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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 120-34 Queens Blvd., #320 |
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City | Kew Gardens |
State | NY |
Zip Code | 11415 |
Country | USA |
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5. Senate ID# 12994-12
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6. House ID# 334210000
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TYPE OF REPORT | 8. Year | 2016 |
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 |
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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: Alexandra Bennewith |
Date | 4/20/2016 11:32:08 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
Support H.R. 292/S. 849 - Advancing Research for Neurological Diseases Act of 2015.
Wrote a letter to CDC advocating for a Traumatic Brain Injury (TBI) survey.
United Spinal signed onto Senate Health Education Labor and Pensions comment letter, facilitated by the HEALTH IT Now Coalition, of which United Spinal is a member, supporting expanded use of telehealth for individuals living with stroke and for expanded prediabetes education.
United Spinal is actively engaged in ensuring improved access to, and education of, all prescription drugs including biologic pharmaceuticals (organic compounds used to treat individuals with MS, SCI etc.) and has requested additional meetings with personnel from the U.S. Food and Drug Administration.
United Spinal supports S.849 - Advancing Research for Neurological Diseases Act of 2015. This bill will mandate that the Centers for Disease Control and Prevention track the incidence and prevalence of neurological diseases.
United Spinal supports S. 800/H.R. 1631 - Enhancing the Stature and Visibility of Medical Rehabilitation Research at the NIH Act which better coordinates rehabilitation and disability research at the NIH.
The Disability and Rehabilitation Research Coalition (DRRC), of which United Spinal is a member, offered comments in a letter to the Administration for Community Living, U.S. Department of Health and Human Services, on the proposed rule entitled, National Institute on Disability, Independent Living, and Rehabilitation Research. The proposed rule would implement the Workforce Innovation and Opportunity Act of 2014 which made significant changes to Title II (Research) of the Rehabilitation Act of 1973. It would also move NIDILRR from the Department of Education to the Department of Health and Human Services (Administration for Community Living).
United Spinal submitted comments to the FDA Arthritis Advisory Committee meeting to raise concerns about a Remicade-luck drugs and the effects of ankylosing spondylitis.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Centers For Disease Control & Prevention (CDC), Food & Drug Administration (FDA), 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 |
Alexandra |
Bennewith |
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Ross |
Meglathery |
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Kent |
Keyser |
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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 VET
16. Specific lobbying issues
HR 3016 Advocated against this bill because it caps funding for certain aviation degree programs and discriminates against veterans who want to train as rotary wing pilots.
HR 385 HAVEN Act. Working with Congressman Al Greens office to make recommendations to Department of Housing and Urban Development for the implementation of a grant program that helps low income disabled veterans rehabilitate dilapidated buildings for use as residences.
HR 2264/S 2596. Signed onto a letter of support to go in base National Defense Authorization Act for 100% disabled veterans (who had not retired from military service) to receive space available (Space A) on military flights.
Liaised with numerous Congressional offices to inform them of the need to support HR 3229 Complex Rehabilitation Technology legislation.
HR 3471 Veterans Mobility Safety Act- this bill is to amend title 38, United States Code, to make certain improvements in the provision of automobiles and adaptive equipment by the Department of Veterans Affairs-Wrote letter in support of this legislation to Congresswoman Walorski.
Lobbied Congressional offices of the need to revamp VAs Vocational Rehabilitation and Employment Program (VR&E). The expectation is that by raising the disability rating qualification, the understaffed VR&E workforce can focus on those veterans most in need of services.
Signed onto a letter to Department of Labors Veterans Employment and Training Service to support its efforts to increase employment for veterans with disabilities.
HR 4683 Wrote a letter in support of HR 4683 Fairness for Veterans Act that provides for the reevaluation of discharges for veterans released under other than honorable conditions due to the effects of traumatic brain injury or post-traumatic stress.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Veterans Affairs - Dept of (VA), Labor - Dept of (DOL)
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 |
Ross |
Meglathery |
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Alexandra |
Bennewith |
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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 EDU
16. Specific lobbying issues
Wrote a letter to Secretary of the Department of Education for a federal student aid complaint and feedback system also known as Enterprise Complaint System (ECS).
Signed onto a letter to the Acting Secretary of Education regarding negotiation and arbitration for disputes with schools to allow a student to dispute via the Department of Veterans Affairs instead of through the schools own hired arbitrator.
Provided a response to the Department of Educations request for comments on the proposed Enterprise Complaint System. The Department of Educations proposed complaint tracking system accepts complaints about loans, other aid, and institutions participating in the Title IV program.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Education - Dept of
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 |
Ross |
Meglathery |
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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 TRA
16. Specific lobbying issues
Transportation Research Board (TRB) Annual Meeting
United Spinal attended the 2016 annual meeting of the TRB. United Spinal raised accessibility issues in workshops, and spoke with US Department of Transportation (USDOT) officials, and transit agency officials from Boston and Dallas, and national academics regarding taxis, equity and accessible TNCs.
United Spinal spoke with a convener appointed by the USDOT about the possibility of a negotiated regulations (Reg Neg) rulemaking for the Air Carrier Access Act. The Reg Neg process would pull together industry stakeholders and members of the disability community to discuss potential regulations regarding: accessible in-flight entertainment, access to in-flight medical oxygen, service animals, accessible lavatories on new single aisle aircraft, classes of service for purposes of seating accommodations, and airline reporting requirements.
United Spinal signed on to, and weighed in on, comments to the USDOT proposed Reg Negs drafted by PVA. The letter suggested that, should the USDOT choose to adopt a Reg Neg process through a committee, USDOT: ensure broad representation of the disability community on the committee and any working groups; ensure participation from the US Access Board on the committee so that they may share their technical expertise regarding accessibility standards; ensure that the framing of the discussions is geared towards prioritizing the civil rights of persons with disabilities. The letter also urged USDOT to consider that: there is a need to address current requirements for individuals who require emotional support and psychiatric service dogs; and to broaden the scope of passengers who must be afforded seats with extra leg room.
United Spinal participated in a discussion with the Amtrak Government Affairs and Engineering staff with other disability stakeholders on issues related to progress and plans towards compliance with the ADA.
Air Carrier Access Act update / Federal Aviation Administration (FAA) Reauthorization
By July 15th, Congress must reauthorize funding and establish priorities for the Federal Aviation Administration (FAA), which is tasked with ensuring safety across all aviation sectors and operating an efficient air traffic control system.
Action: A short term measure extending FAA programs until July 15, 2016 was enacted into law providing Congress time to work on a longer term reauthorization. United Spinal has been participating in a coalition of disability organizations to craft legislative language updating the provisions of the ACAA that could be included in a future long term FAA reauthorization. United Spinal signed onto a letter thanking the Senate Commerce Committee in appreciation of their efforts
17. House(s) of Congress and Federal agencies Check if None
AMTRAK - Natl Railroad Passenger Corporation, Transportation - Dept of (DOT), U.S. SENATE
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 |
Carol |
Tyson |
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Alexandra |
Bennewith |
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Kent |
Keyser |
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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 LBR
16. Specific lobbying issues
United Spinal and other disability stakeholders met with the White House to discuss employment issues for people with disabilities including disabled veterans from the AbilityOne program (alleged fraud related to the requirement that 75% of federal contractors employees must be people with significant disabilities is not being adhered to and the steering of contracts is also occurring) to hiring and recruitment of people with disabilities across the federal government.
United Spinal provided recommendations to DOL on the issue of federal regulations on the hiring and recruitment of people with disabilities across the federal government related to the release of contractor data on existing affirmative action plans, which has been a government recommendation since March 2014.
United Spinal met with the AbilityOne Commission to discuss the AbilityOne program which is established to hire and recruit individuals with disabilities.
17. House(s) of Congress and Federal agencies Check if None
White House Office, Labor - Dept of (DOL)
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 |
Alexandra |
Bennewith |
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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 MMM
16. Specific lobbying issues
Supports H.R. 1516/S. 1013 - Ensuring Access to Quality Complex Rehabilitation Technology Act of 2015 - Creates a separate benefit under Medicare for complex rehab technology.
Supports H.R. 3229/S. 2196 - This bill amends title XVIII (Medicare) of the Social Security Act to prohibit the application of Medicare competitive acquisition rates to complex rehabilitative wheelchairs and accessories. (A competitive bidding program has replaced the use of established fee schedule amounts to determine payments under Medicare for certain durable medical equipment such as wheelchairs.)
Supports S. 2425 - Patient Access and Medicare Protection Act - A bill to amend titles XVIII and XIX of the Social Security Act to improve payments for complex rehabilitation technology and certain radiation therapy services, to ensure flexibility in applying the hardship exception for meaningful use for the 2015 EHR reporting period for 2017 payment adjustments, and for other purposes.
Discussed with CMS, ACL and GAO concerns as it relates to access to durable medical equipment and complex rehab technology and accessories under Medicare's competitive acquisition program.
Discussed with CMS consumer access problems with Medicare's competitive bidding program.
United Spinal submitted comments to the Centers for Medicare and Medicaid Services regarding Medicaid access to covered services.
United Spinal signed onto a comment letter to entities in the Federally-Facilitated Marketplaces, seeking to offer qualified health plans (QHPs), including stand-alone dental plans (SADPs), in the Federally-facilitated Marketplaces (FFMs) or the Federally-facilitated Small Business Health Options Programs (FF-SHOPs) with operational and technical guidance for the disability population.
United Spinal opposes the provision in the FY2017 Presidential Budget to provide authority to expand competitive bidding for certain durable medical equipment specifically: ostomy and
urological supplies.
United Spinal commented to CMS on the issue of discharge planning for hospitals, critical access hospitals, and home health agencies. This proposed rule would revise the discharge planning requirements in order to participate in the Medicare and Medicaid programs.
United Spinal signed onto a letter to CMS opposing the same reimbursement to Medicare from skilled nursing facilities as well as in-patient rehab facilities and units (IRFs). United Spinal also edited and endorsed a letter from Congressman G. T. Thompson (R-PA) to the Centers for Medicare and Medicaid Services to urge Medicare Advantage plants to follow Medicare criteria Medicare IRF coverage criteria when determining coverage for IRF care.
United Spinal signed onto a comment letter to the Centers for Medicare and Medicaid Services (CMS) regarding the Summary of Benefits and Coverage, the Uniform Glossary of Medical Terms.
United Spinal signed onto a letter to MedPAC on Medicare Part D cost sharing for LIS and dual eligible beneficiaries. Generic Utilization is already high in both LIS and non-LIS populations and higher cost sharing for branded products could reduce adherence, increase spending on other health care services in Medicare/Medicaid.
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), Government Accountability Office (GAO), Medicare Payment Advisory Commission (MedPAC)
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 |
Alexandra |
Bennewith |
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Ross |
Meglathery |
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Kent |
Keyser |
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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 CIV
16. Specific lobbying issues
United Spinal supports S. 2427 - the Disability Integration Act.
United Spinal opposes ADA Notification bill, HR 3765.
Disability community stakeholders, including United Spinal Association, TASH, National Council on Independent Living and National Disability Rights Network met with the Civil Rights Division of the Department of Justice to discuss alleged fraudulent activity by the AbilityOne program and next steps related to the hiring, employing and recruiting of people with significant disabilities. The AbilityOne program provides employment opportunities to more than 45,000 people with significant disabilities including 3,000 veterans. The program is among the largest providers of jobs for individuals who are blind or who have significant disabilities.
United Spinal signed on to comments to the Administration on Community Living in response to their draft Adult Protective Services Consensus Guidelines. The comments suggested the rules clarify standards and accessibility requirements, make the client the center of decision making, ensure there are appropriate numbers of experienced caseworkers, and emphasize the importance of working with protection and advocacy and developmental disability agencies.
United Spinal signed on to a letter to Congress, opposing HR 2646, Helping Families in Mental Health Crisis Act of 2015.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Justice - Dept of (DOJ), 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 |
Alexandra |
Bennewith |
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Carol |
Tyson |
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Kent |
Keyser |
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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 DOC
16. Specific lobbying issues
United Spinal testified at a WMATA Accessibility Advisory Committee meeting and a WMATA Board meeting, sharing concerns regarding a proposal for Uber to provide alternative paratransit service.
United Spinal facilitated meetings, drafted a letter, and worked with labor and community advocates to submit a letter to the General Manager of WMATA ccing the Board) calling on WMATA to hold high standards for any alternative paratransit company. The letter calls on WMATA to ensure that any contracts awarded require: provision of wheelchair accessible service; prioritize working conditions of their drivers and other workers, and prioritize hiring of any MetroAccess workers displaced by the transfer of work to taxi or TNC-based paratransit programs; prioritize compliance, and accept their role as a transportation provider under the ADA; prioritize safety of the passengers and workers, and accept liability; prioritize accessibility through all of its business lines; and consider awarding the contract to more than one company so that local businesses can benefit and so there are back up companies if one is not able to meet the demand.
United Spinal organized and facilitated a meeting of the DCTC Accessibility Advisory Committee. The committee recommends, first and foremost, requiring Uber et al to provide accessible service.
United Spinal responded to District of Columbia Homeland Security and Emergency Management Agency (HSEMA) regarding accessibility concerns.
United Spinal participated in a meeting between disability advocate and paratransit riders with the DC Taxicab Commission Chairman, and the Directors of the District Departments of Transportation (DDOT) and Aging (DCOA). The meeting was scheduled in response to a sign-on letter organized by United Spinal and sent to the DC mayor. The letter expressed concerns regarding rumors of cuts to the accessible taxi program. The letter requested a meeting with the Mayor.
17. House(s) of Congress and Federal agencies Check if None
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 |
Carol |
Tyson |
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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 DEF
16. Specific lobbying issues
Wrote a letter to DOD to urge the department to designate $50,000,000 of Congressionally Directed Medical Research Program (CDMRP) funds to be directed towards arthritis study and treatment.
17. House(s) of Congress and Federal agencies Check if None
Defense - Dept of (DOD)
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 |
Ross |
Meglathery |
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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 INS
16. Specific lobbying issues
United Spinal supports Ensuring Access to Quality Representation for Social Security Disability Applicant - in a coalition letter to SSA expressing our support for raising the cap on fees that representatives can earn using the fee agreement when representing applicants for Social Security Disability benefits (Social Security Disability Insurance (SSDI) and Supplemental Security Income (SSI) programs) and for putting in place procedures to ensure more regular and consistent increases in this fee cap to keep pace with inflation moving forward.
Employee Retirement Income Security Act of 1974 (ERISA)
ERISA is a federal law that sets minimum standards for most voluntarily established pension and health plans in private industry to provide protection for individuals in these plans. United Spinal signed onto comments in response to regulations released by the Employee Benefits Security Administration to revise and strengthen the ERISA claims procedures for claimants for disability benefits under private insurance claims.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Social Security Administration (SSA)
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 |
Alexandra |
Bennewith |
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Kent |
Keyser |
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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 FIR
16. Specific lobbying issues
United Spinal signed onto a letter to Congress supporting HR 3516 which opposes President Obamas Executive actions and prohibits the Social Security Administrations (SSA) Representative Payee database to feed the names of people with psychiatric disabilities requesting assistance in managing their financial affairs into the National Instant Criminal Background Check system to prevent firearms purchases.
17. House(s) of Congress and Federal agencies Check if None
Social Security Administration (SSA)
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 |
Alexandra |
Bennewith |
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Kent |
Keyser |
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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 MAR
16. Specific lobbying issues
United Spinal took the lead on maintaining a requirement in current law, Section 609 of the Coast Guard Authorization Act of 2010 that the use of survival craft that do not keep all parts of the body out-of-the-water be phased out by 2015. Supporting 100% of passenger and crew members with out-of-water flotation equipment on passenger vessels is particularly important for people with disabilities, children, and older adults.
United Spinal corresponded with coalition allies and key congressional offices in support of maintaining the 2010 requirements. Congress passed a reauthorization bill that now only requires vessels built or converted after January 1, 2016 operating in cold water to provide out of water survival craft. Became Public Law 114-120 on February 8, 2016.
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 |
Kent |
Keyser |
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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 TEC
16. Specific lobbying issues
United Spinal signed on to a letter to the Federal Communications Commission, in support of the Lifeline Program which facilitates wider access to telecommunications services that are necessary for disabled Americans to stay connected and participate in society.
The wireless voice services provided by Lifeline have been critical in allowing Americans with disabilities to stay connected with their families, access health care services, seek employment and educational opportunities and to have the peace of mind to be able to call for help in emergencies.
Action: United Spinal signed onto a letter to the Federal Communications Commission not to adopt policies that would disenfranchise current Lifeline participants but instead allow current participants to choose between continuing to receive wireless voice service or to receive broadband instead. This position is consistent with both the position taken in the February 10 letter, to which United Spinal was a signatory and that of the Obama Administration in comments recently filed with the FCC on this matter by the National Telecommunications and Information Administration.
17. House(s) of Congress and Federal agencies Check if None
Federal Communications Commission (FCC)
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 |
Alexandra |
Bennewith |
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Kent |
Keyser |
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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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AFFILIATED ORGANIZATIONS
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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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