associated with the Medicare Accelerated and Advance Payment (AAP) Programs; Letter urging the CMS to continue its suspension of medical review activities throughout the ongoing COVID-19 public health emergency; Letter urging CMS to allow periodic interim payment (PIP) hospitals to carry out their accelerated payment repayment at cost settlement, as was initially communicated by the agency and also request that the agency make alternative repayment approaches available, such as direct payments to the Medicare Administrative Contractor (MAC), for all hospitals; Comment letter on CY 2021 Home Health Prospective Payment System Rate Update proposed rule. While we continue to support the PDGM objective of increasing HH PPS payment accuracy, we remain concerned that CY 2020s large behavioral offset, 4.36%, was implemented on a prospective basis; Letter urging the CMS to withdraw the condition of participation (CoP) that hospitals report daily COVID-19 data and request that CMS immediately release detailed interpretive guidance so hospitals can take the necessary steps to come into compliance; Urged CMS to withdraw its Medicaid fiscal accountability proposed rule from its regulatory agenda because it would "severely curtail the availability of health care services to millions of individuals" and "many of its provisions are not legally permissible."

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), Labor - Dept of (DOL)

18. Name of each individual who acted as a lobbyist in this issue area

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

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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

Support HR 1763/ S 348, Resident Physician Shortage Reduction Act of 2019, a bill to amend title XVIII of the Social Security Act to provide for the distribution of additional residency positions; Oppose HR 506,Hospital Competition Act of 2019, a bill to amend title XVIII of the Social Security Act to increase hospital competition; Statement submitted to the House Judiciary on the hearing "Diagnosing the Problem: Exploring the Effects of Consolidation and Anticompetitive Conduct in Health Care Markets";Letter of support for the Senate Workgroups efforts to ensure consumer protections by addressing surprise medical bills and comments on the development of legislation to protect patients from surprise medical bills; Letter urging Congress and the Administration to take further action to help reduce input and administrative costs, as well as maximize the number of insured patients; Support HR 965/ S340, Creating and Restoring Equal Access to Equivalent Samples Act of 2019 or the CREATES Act of 2019, a bill to 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; Support HR 986/ S466 Protecting Americans with Preexisting Conditions Act of 2019, a bill provide that certain guidance related to waivers for State innovation under the Patient Protection and Affordable Care Act shall have no force or effect; Support HR 987 Strengthening Health Care and Lowering Prescription Drug Costs Act, a bill to amend the Patient Protection and Affordable Care Act to provide for Federal Exchange outreach and educational activities; Support HR 938 Bringing Low-cost Options and Competition while Keeping Incentives for New Generics Act of 2019 or the BLOCKING Act of 2019, a bill to amend the Federal Food, Drug, and Cosmetic Act, with respect to eligibility for approval of a subsequent generic drug, to remove the barrier to that approval posed by the 180-day exclusivity period afforded to a first generic applicant that has not yet received final approval, and for other purposes; Support HR 1010, a bill to provide that the rule entitled Short-Term, Limited Duration Insurance shall have no force or effect; Support HR 1499 Protecting Consumer Access to Generic Drugs Act of 2019, a bill to prohibit brand name drug manufacturers from compensating generic drug manufacturers to delay the entry of a generic drug into the market, and to prohibit biological product manufacturers from compensating biosimilar and interchangeable product manufacturers to delay entry of biosimilar and interchangeable products, and for other purposes; Support HR 1425 State Health Care Premium Reduction Act, a bill to amend the Patient Protection and Affordable Care Act to provide for a Improve Health Insurance Affordability Fund to provide for certain reinsurance payments to lower premiums in the individual health insurance market; Support HR 1386/ S 1905 Expand Navigators Resources for Outreach, Learning, and Longevity Act of 2019 or the ENROLL Act of 2019,a bill to amend the Patient Protection and Affordable Care Act to provide for additional requirements with respect to the navigator program, and for other purposes; Support HR 1520 Purple Book Continuity Act of 2019, a bill to amend the Public Health Service Act to provide for the publication of a list of licensed biological products, and for other purposes; Support HR 1503 Orange Book Transparency Act of 2019A bill that would increase transparency for the patent status of both approved biological products and approved drugs; Support HR 2439/ HR 3414 Opioid Workforce Act of 2019, a bill to amend title XVIII of the Social Security Act to provide for the distribution of additional residency positions to help combat the opioid crisis; Submitted statement to the House Committee on Ways and Means Overcoming Racial Disparities and Social Determinants in the Maternal Mortality Crisis sharing information regarding hospitals and health systems efforts to address maternal morbidity and mortality, as we seek ways to improve outcomes and reduce health inequities for expectant and new mothers, and give their children the best possible start in life; Submitted oral and written testimony to the House Committee on Ways and Means Subcommittee on Health Hearing on Protecting Patients from Surprise Medical Bills. Protecting patients from surprise medical bills is a top priority and we have adopted a set of guiding principles to use as we evaluate legislative proposals: Define surprise bills, Protect the patient financially, Ensure patient access to emergency care, Preserve the role of private negotiation, Remove the patient from health plan/provider negotiations, Educate patients about their health care coverage, Ensure patients have access to comprehensive provider networks and accurate network information, and Support state laws that work; Letters submitted to the Energy & Commerce Committee in response to the request for comments on their surprise billing discussion draft. Concerned with the Committees draft legislations approach to determining reimbursement for out-of-network providers. Once the patient is protected from surprise bills, providers and insurers should then be permitted to negotiate payment rates for services provided. We strongly oppose approaches that would impose arbitrary rates on providers. We look forward to continuing to work with the Committee on solutions to stop surprise medical bills; Letter sent to the HELP Committee in response to the Lower Health Care Costs Act of 2019 discussion draft about our concerns about several of the proposals that would allow the government to intrude into private commercial contracts between providers and insurers. For example, several of the provisions could undermine value-based purchasing arrangements aimed directly at improving the quality of care while reducing costs. We strongly urge the Committee to remove these provisions; Submitted oral and written testimony to the House Committee on Energy and Commerce, Subcommittee on Health Hearing on No More Surprises: Protecting Patients from Surprise Medical Bills asking that the Committee preserve the ability of providers and insurers to negotiate private contracts and not establish a fixed payment amount for out-of-network services; Oppose HR 1309 Workplace Violence Prevention for Health Care and Social Service Workers Act, a bill to direct the Secretary of Labor to issue an occupational safety and health standard that requires covered employers within the health care and social service industries to develop and implement a comprehensive workplace violence prevention plan, and for other purposes; Concerns about S.1531, Stopping The Outrageous Practice of Surprise Medical Bills Act of 2019 or the STOP Surprise Medical Bills Act of 2019, to amend the Public Health Service Act to provide protections for health insurance consumers from surprise billing; Concerns about S. 1895 Lower Health Care Costs Act Letter addressed concerns about the legislative provision that sets a benchmark rate in statute for the out-of-network payments, as well as provisions that seek to change privately negotiated contracting arrangements between hospitals and insurance companies; Support HR 3425, Advancing Medical Resident Training in Community Hospitals Act of 2019, to amend title XVIII of the Social Security Act to establish rules for payment for graduate medical education (GME) costs for hospitals that establish a new medical residency training program after hosting resident rotators for short durations; Expressed concerns regarding the provisions that reduce reimbursements to providers and hospitals that administer drugs the Prescription Drug Pricing Reduction Act (PDPRA) of 2019: including about Section 107, Medicare Part B Rebate by Manufacturers for Drugs or Biologicals with Prices Increasing Faster than Inflation, Section 110, Establishment of Maximum Add-on Payment for Drugs, Biologicals, and Biosimilars, this provision would establish $1,000 as the maximum add-on amount that a provider can be paid for a separately payable drug, biological or biosimilar, Section 111, Treatment of Drug Administration Services Furnished by an Off-Campus Outpatient Department of a Provider, the site neutral payment reduction would cut aggregate hospital payments; Support S. 2091, Backlog Elimination, Legal Immigration, and Employment Visa Enhancement Act, this legislation would increase the total number of employment-based visas from 140,000 to 270,000 and ensure that critical health care workers needed in the U.S. have access to employment-based visas by carving out health care workers in designated shortage occupations from the limit; Support S 350, The Competitive Health Insurance Reform Act of 2019, a bill to restore the application of the Federal antitrust laws to the business of health insurance to protect competition and consumers; Submitted statement to Subcommittee on Health of the Committee on Energy and Commerce for the hearing on Improving Maternal Health: Legislation to Advance Prevention Efforts and Access to Care; Concerns with S. 386 and HR 1044, Fairness for High-Skilled Immigrants Act of 2019, this bill increases the per-country cap on family-based immigrant visas from 7% of the total number of such visas available that year to 15%, and eliminates the 7% cap for employment-based immigrant visas. It also removes an offset that reduced the number of visas for individuals from China; Support H.R. 4538, Closing Loopholes for Orphan Drugs Act, a bill to amend title III of the Public Health Service Act to limit the orphan drug exclusion under the drug discount program under section 340B of such title; Discussions of provisions we support and those we recommend be changes in a draft bill called the Mitigating Existing Drug Shortages (MEDS) Act; Discussions in support of the allowing states to designate hospitals as necessary providers for purposes of waiving the critical access hospital mileage requirements; Provided comments to W&M on legislation to expand Health Profession Opportunity Grants; Support S. 2723, The Mitigating Emergency Drug Shortages (MEDS) Act, a bill to amend Sec. 506C of the Federal Food, Drug, and Cosmetic Act which strengthens requirements for drug manufacturers to disclose the root causes and expected duration of shortages, extends reporting requirements to active pharmaceutical ingredients manufacturers, requires manufacturers have contingency plans to ensure ongoing supply, develops recommendations to incentivize manufacturers to enter the market for drugs in shortage and examines the national security risks of shortages; Discuss DEA reductions in annual quotas for opioid products used by hospitals for sedation and pain management; Meeting with the Office of the Assistant Secretary of Preparedness and Response (ASPR) to discuss developments in the hospital preparedness program, the pilot projects for the Regional Disaster Healthcare System and other issues; Rural access to health care, including identifying core services needed in rural communities, outlining approaches and considerations for delivering those services, and examining access and quality in the rural context; ONCs proposed rule to implement the 21st Century Cures provision on information blocking; Supported members serving on the HHS Quality Summit panel, which was convened by the Deputy Secretary to gather input regarding how to improve and energize quality and safety improvement activities across health care system; Discussion with HHS on drug pricing, 340b, and price transparency policies, as well as the International Pricing Index ANPRM; Discussion with HHS about the work of Aligning for Health to address social determinants of health; Support S 2902, Strengthening Our Rural Health Workforce Act of 2019, a bill to enhance the rural health workforce; Meetings and correspondence with staff members of Senate Financing Committee on a proposal to support rural health care access (REH, re-opening necessary provider CAH, infrastructure funding); Letter to Ways & Means committee Rural and Underserved Communities Health Task Force in response to RFI on factors that contribute to health outcomes in these areas, examples of successful models and lessons from the field that address access and outcomes, and considerations for the unique circumstances of rural and underserved communities; Letter to Energy and Commerce Members regarding health information technology priorities; Letter of Support to Senate Appropriations on funding for the Centers for Disease Control and Prevention and the National Institutes of Health to study gun violence; Support S.2741 and H.R. 4932,Creating Opportunities Now for Necessary and Effective Care Technologies (CONNECT) for Health Act of 2019, a bill to amend title XVIII of the Social Security Act to expand access to telehealth services, and for other purposes; Support S 2603, Resolving Extended Limbo for Immigrant Employees and Families (RELIEF) Act, a bill to amend the Immigration and Nationality Act to end the immigrant visa backlog, and for other purposes; Support HR 4995, Maternal Health Quality Improvement Act of 2019, a bill to amend the Public Health Service Act to improve obstetric care and maternal health outcomes, and for other purposes; Concerns with HR 5800,Ban Surprise Billing Act, a bill to address surprise medical bills that relies on a median in-network rate to resolve out-of-network payments and allows for an independent dispute resolution process to determine the final payment. Concerned with the Committee's legislative approach to determining reimbursement for out-of-network providers. Oppose approaches that would impose arbitrary rates on providers, which could have significant consequences far beyond the scope of surprise medical bills. It is the insurers' responsibility to maintain comprehensive provider networks, and a default payment rate would remove incentives for health plans to contract with providers or to offer fair terms; Support HR 5826, Consumer Protections Against Surprise Medical Bills Act, a bill that prohibits providers from balance billing patients for emergency services or medical care the patient reasonably could have expected to be in-network, and from charging patients more than the in-network cost-sharing amount. Rather than rely on a benchmark payment rate to determine out-of-network reimbursement, the legislation provides a period for health plans and providers to negotiate out-of-network reimbursement, followed by a mediated dispute resolution process if necessary; Letter urging HHS to take regulatory actions to help hospitals and health systems prepare and respond to COVID-19; Letter requesting $100 billion to prepare and respond to COVID-19; Letter urging the Department of Labor to accurately define health care provider when promulgating regulations implementing key sections of the Families First Coronavirus Response Act; Letter sent to the President asking for the use of the Defense Production Act to increase the production of medical supplies and equipment; Letter to HHS regarding $100 billion emergency fund, asking HHS and CMS to directly and expediently distribute to rural and urban hospitals and health systems funds from the Public Health and Social Services Emergency Fund that were designated for providers in the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The CARES Act increased funding by $100 billion in order to reimburse eligible health care providers for health care-related expenses or lost revenues that are attributable to COVID-19. In the letter, we urged HHS and CMS to immediately distribute funding to all hospital types in the US - with additional funding going to COVID-19 hotspots; Letter urging Congress to modernize the Stafford Act as part of its next COVID-19 legislative package to allow all hospitals to recoup financial losses from this pandemic and future disasters; Letter to the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency requesting they, as primary federal regulators for insured depository institutions, take prompt action to assist health care providers on the front line of the COVID-19 pandemic should the need to do so arise; Letter to the Secretary of the Treasury and the Federal Reserve Chair of the Board of Governors urging a supplement to the New Main Street Loan Facility term sheet with prompt guidance to ensure that access to this critically-necessary loan facility will be attainable for hospitals without delay; Letter was sent to the SBA urging it to ensure that small- and mid-size public hospitals, including those that have both nonprofit and public designations, are allowed to apply for and receive loans under the newly-authorized SBA Paycheck Protection Program; Letter in response to FEMAs request for input on establishing a voluntary agreement, under the Defense Production Act, of key private sector stakeholders relevant to responding to COVID-19, urging that such an agreement account for the full breadth of COVID-19 medical supply and equipment needs; Support H.R. 6474/S.3838 Healthcare Broadband Expansion During COVID-19 Act, a bill that would provide an additional $2 billion in funding for the FCC Rural Health Care program and increase the subsidy for health care providers from 65 to 85 percent. This legislation also simplifies the program to allow for more efficient application processes and disbursement of much needed funding; Support HR 6654 Emergency COVID-19 Telehealth Response Act, a bill that would codify an expanded list of providers to deliver and bill for telehealth services during the PHE; Support HR 7233Knowing the Efficiency and Efficacy of Permanent (KEEP) Telehealth Options Act of 2020, a bill that would require the Department of Health and Human Services and the Government Accountability Office (GAO) to conduct studies to provide information about the expanded use of telehealth during the COVID-19 pandemic; Letter to Senate HELP Committee in response to request for feedback on preparing for next pandemic; Discussion about telehealth waivers and flexibilities with HHS; Discussion about CARES provider relief fund distributions with HHS; Oppose HR 6559/ S 3677 COVID-19 Every Worker Protection Act of 2020, a bill to require the Occupational Safety and Health Administration to promulgate an emergency temporary standard to protect employees from occupational exposure to SARS-CoV-2, and for other purposes; Joint letter with ANA urging Congress to act quickly to get needed resources into the health care system, so that hospitals, nurses and physicians responding to COVID-19 are able to continue to provide treatments, front-line health care personnel are able to provide care and patients are able access health care services; Statement to Committee on Ways and Means for the hearing on The Disproportionate Impact of COVID-19 on Communities of Color urging Congress to employ the resources of the National Institute on Minority Health and Health Disparities - which is congressionally-mandated to coordinate the research of the other National Institutes of Healths centers and institutes related to minority health - to research and develop approaches to specifically address the COVID-19 needs of minority populations; Advocate with Congress for full forgiveness of COVID-19 related accelerated payments received by hospitals; Support S 3781Pharmaceutical Accountability, Responsibility, and Transparency (PART) Act, a bill to increase reporting of, help mitigate potential shortages related to, and promote, accountability and transparency for pharmaceuticals and medical devices; Support S 3780 Help Onshore Manufacturing Efficiencies (HOME) for Drugs and Devices Act, a bill to encourage domestic advanced manufacturing of critical drugs and devices in order to address economic, health, and security concerns, combat shortages of critical drugs and devices, and promote increased domestic diversification of, and independence from foreign reliance on, pharmaceutical and medical device supply chains; Support S.3763 Pandemic Responder Service Award Act, a bill to establish the Pandemic Responder Service Award program to express our gratitude to front-line health care workers; Support HR 6788/ S 3599 Healthcare Workforce Resilience Act, a bill to enhance our Nations nurse and physician workforce during the COVID-19 crisis by recapturing unused immigrant visas; Urged support for joint House and Senate letter to the Administration asking for flexibility for hospitals with respect to J-1 and H-1B visa programs; Letter to Senate Finance Committee to address the important issue of maternal health and the opportunity to provide suggestions regarding how to improve maternal health in this country; Support the Temporary Reciprocity to Ensure Access to Treatment Act, a bill that allows for the temporary reciprocity for treatment by medical professionals licensed in one state to patients in other states; Letter urging the Senate to include in the next COVID-19 relief bill provisions to strengthen the federal response for racial and ethnic minority and marginalized communities, which are disproportionately affected by the pandemic;Letter asking Congress to allocate as part of the next COVID-19 relief package at least an additional $100 billion to the emergency relief fund to provide direct funding to front line health care personnel and providers to continue to respond to this pandemic; Letter sent to HHS urging them to direct HRSA to take action to stop three drug manufacturers from limiting the distribution of 340B drugs to 340B covered entities. These drug manufacturers have taken separate actions to either limit the distribution of 340B drugs or require 340B covered entities provide claims level data for investigatory purposes if that 340B covered entity uses a contract pharmacy arrangement; Letter to the Congressional Leadership asking them to not to include in the next COVID-19 relief package any surprise medical billing legislation - such as a reimbursement rate set in statute - that would further destabilize hospitals finances during the pandemic; Support S 4507, Getting Early Treatment and Comprehensive Assessments Reduces Emergencies Act of 2020 or the GET CARE Act of 2020, a bill to amend the Public Health Service Act to provide for a national campaign to raise awareness of the importance of seeking preventive health services and the utilization of such services; Comment letter addressing concerns on the proposed rule from the Departments of the Treasury, Labor and Health and Human Services that would allow certain grandfathered health plans to increase patient cost-sharing beyond current limits, without losing their grandfathered status; Letter urging the Administration to work with the AHA and Congress to create a future for telehealth that allows not only clinicians, but also hospitals and health systems, to code and bill for virtual services. We further urge CMS and HHS to continue to provide hospitals with the flexibility for annual beneficiary consent to telehealth treatment to be obtained at the same time, and not necessarily before, services are furnished; Support HR 8061,Community Immunity During COVID-19 Act of 2020, a bill that would provide funding to state and local health departments to work with community providers and organizations to increase immunization rates for Advisory Committee on Immunization Practices (ACIP)-recommended vaccines during the COVID-19 public health emergency; Letter again expressing concern with recent actions taken by several major drug manufacturers to limit the distribution of certain 340B drugs to our hospital members. While we understand that the HRSA is further investigating these actions, we urge swift and decisive action to halt these pernicious tactics so as to prevent other manufacturers from following suit; Comment letter outlining our concerns about the ability of hospital systems to distribute provider relief funds among the parent and subsidiaries. HHS published certain FAQs that place problematic restrictions on the use of CARES Act provider relief fund dollars. Specifically, the FAQs restrict the ability of a hospital system to allocate the funds throughout its system where COVID-19 related expenses and lost revenues are occurring; Submitted comments in response to HRSAs RFI on Health Professional Shortage Area (HPSA) scoring. HPSA scores are important for rural hospitals and clinics ability to recruit physicians and other clinicians, namely from the National Health Service Corps (NHSC) program. Letter asking HHS to reinstate the COVID-19 Provider Relief Fund reporting requirements.

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), White House Office, Drug Enforcement Administration (DEA), Office of Management & Budget (OMB), Health Resources & Services Administration (HRSA)

18. Name of each individual who acted as a lobbyist in this issue area

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

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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 LAW

16. Specific lobbying issues

Meeting with CMS and HHS OIG to relate continuing methodological issues and other errors with the OIG audits targeting hospitals for potential Medicare overpayments and to urge significant reforms of the auditing process including discontinuing use of extrapolation; Discussions on the work/fixes to the anti-kickback provisions in the Eliminating Kickback in Recovery Act of 2018; Urging FTC to give more weight to the efficiencies with demonstrable benefits for patients and their communities in agency reviews and court challenges of hospital mergers and challenges as this more holistic and balanced view of the merger could diminish pressure to enact additional Certificate of Public Advantage (COPA) legislation, and the need for hospitals to seek COPA in the future and endure the associated regulatory and cost burdens of doing so; Letter requesting that DOJ temporarily suspend enforcement of the Stark Law and Anti-Kickback Statute to enable hospitals and health systems to meet the unique circumstances created by the COVID-19 public health emergency; Urged an expeditious review and release of the Physician Self-Referral and Anti-Kickback Statute final regulations that were submitted by the CMS and the HHS Office of Inspector General in July.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Trade Commission (FTC), Justice - Dept of (DOJ), Veterans Affairs - Dept of (VA), Office of Management & Budget (OMB), Health & Human Services - Dept of (HHS)

18. Name of each individual who acted as a lobbyist in this issue area

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

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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 BUD

16. Specific lobbying issues

Monitor HR 6800Health and Economic Recovery Omnibus Emergency Solutions Act or the HEROES Act, a bill to make emergency supplemental appropriations for the fiscal year ending September 30, 2020 will help hospitals and health systems serve their communities from the Public Health and Social Services Emergency Fund, accelerated payments and temporary elimination of the Medicare sequestration, among other important provisions during this unprecedented public health crisis; Letter sent requesting funding for health care programs for fiscal year FY 2021 to prevent or minimize hospital cuts; Support of the passing of the Continuing Resolution, which included two important provisions for Americas hospitals and health systems and the patients they serve: relief on Medicare accelerated and advanced payments and a delay of Medicaid Disproportionate Share Hospital (DSH) payment cuts.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, White House Office, Office of Management & Budget (OMB)

18. Name of each individual who acted as a lobbyist in this issue area

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

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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

Monitoring the Tax Cuts and Jobs Act, legislation to overhaul the nations tax code that contains several notable provisions affecting hospitals; Individual Mandate, Access to Tax-exempt Bond Financing, Interest Deduction for Debt, Medical Expense Deductions, Executive Compensation; Support HR 3300, Economic Mobility Act of 2019, a bill to amend the Internal Revenue Code of 1986 to provide tax relief for workers and families; Letter requesting that Congress use the employer side payroll tax if they use the tax code to provide this assistance so that all hospitals benefit from that relief. The letter also highlights several bond financing options that should be considered; Support HR 2772, Investing in Our Communities Act, a bill to amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds; Support HR 3967, Municipal Bond Market Support Act of 2019, a bill to amend the Internal Revenue Code of 1986 to permanently modify the limitations on the deduction of interest by financial institutions which hold tax-exempt bonds; Support HR 6886Paycheck Protection Program Flexibility Act of 2020, a bill to amend the Small Business Act and the CARES Act to modify certain provisions related to the forgiveness of loans under the paycheck protection program, to allow recipients of loan forgiveness under the paycheck protection program to defer payroll taxes, and for other purposes; A letter requesting that the Treasury and IRS extend the deadlines for tax-exempt hospitals and health systems to prepare community health needs assessments that occur during the COVID public health emergency; Support HR 7819, Eliminating the Provider Relief Fund Tax Penalties Act of 2020, A bill that would remove an unintentional tax penalty on health care providers who received CARES Act funding under the Public Health and Social Services Emergency Fund. If left unchanged, health providers and for-profit hospitals could face a tax as high as 20% on money intended to support them during this pandemic.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS)

18. Name of each individual who acted as a lobbyist in this issue area

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

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Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

21. Client new principal place of business (if different than line 20)

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

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

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

FOREIGN ENTITIES

27. Add the following foreign entities:

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization

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?
No Yes