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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 25 Massachusetts Avenue, NW, Suite 700 |
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City | WASHINGTON |
State | DC |
Zip Code | 20001 |
Country | USA |
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5. Senate ID# 2002-12
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6. House ID# 321900000
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TYPE OF REPORT | 8. Year | 2018 |
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: Robert Doherty |
Date | 4/18/2018 8:56:23 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
Preserving Access to Primary Care Services: Address the shortage of primary care physicians; provide scholarships and loan forgiveness in exchange for primary care service commitments to practice in critical shortage areas; provide grants for medical school mentorship programs and primary care training in community health centers; increase Title VII funding for primary care health programs; increase funding for the National Health Service Corps, provide regulatory relief for primary care physicians; H.R. 7192/S. 1174, the Preserving Patient Access to Primary Care Act (as first introduced in the 111th Congress).
Support the Affordable Care Act (P.L. 111-148, P.L. 111-152) by: Expanding coverage and improving Medicare benefits; Providing needed protections to guard against insurance practices that unfairly limit, deny or rescind coverage based on health status; public and private health insurers should encourage preventive health care by providing full coverage, with no cost-sharing, for preventive services recommended by an expert advisory group, such as the U.S. Preventive Services Task Force; Ensuring access to primary care physicians; and beginning to bend the cost curve; Prohibiting insurers from excluding or charging excessive rates to children based on pre-existing conditions, which later will be expanded to all persons; Covering young adults on their parents' plans; Eliminating lifetime and annual limits on health insurance coverage; Requiring that health insurers spend more on patient care and less on administration; support enactment of S. 248, the Empowering States to Innovate Act, which amends the Patient Protection and Affordable Care Act (ACA) to: (1) allow states to apply for waivers of certain health insurance coverage requirements in such Act (including requirements for the establishment of qualified health plans and health insurance exchanges) for plan years beginning on or after January 1, 2014 (currently, January 1, 2017), and (2) require the waiver application process to begin not later than 180 days after the enactment of this Act; Phasing out the Medicare Part D doughnut hole; Eliminating patient cost-sharing for preventive services offered by Medicare or private insurers; Increasing Medicare and Medicaid payments to primary care physicians; Supporting the Patient-Centered Outcomes Research Institute to help physicians and patients make care decisions based on the best available evidence; Supporting the Center on Medicare and Medicaid Innovation to fund pilots of delivery models to improve outcomes and reduce costs, including patient-centered medical homes; Training more primary care physicians through the National Health Service Corps, Title VII health professions funding, and redistributing unused graduate medical education positions to primary care specialties facing shortages; Beginning in 2014, ensuring that nearly all Americans have access to coverage either through subsidized private health insurance offered by state health exchanges or through Medicaid, if they don't already have access to coverage through an employer, Medicare, or another public program; voiced strong opposition to the American Health Care Act/Better Care Reconciliation Act/Graham-Cassidy proposal because these bills would cap the federal contribution to Medicaid or block grant the program, end support for Medicaid expansion, allow state waivers to eliminate essential evidence-based benefits, cut funding for opioid use treatment, restrict access to womens health services, and replace the Affordable Care Acts income-based premium and cost-saving subsidies with regressive age-based ones that will raise premiums and deductibles for most Americans, especially, for older, poorer and sicker patients.
Medicare Physician Payment Reform: Advocated in support of H.R. 2, the Medicare Access and CHIP Reauthorization Act (MACRA), which was enacted in April 2015 and repealed Medicares Sustainable Growth Rate (SGR) formula and moved us to a new value-based payment and delivery system under Medicare; Advocated with CMS on numerous aspects of the MACRA proposed and final rules, including: proposing a distinctive alternative scoring methodology, developed by ACP, which combines, simplifies, aligns and reduces the complexity of the four reporting categories that will qualify physicians for FFS payment adjustments in 2019; proposing specific alternatives to CMS Advancing Care Information program that is to replace the current Meaningful Use program; proposing additional improvements to simplify the reporting requirements for the Quality, Advancing Care Information and Clinical Practice Improvement categories; urging CMS to immediately create virtual reporting options and to create safe harbors for smaller practices until such options are available; proposing more options and flexibility, instead of a one-size fits all approach, for practices to be certified as Patient-Centered Medical Homes or Patient-Centered Medical Home specialty practices, qualifying them for the highest possible score for the Clinical Practice Improvement Activity reporting category; Proposing four different options for Medical Home practices to qualify as advanced Alternative Payment Models, instead of the single option proposed by CMS, including options to allow PCMHs to qualify without taking financial risk: Advocated with CMS on Patient Relationship Categories and Codes, as required by MACRA, specifically: that CMS work to ensure that patients, families, and the relationship of patients and families with their physicians are at the forefront of the Agencys thinking in the development of both the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) pathways; that the implementation of these categories and codes is carried out in a manner that fully considers and minimizes the impact of reporting burden on the participating clinicians and that has appropriate flexibility to allow for learning and improvement in the approach by both the Agency and the clinicians; that CMS use its authority to adjust resource use down from 10 percent in the first performance period by setting resource use at zero and increasing the quality performance category by 10 percent to make up for the difference; that CMS ensures the utmost transparency in how the Agency attributes cost, based on the use of the patient relationship categories and codes, along with the codes for care episodes and patient conditions; that CMS allow all Accountable Care Organizations (ACOs) to be eligible to participate in Track 1+ and to not restrict participation based on ACO size or composition (ex. only physician-led ACOs or small ACOs); that CMS allow current ACOs to move into Track 1+ at the start of any performance year and not be required to wait until the beginning of their next three-year agreement period; that Track 1+ utilize the same benchmarking methodology used for the other MSSP tracks; that CMS implement a minimum threshold of 5,000 beneficiaries for Track 1+, which is consistent with the other MSSP tracks but is lower than the 10,000 (or 7,500 for rural ACOs) beneficiary threshold used in the Next Generation ACO model.
Medical Education: Provide incentives to medical schools, community health centers, or hospitals, to increase the numbers of physicians choosing primary care; authorize HHS to selectively eliminate Graduate Medical Education (GME) caps for residency programs in primary care, advocated for S. 1627, which would increase the number of Medicare-supported training positions for medical residents by 15 percent (approximately 15,000 slots) over five years, requiring at least 50 percent of the new positions to be allocated to specialties facing a current shortage; Urged lawmakers to combine DGME and IME into a single, more functional payment program, and broaden the GME financing structure to include all payers; Allocate GME funds transparently and specifically to activities that further the educational mission of teaching and training residents and fellows with input from practicing clinicians and in collaboration with their professional organizations
FY2018 Appropriations: Supported funding to "improve health care quality, enhance consumer choice, advance patient safety, improve efficiency, reduce medical errors, and broaden access to essential services; Advocated for funding for AHRQ and Patient Centered Outcome Research Trust Fund, the Health Resources and Services Administration (HRSA); Title VII, Section 747, Primary Care Training and Enhancement; National Health Service Corps. Also, advocated for the reauthorization of critical workforce programs that expired on Sept. 30, 2017 including, Community Health Centers, the Teaching Health Center Graduate Medical Education program, the National Health Services Corps, and expired on Dec. 8th, the Title VII Health Professions programs; Advocated for raising the budget caps equally on defense and non-defense discretionary spending; Restore $40 million in unobligated funds for the National Quality Forum plus $7.5 million in funding for the next two fiscal years.
Public Health Programs and Funding: Increase funding to accomplish the core missions and activities of the major federal public health agencies, including: biomedical and behavioral research, disease prevention and health promotion, access to safety net health care services, health professions education, mental health and substance abuse, health services research, food and drug safety.
Improving Access to Primary Care in the Context of Comprehensive Healthcare Reform Legislation (H.R. 3962/H.R. 3590/H.R. 4872):
Ensure that all Americans will have access to affordable coverage.
Provide sliding scale subsidies based on income to buy coverage from qualified plans; Qualified plans should: provide evidence-based benefits, including preventive services; and be prohibited from excluding persons with pre-existing conditions, charging them more, cherry-picking enrollees, or cancelling or failing to renew coverage; Expand Medicaid to cover all persons below the Federal Poverty Level and ensure fair payments to participating physicians; As coverage becomes affordable, all persons should participate and coverage should be guaranteed; Responsibility for financing should be shared by individuals, employers and government. Regarding the Essential Health Benefits Bulletin, issued by the Department of Health and Human Services (HHS) on December 16, 2011, the College advocated for striking a balance between comprehensiveness and affordability while giving States some freedom to determine a package that best serve the needs of residents. The College believes that strong oversight is needed when determining the initial benchmark plan (and whether it reflects the coverage requirements of the Affordable Care Act) and how the package will be updated, particularly if insurers are given the ability to substitute benefits within and across categories. State and the federal government must work in concert with physicians, health care providers and payers to determine and promote use of clinically effective and cost-effective services that result in improved patient health while bending the cost curve. Under the Affordable Care Act, advocated to ensure that people residing in states with health insurance marketplaces operated by the federal government do not lose their cost-sharing reduction subsidies (CSRs) and that those CSRs should be continued indefinitely as part of a larger bipartisan effort to stabilize the individual insurance market.
Pilot test Medicare payment models that re-align incentives to support effective, efficient, patient-centered, coordinated care. Priority should be given to models designed to support the value of services provided by primary care physicians as well as to models that would create incentives, across physician specialties and sites of services, to improve the quality, effectiveness, and efficiency of care provided. Policy criteria for selecting the most promising models for pilot testing should be developed, in consultation with outside experts; The Patient-Centered Medical Home (PCMH), which has shown great promise in meeting the policy objectives suggested above, should be among the models selected for broader testing on a national pilot basis; the establishing of a new CMS Innovation Center to pilot-test new payment models, such as the medical home; the use of the medical home model for treatment or services under private health plans, the requirement of health plans to provide incentives to promote and report on medical home services provided, the establishment of community health teams and a primary care extension program to educate and support primary care practices in the delivery of medical home services, and the establishment of a demonstration project to educate physicians and other clinicians in training in the competencies required to deliver care consistent with the medical home care model.
Reducing Administrative Burdens on Physicians: Urged Congress to reduce administrative tasks that negatively impact physicians and patients, including: 1) Encourage the administration to convene a multi-agency task force to identify tasks that could be streamlined or eliminated, based on a new comprehensive framework to assess the intent and impact of administrative tasks on care as proposed in ACPs policy paper, Putting Patients First by Reducing Administrative Tasks in Health Care. Establish a process to require that CMS and other relevant federal agencies reexamine and replace the existing E/M documentation guidelines with input from practicing clinicians and their professional organizations, 3) Call on federal advisory bodies, such as the Medicare Payment Advisory Commission (MedPAC), to research the effect of administrative tasks on patient and family care experience and outcomes, 4) Facilitate congressional hearings among government, clinician stakeholders, EHR vendors and suppliers to foster collaboration between parties to recognize their role and responsibility in reducing health IT administrative burdens.
Opioid Abuse: ACP supports efforts in trying to improve access to care and treatment for those suffering from mental health and substance abuse disorders. As contained in S. 2256, Co-Prescribing Saves Lives Act of 2015, ACP supports a comprehensive national policy on prescription drug abuse containing education, monitoring, proper disposal, and enforcement elements. As contained in S. 2256, Co-Prescribing Saves Lives Act of 2015, ACP is supportive of expanding access to naloxone within the community. ACP also supports the policy proposal known as partial-fill. This would allow a patient to elect to receive a portion of a prescription, and return for either a portion of, or the remainder of the prescription, if the pain persists, up to a 30-day maximum. Urged lawmakers to include language in the final House opioids legislative package to ensure healthcare providers who are engaged in population health initiatives have access to the medical records they need, including information on substance use disorders, to effectively and safely treat their patients; Urged lawmakers to reach agreement on a final conference report to the Comprehensive Addiction and Recovery Act (CARA) that would include: Development of a federal interagency task force to review, modify, and update, as appropriate, best practices for pain management and prescribing pain medication; Grants to states to expand awareness and education of physicians, patients, health care providers regarding the risks associated with the misuse of opioids; A comprehensive Prescription Drug Monitoring Program (PDMP) to track the dispensing of controlled substances; Increased availability of opioid overdose reversal drugs; Alternatives to incarceration to individuals who misuse opioid drugs and other substances to manage their pain. The College was also encourage by Administrations Opioid Commission report, released in November, that emphasizes the need to expand access to substance use disorder treatment, for which there is a massive demand in many parts of the country.
Chronic Care Management: Urged lawmakers to eliminate the beneficiary co-pay for chronic care management (CCM) services, require reimbursement and coverage of additional codes for more complex CCM services, direct HHS to authorize payment for CCM codes to allow physicians to spend up to 40 minutes with a patient and an additional code that would allow for 60 minutes of treatment for a patient with multiple chronic illnesses; Advocated for passage of The Creating High-Quality Results and Outcomes Necessary to Improve Chronic (CHRONIC) Care Act, S. 870, which would expand the use of tele-health for individuals with stroke, provide flexibility for Medicare beneficiaries to be part of an Accountable Care Organization, extend the Independence at Home model of care.
Childrens Health: Advocated for a 5-year extension of the Childrens Health Insurance Program (CHIP), which expired on Sept. 30, 2017, on the basis of it serving as the key health insurance safety net program for children of low-income families.
Insurance Market Stabilization: Advocated with Congress on the need to stabilize the health insurance market, including the need to fund cost-sharing reduction (CSRs) payments for the long-term; Urged enactment of legislation, built around robust federal funding for reinsurance that is adequate to ensure stability, encourage competition and lower costs for consumers while maintaining the core consumer protections in current federal statute. Reinsurance provisions of this legislation should be structured in a manner to bring relief to consumers in every state. To assure its sustainability, any legislative solution must be bipartisan.
Immigration: Voiced support to Congress on the need to pass the Development, Relief, and Education for Alien Minors (DREAM) Act of 2017, H.R. 3440. This legislation would establish a three-step pathway to U.S. citizenship through college, work, or the armed services for individuals who were born in another country and brought illegally to the U.S. at a young age (DREAMers).
Clinical Labs: Commented to the Centers for Medicare and Medicaid Services (CMS) on issues pertaining to the Protecting Access to Medicare Act of 2014 (PAMA), specifically citing concerns about the potential impacts of PAMA on patient access to critical rapid clinical testing services offered to patients while they are receiving medical care in their physicians office; expressed further concerns about impending cuts on Jan. 1, 2018 for physician office-based testing services.
Medicare Physician Fee Schedule: Commented to CMS on the CY2018 proposed and final rules on the Physician Fee Schedule, including: any revisions made to the E/M documentation guidelines should not result in a revaluation of the entire E/M code set; all relevant stakeholders, including medical specialty organizations, should work with both the Current Procedural Terminology (CPT) Editorial Panel and CMS to create frameworks outlining general principles of care that are beneficial and appropriate for medical specialties in describing the varying approaches to patient care for the current levels of E/M codes; CMS should simplify the documentation requirements necessary to bill CCM services in order to ease the burden of documenting each separate minute of care management over the course of the month; CMS should modify the existing PAMA regulations through issuance of an interim final rule that provides for CMS to conduct targeted market segment surveys (reference laboratories, physician office-base laboratories, independent laboratories, and hospital outreach laboratories) to validate and adjust the final amount calculated based on the data collection to ensure Congressional intent-payment rates that accurately reflect private market payments across all market segments-is achieved; CMS should provide relief from penalties associated with the Medicare EHR Incentive Program (Meaningful Use) for the 2016 performance period for ECs who tried but were unsuccessful at reporting MU.
Medicare Access and CHIP Reauthorization Act (MACRA): Called on CMS to: work to ensure that patients, families, and the relationship of patients and families with their physicians are at the forefront of the agencys thinking in the development of both the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APM) pathways, including the development and implementation of the performance measures to be used within these programs; to reduce administrative tasks and burdens on physicians; collaborate with specialty societies, frontline clinicians, patients, and electronic health record (EHR) vendors in the development, testing, and implementation of measures with a focus on integrating the measurement of and reporting on performance with quality improvement and care delivery and decreasing clinician burden. Urged Congress to: continue the existing flexibility in the MACRA statute that CMS is currently using for an additional three years so that the agency may move forward as the necessary program elements are put in place; clarify that Medicare Part B drugs and other items and services outside the physician fee schedule are not included in the application of MIPS payment adjustments and determination of MIPS eligibility; rationalize what is considered a small practice; and explicitly authorize the Physician-focused Payment Model Technical Advisory Committee (PTAC) to provide technical assistance to developers of Advanced Payment Models.
State Medicaid Waivers: The College commented to CMS on the Arizona Health Care Cost Containment System (AHCCCS) 1115 Waiver amendment request opposing the request for a 5-year maximum lifetime limit on coverage for certain enrollees. Placing an arbitrary limit on enrollment could disrupt continuity of care and undermine the patient-physician relationship. Patients with chronic conditions may need ongoing care management from their physician and health care team. Abruptly ending a patients medical assistance after 5 years could sever a patients link to their care team and threaten progress. The College also commented to CMS on the KanCare 2.0 State Extension Application opposing the 36-month limit on KanCare 2.0 coverage. This proposal would greatly harm patients with complex chronic care needs, including patients with diabetes, obesity, cardiovascular disease, and asthma, who require ongoing care management. The College also commented to CMS on the New Mexico Centennial Care 2017 Extension Application expressing concerns that the states proposal to implement premiums and cost sharing for the Other Adult Group expansion population with household income that exceeds 100% FPL will undermine access to care. The proposal would impose monthly premiums of $10 in 2019 and provide the state the option of raising the premium to $20 a month in subsequent years. The College believes that Medicaid premiums and cost-sharing should be structured in a way that does not discourage enrollment or cause enrollees to disenroll or delay or forgo care due to cost, especially those with chronic disease.
Firearms: The College urged Congress to: Reject any consideration of the Concealed Carry Reciprocity Act (H.R. 38) as passed by the House in December, 2017; Pass S. 2095, the Assault Weapons Ban of 2017, which would place bans on the sale of high-velocity, rapid-fire assault rifles (rifles specifically designed to inflict lethal harm to as many victims as possible, in as little time as possible), large capacity ammunition magazines and bump stocks; Pass S. 2135, the Fix NICS Act, which would strengthen the criminal background check system to help ensure that criminals and domestic abusers are prevented from obtaining firearms; Enact strong penalties for persons who unlawfully purchase firearms for other persons who are in a prohibited category-known as straw purchasers; Repeal the Dickey amendment, which limits the ability of the Centers for Disease Control and Prevention, the National Institutes of Health, and the National Institute of Justice, to study the effect of violence and unintentional firearms-related injury on public health and safety, and to eliminate any language in appropriations bills for these agencies that would preclude them from conducting such studies.
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), President of the U.S.
18. Name of each individual who acted as a lobbyist in this issue area
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Crowley |
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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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ISSUE UPDATE
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AFFILIATED ORGANIZATIONS
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
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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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