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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)
City | WASHINGTON |
State | DC |
Zip Code | 20005 |
Country | USA |
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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 | 2023 |
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. | ||||||||
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: Jill H. Randolph |
Date | 4/20/2023 11:20:36 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 RET
16. Specific lobbying issues
Legislative
Consolidated Appropriations Act of 2023 CAA) - Public Law 117-328 (H.R. 2617) - SECURE 2.0 - technical corrections
FY 2024 Budget Proposal - cap on retirement assets, other retirement and compensation provisions, employee misclassification and tax policy
Congressional Review Act (CRA) resolution - proposed repeal of the Administrations environmental, social and corporate governance (ESG) factors when selecting investment options
Womens Retirement Protection Act (WRPA) - S. 2446/H.R. 4678 (117th Congress)
Hard Stop Rule affecting retirement plans - proposed Securities and Exchange Commission (SEC) rule
Cybersecurity
Fiduciary investment responsibilities, including ESG, cryptocurrency, and brokerage windows
Defined Benefit Plan (DB) Issues
Electronic communication
ERISA Uniformity
Pooled Employer Plan (PEPs) Issues
Retirement plan access
Tax Incentives for 401 (k) contributions
403(b) plan access to investments such as Collective Investment Trust (CIT) and separate accounts
Regulatory
Department of Labor (DOL)/Department of Treasury (Treasury) /Internal Revenue Service (IRS) - Consolidated Appropriations Act of 2023 CAA) - Public Law 117-328 (H.R. 2617) - SECURE 2.0 - priority guidance, technical corrections and implementation issues
White House - Public Health Emergency (PHE) and National Emergency (NE) to end May 11, 2023 - relief extending certain participant and plan deadlines related to COVID-19
Treasury/Internal Revenue Service (IRS) - delay of Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019 plan amendment
DOL - proposed amendment to QPAM exemption affecting investment managers - Prohibited Transaction Exemption
DOL - proposed changes to retirement plan prohibited transaction exemption (PTEs) - proposed rule
Securities and Exchange Commission (SEC) - proposed Hard Stop rule affecting retirement plans; and request for extension to comment period
DOL/EBSA - proposed expansion of benefit plan self-correction processes (EBSAs Voluntary Fiduciary Correction Program (VFCP)
Internal Revenue Service (IRS) - Notice 2023-23, providing reporting relief for required minimum distributions (RMDs) for IRAs in 2023
DOL/EBSA- Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder rights - final regulations addressing Environmental, Social and Governance (ESG) investment strategies for retirement plans
Federal Trade Commission (FTC) - proposal on noncompete agreements
DOL - Proposed regulation - New Independent Contractor Regulations
DOL - comment letter outlining concerns with the Departments collection of personal identifiable information (PII)
Treasury, IRS - comment letter outlining key issues regarding forthcoming guidance for frozen defined benefit plans
White House Executive Order on Climate-Related Financial Risk
DOL - Request for Information (RFI) - Possible Agency Actions on Climate-Related Financial Risk
White House Executive Order - Ensuring Responsible Development of Digital Assets
DOL - sub-regulatory guidance - reduction of cybersecurity risks for retirement plan sponsors
DOL/Treasury/IRS/PBGC - Final Revisions to 2023 Form 5500 Reporting requirements
PBGC/IRS - Missing Participants - request for clarifying guidance on missing participant benefits
DOL - best practices for missing participants
Treasury/IRS - safe harbor correction method for automatic contribution arrangements
IRS -Employee Plans Compliance Resolution System (EPCRS)
Treasury/IRS - Pooled Employer Plans (PEPs) and Multiple Employer Plans (MEPs) - immediate guidance needed under SECURE 2.0
DOL/Treasury/IRS - Pooled Employer Plans (PEPs) and Multiple Employer Plans (MEPs) - comments on registration requirements, service crediting guidance and other issues
Treasury/IRS - Proposed Regulation - Providing an exception to the Unified Plan Rule for certain Multiple Employer Plans (One-Bad-Apple Rule)
DOL (EBSA) - investment advice guidance and related prohibited transaction exemptions
Treasury/IRS - proposed regulations for permanent extension - remote notarization for spousal consent
DOL - Interim Final Rule on Lifetime Income Illustration Requirements - temporary frequently asked questions (FAQs) - timing clarification
DOL - defined benefit plans - annuity purchases
DOL - redefinition of fiduciary
Emergency savings
Executive compensation
ERISA Uniformity
State retirement plan initiatives
IRS Tax Forms W4-P and W4-R - Effective date of the revised 2022 tax forms postponed until 2023
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), White House Office, Office of Management & Budget (OMB), Securities & Exchange Commission (SEC), Federal Trade Commission (FTC)
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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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
Priorities - preserve and strengthen employer-provided health coverage, lower cost and improve value; leverage telehealth to improve access and value, and combat the mental health crisis
FY 2024 Budget Proposal - mental health, prescription drug pricing, paid family leave and pandemic preparedness
Mental Health Matters Act - (H.R. 7780) (117th Congress)
Health Network and Directory Improvement Act
Healthcare Workforce Shortage - request for information (RFI), Senate Health, Education, Labor and Pensions (HELP) Committee
Healthy Competition for Better Care Act - S. 3139 (117th Congress)
Telehealth Expansion Act - S, 1001/H.R. 1843
HSA Telehealth Extension
Telehealth Benefit Expansion for Workers Act - H.R. 824
Employer-sponsored health coverage
Site-Neutral Payment Reform
Hospital Billing Practices
Mental health parity
Health cost transparency
PBM Transparency and Oversight legislation
Dependent Care Flexible Spending Accounts (FSAs)
Health Flexible Spending Accounts (FSAs)
Health Savings Accounts (HSAs)
Chronic Disease Management
Prescription drug legislation
Surprise billing regulations
Health Equity
Regulatory
White House - Public Health Emergency (PHE) and National Emergency (NE) ending May 11, 2023
Department of Health (HHS), Department of Labor (Labor) and Department of Treasury (Treasury) - (the tri-agencies) - request for guidance on end of COVID-19 Public Health Emergency (PHE) and National Emergency (NE)
Centers for Medicare and Medicaid Services (CMS) - comment letter underscoring importance of Medicare Advantage to employers and comments on 2024 rate notice
HHS and CMS - request for information (RFI) - current essential health benefits guidance
HHS, Labor and Treasury(the tri-agencies) - guidance on group health plan attestations to Gag clause prohibition
HHS, Labor and Treasury(the tri-agencies) - clarification of air ambulance reporting deadline for group health plans
HHS, Labor and Treasury(the tri-agencies) prescription drug and health care cost reporting
HHS, Labor and Treasury (the tri-agencies) - final surprise billing regulations on the independent dispute resolution (IDR) process
HHS, Labor and Treasury (the tri-agencies) - request for information (RFI) - advanced explanation of benefits
Treasury/IRS -Pre-Deductible Telehealth Care in High Deductible Health Plans
HHS, Labor and Treasury (the tri-agencies) Mental health parity requirements for group health plans and insurers, including under the CAA
HHS, Labor and Treasury (tri-agencies) - transparency provisions under the CAA
HHS - Enforcement of Hospital Price Transparency Rules
Treasury/IRS - request for guidance on repurposing of welfare benefit fund assets
ERISA uniformity
High Deductible Health Plans (HDHPs)
Health Savings Accounts (HSAs)
State health care requirements affecting self-insured plans
Abortion coverage and travel benefits in health plans
Employer mandate
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), Office of Management & Budget (OMB), Federal Trade Commission (FTC), Justice - Dept of (DOJ)
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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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) |