Rural Hospital Fairness Act of 2013

Medicare Audit Improvement Act of 2013 (H.R. 1250) Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) Protecting Seniors Access to Medicare Act of 2013 (H.R. 351 and S. 351) The DSH Reduction Relief Act of 2013 (H.R. 1920) Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Medicare physician fee schedule fix Structural changes to Medicare - combining Parts A and B Severe sepsis protocols Federal Housing Administrations Hospital Mortgage Insurance Program (242) Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, incl. Grad. Medical Education

Client expense: Not reported · Firm income: Not reported

Medicare Audit Improvement Act of 2013 (H.R. 1250) Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) Protecting Seniors Access to Medicare Act of 2013 (H.R. 351 and S. 351) The DSH Reduction Relief Act of 2013 (H.R. 1920) Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Medicare physician fee schedule fix Structural changes to Medicare - combining Parts A and B Severe sepsis protocols Federal Housing Administrations Hospital Mortgage Insurance Program (242) Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, incl. Grad. Medical Education

Client expense: Not reported · Firm income: Not reported

Submitted comments on the Hatch Entitlement Reform in support of the several key reforms proposed for the Medicare program as alternative reductions to provider payments; Support S 351 Protecting Seniors Access to Medicare Act, a bill to repeal the provisions of the Patient Protection and Affordable Care Act providing for the Independent Payment Advisory Board; Support HR 297 and S1557, Children's Hospital GME Support Reauthorization Act of 2013, the bill would reauthorize the CHGME program for an additional five years through fiscal year (FY) 2017; Support HR 1250 and S 1012 Medicare Audit Improvement Act of 2013, a bill to amend title XVIII of the Social Security Act to improve operations of recovery auditors under the Medicare integrity program, to increase transparency and accuracy in audits conducted by contractors; Support S. 596 Fostering Independence Through Technology Act of 2014, a bill to establish pilot projects under the Medicare program to provide incentives for home health agencies to furnish remote patient monitoring services that reduce expenditures under such program; Support HR 1787 and S 842 Rural Hospital Access Act of 2013, a bill to amend title XVIII of the Social Security Act to provide for an extension of the Medicare-dependent hospital (MDH) program and the increased payments under the Medicare low-volume hospital program; Support HR 1920 and S 1555 DSH Reduction Relief Act of 2013, a bill to amend titles XVIII and XIX of the Social Security Act to provide for a delay in the implementation schedule of the reductions in disproportionate share hospital payments;AHA submitted a statement to the Presidents and Other Bipartisan Proposals to Reform Medicare Post-Acute Care Payments hearing to provide input on proposals to reform Medicares post-acute care payment systems; AHA submitted a statement to the Program Integrity: Oversight of Recovery Audit Contractors hearing supporting increased oversight of Recovery Audit Contractors (RACs); Support HR 2578 Rural Hospital Fairness Act of 2013, a bill to amend title XVIII of the Social Security Act to extend for one year the hold harmless provision for small rural hospitals and sole community hospitals under the Medicare prospective payment system for hospital outpatient department services related to enhanced physician supervision requirements; AHA submitted a statement to the Health Care Quality: The Path Forward hearing in support of improving transparency for the public, continuing and enhancing support of efforts to improve the safety and quality of the care delivered,and reduce unnecessary hospital expenditures; Support HR 2931 Fairness in Health Care Claims, Guidance and Investigations Act, a bill to amend the false claims provisions of title 31, United States Code, with respect to health care programs; Request additional guidance on and delay of two-midnight rule from CMS; Request issue corrected data on OPPS proposed rule and delay comment period from CMS; Discussion of ACAs patient safety evaluation system with CMS; Discussed the improvements to the National Practitioner Data Bank and new compliance efforts at HRSA; Discussions of Medicaid presumptive eligibility; Medicaid DSH; and request release of DSH audit rule with CMS; Follow up on GPO exclusion related to 340(b) entities; discussions to help shape upcoming proposed rule on 340B with HRSA; Discussed the Qualified Health Plans (QHP) 90day grace period with HHS and its implications for hospitals; Support HJ Res 59, a continuing Appropriations Resolution for 2014, which includes a provision that averts Medicare physician payment cuts as Congress continues to work on a replacement of the flawed SGR formula; Support HR 3444 Critical Access Hospital Flexibility Act of 2013, to amend title XVIII of the Social Security Act to provide flexibility in the manner in which beds are counted for purposes of determining whether a hospital may be designated as a critical access hospital under the Medicare program; Support H.R.3698 and S. 2037 Two-Midnight Rule Delay Act of 2013, to delay the enforcement of the Medicare two-midnight rule for short inpatient hospital stays until the implementation of a new Medicare payment methodology for short inpatient hospital stays; Requested CMS and ONC to extend the EHR Incentive program regulatory timelines for 2014 and allow all providers greater flexibility in Stage 2 by giving all hospitals the option to make the transition to the 2014 Edition Certified EHR and the Stage 2 requirements (or the revised Stage 1 requirements, as applicable) over the course of 2014 or 2015; Support HR 3991 and S 2037 Critical Access Hospital Relief Act of 2014, amends title XVIII (Medicare) of the Social Security Act to repeal the 96-hour physician certification requirement for inpatient critical access hospital services under which a physician must certify that a patient may reasonably be expected to be discharged or transferred to a hospital within 96 hours after admission to the critical access hospital; Support HR 4188 Establishing Beneficiary Equity in the Hospital Readmission Program Act, to amend title XVIII of the Social Security Act to adjust the Medicare hospital readmission reduction program to respond to patient disparities; Support H.R. 2801 and S1143 Protecting Access to Rural Therapy Services (PARTS) Act of 2013, a bill to adopt a default standard of general supervision for outpatient therapeutic services, develop a reasonable exceptions process with provider input to identify specific procedures that require direct supervision, ensure that, for CAHs, the definition of direct supervision is consistent with the CAH conditions of participation that allow a physician or NPP to present within 30 minutes of being called and prohibit enforcement of CMSs retroactive reinterpretation that the direct supervision requirements applied to services furnished since January 1, 2001; S.1932/H.R. 3890 Better Care, Lower Cost Act , AHA has not taken position on the bill, but did establish an AHA working group to analyze the legislation to amend title XVIII of the Social Security Act to establish a Medicare Better Care Program to provide integrated care for Medicare beneficiaries with chronic conditions; requested that the increasing number of hospital compliance reviews performed by the Office of Inspector General (OIG) Office of Audit Services in which the OIG has extrapolated audit findings to estimate Medicare overpayments to the hospitals and the hospitals Medicare Administrative Contractors (MACs)have sought to recover the extrapolated overpayment amounts be halted without delay; Support HR 5481, The Flexibility in Health IT Reporting (Flex-It) Act, a bill to continue the use of a 3-month quarter EHR reporting period for health care providers to demonstrate meaningful use for 2015 under the Medicare and Medicaid EHR incentive payment programs. Senate briefing on legal barriers to providers' ability to manage risk, particularly with respect to Medicare ACO programs. Support HR 4656 and S2276, Caring for America's Heroes Act, a bill to improve access to mental health services under the TRICARE program; Funding for Ebola treatment and preparedness as part of the FY15 Omnibus Appropriations Act. Met to discuss the HHS calculator issue to ensure employers cannot offer health plans that exclude inpatient hospital care.

H.R. 83: Consolidated and Further Continuing Appropriations Act, 2015 (H.R. 83) Funding for Ebola preparedness and treatment Medicare Audit Improvement Act of 2013 (H.R. 1250) Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) Protecting Seniors Access to Medicare Act of 2013 (H.R. 351 and S. 351) The DSH Reduction Relief Act of 2013 (H.R. 1920) Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Two Midnight Rule Delay Act (H.R. 3698)/Two-Midnight Rule Coordination and Improvement Act of 2014 (S. 2082) Establishing Beneficiary Equity in the Hospital Readmission Program Act (H.R. 4188)/ Hospital Readmissions Program Accuracy and Accountability Act of 2014 (S. 2501) Craig Thomas Rural Hospital and Provider Equity Act (S. 2359) Flexibility in Health IT Reporting Act (HR 5481) Making the Education of Nurses Dependable for Schools (MEND) Act (H.R. 5227) Medicare physician fee schedule fix Severe sepsis protocols Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, Disproportionate Share Hospital (DSH) Payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, hospital outpatient department (HOPD) evaluation and management (E/M) services, and sequestration. Medicare and Medicaid Electronic Health Record Incentive Payment Programs Medicaid, New York State Medicaid Vital Access Provider Program Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) - Two-Midnight Policy FFY 2015 Inpatient Prospective Payment System Proposed Rule (CMS-1607-P) - Two-Midnight Policy

Submitted comments on the Hatch Entitlement Reform in support of the several key reforms proposed for the Medicare program as alternative reductions to provider payments; Support S 351 Protecting Seniors Access to Medicare Act, a bill to repeal the provisions of the Patient Protection and Affordable Care Act providing for the Independent Payment Advisory Board; Support HR 297 and S1557, Children's Hospital GME Support Reauthorization Act of 2013, the bill would reauthorize the CHGME program for an additional five years through fiscal year (FY) 2017; Support HR 1250 and S 1012 Medicare Audit Improvement Act of 2013, a bill to amend title XVIII of the Social Security Act to improve operations of recovery auditors under the Medicare integrity program, to increase transparency and accuracy in audits conducted by contractors; Support S. 596 Fostering Independence Through Technology Act of 2014, a bill to establish pilot projects under the Medicare program to provide incentives for home health agencies to furnish remote patient monitoring services that reduce expenditures under such program; Support HR 1787 and S 842 Rural Hospital Access Act of 2013, a bill to amend title XVIII of the Social Security Act to provide for an extension of the Medicare-dependent hospital (MDH) program and the increased payments under the Medicare low-volume hospital program; Support HR 1920 and S 1555 DSH Reduction Relief Act of 2013, a bill to amend titles XVIII and XIX of the Social Security Act to provide for a delay in the implementation schedule of the reductions in disproportionate share hospital payments;AHA submitted a statement to the Presidents and Other Bipartisan Proposals to Reform Medicare Post-Acute Care Payments hearing to provide input on proposals to reform Medicares post-acute care payment systems; AHA submitted a statement to the Program Integrity: Oversight of Recovery Audit Contractors hearing supporting increased oversight of Recovery Audit Contractors (RACs); Support HR 2578 Rural Hospital Fairness Act of 2013, a bill to amend title XVIII of the Social Security Act to extend for one year the hold harmless provision for small rural hospitals and sole community hospitals under the Medicare prospective payment system for hospital outpatient department services related to enhanced physician supervision requirements; AHA submitted a statement to the Health Care Quality: The Path Forward hearing in support of improving transparency for the public, continuing and enhancing support of efforts to improve the safety and quality of the care delivered,and reduce unnecessary hospital expenditures; Support HR 2931 Fairness in Health Care Claims, Guidance and Investigations Act, a bill to amend the false claims provisions of title 31, United States Code, with respect to health care programs; Request additional guidance on and delay of two-midnight rule from CMS; Request issue corrected data on OPPS proposed rule and delay comment period from CMS; Discussion of ACAs patient safety evaluation system with CMS; Discussed the improvements to the National Practitioner Data Bank and new compliance efforts at HRSA; Discussions of Medicaid presumptive eligibility; Medicaid DSH; and request release of DSH audit rule with CMS; Follow up on GPO exclusion related to 340(b) entities; discussions to help shape upcoming proposed rule on 340B with HRSA; Discussed the Qualified Health Plans (QHP) 90day grace period with HHS and its implications for hospitals; Support HJ Res 59, a continuing Appropriations Resolution for 2014, which includes a provision that averts Medicare physician payment cuts as Congress continues to work on a replacement of the flawed SGR formula; Support HR 3444 Critical Access Hospital Flexibility Act of 2013, to amend title XVIII of the Social Security Act to provide flexibility in the manner in which beds are counted for purposes of determining whether a hospital may be designated as a critical access hospital under the Medicare program; Support H.R.3698 and S. 2037 Two-Midnight Rule Delay Act of 2013, to delay the enforcement of the Medicare two-midnight rule for short inpatient hospital stays until the implementation of a new Medicare payment methodology for short inpatient hospital stays; Requested CMS and ONC to extend the EHR Incentive program regulatory timelines for 2014 and allow all providers greater flexibility in Stage 2 by giving all hospitals the option to make the transition to the 2014 Edition Certified EHR and the Stage 2 requirements (or the revised Stage 1 requirements, as applicable) over the course of 2014 or 2015; Support HR 3991 and S 2037 Critical Access Hospital Relief Act of 2014, amends title XVIII (Medicare) of the Social Security Act to repeal the 96-hour physician certification requirement for inpatient critical access hospital services under which a physician must certify that a patient may reasonably be expected to be discharged or transferred to a hospital within 96 hours after admission to the critical access hospital; Support HR 4188 Establishing Beneficiary Equity in the Hospital Readmission Program Act, to amend title XVIII of the Social Security Act to adjust the Medicare hospital readmission reduction program to respond to patient disparities; Support H.R. 2801 and S 1143 Protecting Access to Rural Therapy Services (PARTS) Act of 2013, a bill to adopt a default standard of general supervision for outpatient therapeutic services, develop a reasonable exceptions process with provider input to identify specific procedures that require direct supervision, ensure that, for CAHs, the definition of direct supervision is consistent with the CAH conditions of participation that allow a physician or NPP to present within 30 minutes of being called and prohibit enforcement of CMSs retroactive reinterpretation that the direct supervision requirements applied to services furnished since January 1, 2001; S.1932/H.R. 3890 Better Care, Lower Cost Act , AHA has not taken position on the bill, but did establish an AHA working group to analyze the legislation to amend title XVIII of the Social Security Act to establish a Medicare Better Care Program to provide integrated care for Medicare beneficiaries with chronic conditions; requested that the increasing number of hospital compliance reviews performed by the Office of Inspector General (OIG) Office of Audit Services in which the OIG has extrapolated audit findings to estimate Medicare overpayments to the hospitals and the hospitals Medicare Administrative Contractors (MACs)have sought to recover the extrapolated overpayment amounts be halted without delay; Support HR 5481, The Flexibility in Health IT Reporting (Flex-It) Act, a bill to continue the use of a 3-month quarter EHR reporting period for health care providers to demonstrate meaningful use for 2015 under the Medicare and Medicaid EHR incentive payment programs.

- Medicare Audit Improvement Act of 2013 (H.R. 1250) - Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) - The DSH Reduction Relief Act of 2013 (H.R. 1920)Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Medicare physician fee schedule fix Structural changes to Medicare combining Parts A and B Severe sepsis protocols Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, and Medicaid provider taxes. Medicare and Medicaid Programs; Electronic Health Record Incentive Payment Programs certification requirements. Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures Medicare and Medicaid Disproportionate Share Hospital (DSH) Payments FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy Vital Access Provider (VAP) program

Client expense: Not reported · Firm income: Not reported

Medicare Audit Improvement Act of 2013 (H.R. 1250) Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) Protecting Seniors Access to Medicare Act of 2013 (H.R. 351 and S. 351) The DSH Reduction Relief Act of 2013 (H.R. 1920) Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Two Midnight Rule Delay Act (H.R. 3698)/Two-Midnight Rule Coordination and Improvement Act of 2014 (S. 2082) Establishing Beneficiary Equity in the Hospital Readmission Program Act (H.R. 4188)/ Hospital Readmissions Program Accuracy and Accountability Act of 2014 (S. 2501) Craig Thomas Rural Hospital and Provider Equity Act (S. 2359) Flexibility in Health IT Reporting Act (HR 5481) Making the Education of Nurses Dependable for Schools (MEND) Act (H.R. 5227)? Medicare physician fee schedule fix Structural changes to Medicare - combining Parts A and B Severe sepsis protocols Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, Disproportionate Share Hospital (DSH) Payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, Medicaid provider taxes, and sequestration. Medicare and Medicaid Electronic Health Record Incentive Payment Programs Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Medicare Advantage Plan implementation of sequestration reductions Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) - Two-Midnight Policy FFY 2015 Inpatient Prospective Payment System Proposed Rule (CMS-1607-P) - Two-Midnight Policy Meaningful Use Proposed Rule (CMS-0052-P) Vital Access Provider (VAP) program

Submitted comments on the Hatch Entitlement Reform in support of the several key reforms proposed for the Medicare program as alternative reductions to provider payments; Support S 351 Protecting Seniors Access to Medicare Act, a bill to repeal the provisions of the Patient Protection and Affordable Care Act providing for the Independent Payment Advisory Board; Support HR 297 and S1557, Children's Hospital GME Support Reauthorization Act of 2013, the bill would reauthorize the CHGME program foran additional five years through fiscal year (FY) 2017; Support HR 1250 and S 1012 Medicare Audit Improvement Act of 2013, a bill to amend title XVIII of the Social Security Act to improve operations of recovery auditors under the Medicare integrity program, to increase transparency and accuracy in audits conducted by contractors; Support S. 596 Fostering Independence Through Technology Act of 2014, a bill to establish pilot projects under the Medicare program to provide incentives for home health agencies to furnish remote patient monitoring services that reduce expenditures under such program; Support HR 1787 and S 842 Rural Hospital Access Act of 2013, a bill to amend title XVIII of the Social Security Act to provide for an extension of the Medicare-dependent hospital (MDH) program and the increased payments under the Medicare low-volume hospital program; Support HR 1920 and S 1555 DSH Reduction Relief Act of 2013, a bill to amend titles XVIII and XIX of the Social Security Act to provide for a delay in the implementation schedule of the reductions in disproportionate share hospital payments; AHA submitted a statement to the Presidents and Other Bipartisan Proposals to Reform Medicare Post-Acute Care Payments hearing to provide input on proposals to reform Medicares post-acute care payment systems; AHA submitted a statement to the Program Integrity: Oversight of Recovery Audit Contractors hearing supporting increased oversight of Recovery Audit Contractors (RACs); Support HR 2578 Rural Hospital Fairness Act of 2013, a bill to amend title XVIII of the Social Security Act to extend for one year the hold harmless provision for small rural hospitals and sole community hospitals under the Medicare prospective payment system for hospital outpatient department services related to enhanced physician supervision requirements; AHA submitted a statement to the Health Care Quality: The Path Forward hearing in support of improving transparency for the public, continuing and enhancing support of efforts to improve the safety and quality of the care delivered, and reduce unnecessary hospital expenditures; Support HR 2931 Fairness in Health Care Claims, Guidance and Investigations Act, a bill to amend the false claims provisions of title 31, United States Code, with respect to health care programs; Request additional guidance on and delay of two-midnight rule from CMS; Request issue corrected data on OPPS proposed rule and delay comment period from CMS; Discussion of ACAs patient safety evaluation system with CMS; Discussed the improvements to the National Practitioner Data Bank and new compliance efforts at HRSA; Discussions of Medicaid presumptive eligibility; Medicaid DSH; and request release of DSH audit rule with CMS; Follow up on GPO exclusion related to 340(b) entities; discussions to help shape upcoming proposed rule on 340B with HRSA; Discussed the Qualified Health Plans (QHP) 90day grace period with HHS and its implications for hospitals; Support HJ Res 59, a continuing Appropriations Resolution for 2014, which includes a provision that averts Medicare physician payment cuts as Congress continues to work on a replacement of the flawed SGR formula; Support HR 3444 Critical Access Hospital Flexibility Act of 2013, to amend title XVIII of the Social Security Act to provide flexibility in the manner in which beds are counted for purposes of determining whether a hospital may be designated as a critical access hospital under the Medicare program; Support H.R.3698 and S. 2037 Two-Midnight Rule Delay Act of 2013, to delay the enforcement of the Medicare two-midnight rule for short inpatient hospital stays until the implementation of a new Medicare payment methodology for short inpatient hospital stays; Requested CMS and ONC to extend the EHR Incentive program regulatory timelines for 2014 and allow all providers greater flexibility in Stage 2 by giving all hospitals the option to make the transition to the 2014 Edition Certified EHR and the Stage 2 requirements (or the revised Stage 1 requirements, as applicable) over the course of 2014 or 2015; Support HR 3991 and S 2037 Critical Access Hospital Relief Act of 2014, amends title XVIII (Medicare) of the Social Security Act to repeal the 96-hour physician certification requirement for inpatient critical access hospital services under which a physician must certify that a patient may reasonably be expected to be discharged or transferred to a hospital within 96 hours after admission to the critical access hospital; Support HR 4188 Establishing Beneficiary Equity in the Hospital Readmission Program Act, to amend title XVIII of the Social Security Act to adjust the Medicare hospital readmission reduction program to respond to patient disparities; Support H.R. 2801 and S 1143 Protecting Access to Rural Therapy Services (PARTS) Act of 2013, a bill to adopt a default standard of general supervision for outpatient therapeutic services, develop a reasonable exceptions process with provider input to identify specific procedures that require direct supervision, ensure that, for CAHs, the definition of direct supervision is consistent with the CAH conditions of participation that allow a physician or NPP to present within 30 minutes of being called and prohibit enforcement of CMSs retroactive reinterpretation that the direct supervision requirements applied to services furnished since January 1, 2001; S. 1932/H.R. 3890 Better Care, Lower Cost Act , AHA has not taken position on the bill, but did establish an AHA working group to analyze the legislation to amend title XVIII of the Social Security Act to establish a Medicare Better Care Program to provide integrated care for Medicare beneficiaries with chronic conditions; requested that the increasing number of hospital compliance reviews performed by the Office of Inspector General (OIG) Office of Audit Services in which the OIG has extrapolated audit findings to estimate Medicare overpayments to the hospitals and the hospitals Medicare Administrative Contractors (MACs) have sought to recover the extrapolated overpayment amounts be halted without delay.

SEE ATTACHED PAGENYS Medicaid 1115 Waiver NYS Vital Access Provider (VAP) funds Two-Midnight Rule Delay Act of 2013 (H.R. 3698) To delay the enforcement of the Medicare two-midnight rule for short inpatient hospital stays until the implementation of a new Medicare payment methodology for short inpatient hospital stays, and for other purposes. Rural Hospital Access Act (H.R. 1787/S. 842) Related to Medicare Dependent Hospital (MDH) and Medicare Low Volume (LV) Hospital, legislation to reauthorize for one year the MDH program and extend the current, expiring criteria for the LV adjustment. Rural Hospital Fairness Act of 2013 (H.R. 2578) Legislation that would reinstitute the TOPS (Transitional Outpatient Payments)program. Medicare Audit Improvement Act of 2013 (H.R. 1250/S. 1012) Legislation that would institute improvements in the Recovery Audit Contractor (RAC) program and other Medicare audit programs. The bill makes important changes to the RAC program that would streamline processes, establish more reasonable standards, and create greater fairness in RAC operations. 340B Drug Discount Program Allows hospitals that care for a disproportionate share of poor patients to purchase outpatient drugs at discounted rates. These hospitals experience chronic underpayments from public payers, like Medicaid. Maintaining the Special Medicare Status of Certain Rural Hospitals Special Medicare designations for certain rural hospitals preserve patient access to emergency, acute care, and other services largely in rural communities across Upstate New York; The Sole Community Hospital (SCH) and Critical Access Hospital (CAH) permanent programs should be fully protected as currently delineated.

Client expense: $150,000 · Firm income: Not reported

"Medicare Audit Improvement Act of 2013 (H.R. 1250) "Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) "Protecting Seniors' Access to Medicare Act of 2013 (H.R. 351 and S. 351) "The DSH Reduction Relief Act of 2013 (H.R. 1920)Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Two Midnight Rule Delay Act (H.R. 3698)/Two-Midnight Rule Coordination and Improvement Act of 2014 (S. 2082) Establishing Beneficiary Equity in the Hospital Readmission Program Act (H.R. 4188)/ Hospital Readmissions Program Accuracy and Accountability Act of 2014 (S. 2501) Craig Thomas Rural Hospital and Provider Equity Act (S. 2359) Medicare physician fee schedule fix Structural changes to Medicare combining Parts A and B Severe sepsis protocols Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, Disproportionate Share Hospital (DSH) Payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, Medicaid provider taxes, and sequestration. Medicare and Medicaid Electronic Health Record Incentive Payment Programs Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Medicare Advantage Plan implementation of sequestration reductions Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy FFY 2015 Inpatient Prospective Payment System Proposed Rule (CMS-1607-P) Two-Midnight Policy Meaningful Use Proposed Rule (CMS-0052-P) Vital Access Provider (VAP) program

- Medicare Audit Improvement Act of 2013 (H.R. 1250) - Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) - The DSH Reduction Relief Act of 2013 (H.R. 1920) Rural Hospital Access Act (H.R. 1787)Rural Hospital Fairness Act (H.R. 2578) Medicare physician fee schedule fix Medicare physician fee schedule fix Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Severe sepsis protocols Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, and Medicaid provider taxes. Medicare and Medicaid Programs; Electronic Health Record Incentive Payment Programs certification requirements. Medicare Advantage Plan implementation of sequestration reductions Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures Medicare and Medicaid Disproportionate Share Hospital (DSH) Payments FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy Vital Access Provider (VAP) program Medicare Readmissions legislation

Client expense: Not reported · Firm income: Not reported

"Medicare Audit Improvement Act of 2013 (H.R. 1250) "Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) "Protecting Seniors' Access to Medicare Act of 2013 (H.R. 351 and S. 351) "The DSH Reduction Relief Act of 2013 (H.R. 1920)Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Two Midnight Rule Delay Act (H.R. 3698)/Two-Midnight Rule Coordination and Improvement Act of 2014 (S. 2082) Establishing Beneficiary Equity in the Hospital Readmission Program Act (H.R. 4188) Medicare physician fee schedule fix Structural changes to Medicare combining Parts A and B Severe sepsis protocols Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, Disproportionate Share Hospital (DSH) Payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, Medicaid provider taxes, and sequestration. Medicare and Medicaid Electronic Health Record Incentive Payment Programs Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Medicare Advantage Plan implementation of sequestration reductions Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy Vital Access Provider (VAP) program

Client expense: $200,000 · Firm income: Not reported

Submitted comments on the Hatch Entitlement Reform in support of the several key reforms proposed for the Medicare program as alternative reductions to provider payments; Support S 351 Protecting Seniors Access to Medicare Act, a bill to repeal the provisions of the Patient Protection and Affordable Care Act providing for the Independent Payment Advisory Board; Support HR 297 and S1557, Children's Hospital GME Support Reauthorization Act of 2013, the bill would reauthorize the CHGME program foran additional five years through fiscal year (FY) 2017; Support HR 1250 and S 1012 Medicare Audit Improvement Act of 2013, a bill to amend title XVIII of the Social Security Act to improve operations of recovery auditors under the Medicare integrity program, to increase transparency and accuracy in audits conducted by contractors; Support S. 596 Fostering Independence Through Technology Act of 2014, a bill to establish pilot projects under the Medicare program to provide incentives for home health agencies to furnish remote patient monitoring services that reduce expenditures under such program; Requested the Health Resource and Service Admin (HRSA) to delay the compliance date by at least six months to allow sufficient time for affected hospitals to make the necessary modifications to their existing inventory management practices as required by the new GPO guidance and recommend that HRSA continue to work with affected 340B hospitals to provide guidance and education on the GPO compliance issues.; Discussion of the Medicaid ACA implementation --DSH, expansion, eligibility at CMS; Discussion of the implementation of the American Taxpayer Relief Act (ATRA) specifically, the outpatient therapy provision and extension of the MDH program and enhanced low-volume adjustment at CMS; Urged CMS to to extend the timeline for meaningful use in 2014 and provide greater flexibility in Stage 2; Support HR 1787 and S 842 Rural Hospital Access Act of 2013, a bill to amend title XVIII of the Social Security Act to provide for an extension of the Medicare-dependent hospital (MDH) program and the increased payments under the Medicare low-volume hospital program; Support HR 1920 and S 1555 DSH Reduction Relief Act of 2013, a bill to amend titles XVIII and XIX of the Social Security Act to provide for a delay in the implementation schedule of the reductions in disproportionate share hospital payments; AHA submitted a statement to the Presidents and Other Bipartisan Proposals to Reform Medicare Post-Acute Care Payments hearing to provide input on proposals to reform Medicares post-acute care payment systems; AHA submitted a statement to the Program Integrity: Oversight of Recovery Audit Contractors hearing supporting increased oversight of Recovery Audit Contractors (RACs); Support HR 2578 Rural Hospital Fairness Act of 2013, a bill to amend title XVIII of the Social Security Act to extend for one year the hold harmless provision for small rural hospitals and sole community hospitals under the Medicare prospective payment system for hospital outpatient department services related to enhanced physician supervision requirements; AHA submitted a statement to the Health Care Quality: The Path Forward hearing in support of improving transparency for the public, continuing and enhancing support of efforts to improve the safety and quality of the care delivered, and reduce unnecessary hospital expenditures; Support HR 2931 Fairness in Health Care Claims, Guidance and Investigations Act, a bill to amend the false claims provisions of title 31, United States Code, with respect to health care programs; Request additional guidance on and delay of two-midnight rule from CMS; Request issue corrected data on OPPS proposed rule and delay comment period from CMS; Discussion of ACAs patient safety evaluation system with CMS; Discussed the improvements to the National Practitioner Data Bank and new compliance efforts at HRSA; Discussions of Medicaid presumptive eligibility; Medicaid DSH; and request release of DSH audit rule with CMS; Follow up on GPO exclusion related to 340(b) entities; discussions to help shape upcoming proposed rule on 340B with HRSA; Discussed the Qualified Health Plans (QHP) 90day grace period with HHS and its implications for hospitals; Support HJ Res 59, a continuing Appropriations Resolution for 2014, which includes a provision that averts Medicare physician payment cuts as Congress continues to work on a replacement of the flawed SGR formula; Support HR 3444 Critical Access Hospital Flexibility Act of 2013, to amend title XVIII of the Social Security Act to provide flexibility in the manner in which beds are counted for purposes of determining whether a hospital may be designated as a critical access hospital under the Medicare program; Support H.R.3698 and S. 2037 Two-Midnight Rule Delay Act of 2013, to delay the enforcement of the Medicare two-midnight rule for short inpatient hospital stays until the implementation of a new Medicare payment methodology for short inpatient hospital stays; Requested CMS and ONC to extend the EHR Incentive program regulatory timelines for 2014 and allow all providers greater flexibility in Stage 2 by giving all hospitals the option to make the transition to the 2014 Edition Certified EHR and the Stage 2 requirements (or the revised Stage 1 requirements, as applicable) over the course of 2014 or 2015; Requested CMS to expedite its ICD-10 testing plans to ensure that testing begins no later than January 2014, be made available to all hospitals and include extensive end-to-end testing by Medicare contractors and state Medicaid agencies of both the electronic transaction and the adjudication of the claim; Support HR 3991 and S 2037 Critical Access Hospital Relief Act of 2014, amends title XVIII (Medicare) of the Social Security Act to repeal the 96-hour physician certification requirement for inpatient critical access hospital services under which a physician must certify that a patient may reasonably be expected to be discharged or transferred to a hospital within 96 hours after admission to the critical access hospital; Support HR 4188 Establishing Beneficiary Equity in the Hospital Readmission Program Act, to amend title XVIII of the Social Security Act to adjust the Medicare hospital readmission reduction program to respond to patient disparities; Support H.R. 2801 and S 1143 Protecting Access to Rural Therapy Services (PARTS) Act of 2013, a bill to adopt a default standard of general supervision for outpatient therapeutic services, develop a reasonable exceptions process with provider input to identify specific procedures that require direct supervision, ensure that, for CAHs, the definition of direct supervision is consistent with the CAH conditions of participation that allow a physician or NPP to present within 30 minutes of being called and prohibit enforcement of CMSs retroactive reinterpretation that the direct supervision requirements applied to servicesfurnished since January 1, 2001; S. 1932/H.R. 3890 Better Care, Lower Cost Act , AHA has not taken position on the bill, but did establish an AHA working group to analyze the legislation to amend title XVIII of the Social Security Act to establish a Medicare Better Care Program to provide integrated care for Medicare beneficiaries with chronic conditions.

- Medicare Audit Improvement Act of 2013 (H.R. 1250) - Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) - Protecting Seniors' Access to Medicare Act of 2013 (H.R. 351 and S. 351) - The DSH Reduction Relief Act of 2013 (H.R. 1920)Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Medicare physician fee schedule fix Structural changes to Medicare combining Parts A and B Severe sepsis protocols Federal Housing Administrations Hospital Mortgage Insurance Program (242) Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, and Medicaid provider taxes. Medicare and Medicaid Programs; Electronic Health Record Incentive Payment Programs certification requirements. Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Medicare Advantage Plan implementation of sequestration reductions Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures Medicare and Medicaid Disproportionate Share Hospital (DSH) Payments FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy Vital Access Provider (VAP) program Medicare Readmissions legislation

Client expense: Not reported · Firm income: Not reported

SEE ATTACHED PAGEIROQUOIS HEALHCARE ALLIANCE 1Q2014 NYS Medicaid 1115 Waiver NYS Vital Access Provider (VAP) funds Two-Midnight Rule Delay Act of 2013 (H.R. 3698) To delay the enforcement of the Medicare two-midnight rule for short inpatient hospital stays until the implementation of a new Medicare payment methodology for short inpatient hospital stays, and for other purposes. Rural Hospital Access Act (H.R. 1787/S. 842) Related to Medicare Dependent Hospital (MDH) and Medicare Low Volume (LV) Hospital, legislation to reauthorize for one year the MDH program and extend the current, expiring criteria for the LV adjustment. Rural Hospital Fairness Act of 2013 (H.R. 2578) Legislation that would reinstitute the TOPS (Transitional Outpatient Payments)program. Medicare Audit Improvement Act of 2013 (H.R. 1250/S. 1012) Legislation that would institute improvements in the Recovery Audit Contractor (RAC) program and other Medicare audit programs. The bill makes important changes to the RAC program that would streamline processes, establish more reasonable standards, and create greater fairness in RAC operations. 340B Drug Discount Program Allows hospitals that care for a disproportionate share of poor patients to purchase outpatient drugs at discounted rates. These hospitals experience chronic underpayments from public payers, like Medicaid. Maintaining the Special Medicare Status of Certain Rural Hospitals Special Medicare designations for certain rural hospitals preserve patient access to emergency, acute care, and other services largely in rural communities across Upstate New York; The Sole Community Hospital (SCH) and Critical Access Hospital (CAH) permanent programs should be fully protected as currently delineated.

Client expense: $130,000 · Firm income: Not reported

H.R. 1250/S. 1012 Medicare Audit Improvement Act of 2013, entire bill. H.R. 2578, the Rural Hospital Fairness Act of 2013, entire bill. S. 1143, Protecting Access to Rural Therapy Services Act, entire bill. H.R. 1787/S. 842, the Rural Hospital Access Act of 2013, entire bills.S. 183, Hospital Payment Fairness Act of 2013. S. 1053/H.R. 2302, the HELP Hospice Act, entire bill. H.R. 2053/ S. 183, to amend title XVIII of the Social Security Act to apply budget neutrality on a state-specific basis in the calculation of the Medicare hospital wage index floor for non-rural areas, entire bill. H.R. 1920, DSH Reduction Relief Act of 2013, entire bill. H.R. 2801/S. 1143, Protecting Access to Rural Therapy Services (PARTS) Act, entire bill. H.R. 2810, Medicare Patient Access and Quality Improvement Act of 2013. Proposals surrounding the Sustainable Growth Rate (SGR) and deficit/debt reduction as related to hospitals and physicians, including H.R.2810, the Medicare Patient Access and Quality Improvement Act of 2013, entire bill. Bi-partisan, bi-cameral proposal in Senate Finance Committee to permanently repeal SGR and amendments. H. Resolution 356/ S Resolution 26, The Importance of Rural Health Access for American Communities. President Obama's budget for FY 2014, budget proposal with a focus on Medicare and Medicaid policies. H.R. 3698, Two Midnight Rule Delay Act of 2013; S 2082: Two Midnight Rule Coordination and Improvement Act of 2014 H.R. 3991/ S. 2037 Critical Access Hospital Relief Act of 2014 (96 Hour Rule) HR 4067/S 1954: Extension of Moratorium on Direct Supervision; HR 3769: Extension of Moratorium on Direct Supervision HR 4015/ S 2000: SGR Repeal and Medicare Provider Payment Modernization Act of 2014; HR 4302: Protecting Access to Medicare Act 2014 S. 25: Repealing the Reduction in the Cost of Living Adjustment (COLA) for Retired Members of the Armed Services Bureau By Extending the Medicare Sequester. S.540 - Temporary Debt Limit Extension Act and preceeding potential proposals for raising the debt limit and funding.H.R. 3590, Patient Protection and Affordable Care Act, provisions relating to hospitals, hospice and physicians including: Section 3001: hospital value-based purchasing; Section 3125: low-volume hospital payment; Section 3401: productivity adjustments; Section 3121: outpatient hold harmless for hospitals; Sections 7101-7103: 340B Program; Section 3401: Independent Payment Advisory Board; Section 3015: hospital readmissions program; Section 3124: Extension of Medicare Dependent Hospital program; Section 3137: Section 508 Reclassification; Section 9007: non-profit hospital provision; Section 3105: ambulance services; Section 3008 and Section 2702: payment adjustment for hospital acquired conditions; Section 3133: Medicare DSH; Section 2551: Disproportionate Share Hospitals; Section 5501: Primary Care Provisions; Section 5503: Graduate Medical Education; Sections 2001-2081: Expansion of Medicaid, CHIP; Sections 1311-1343: CO-OPs and Exchanges; Section 3022: Accountable Care Organizations; Section 3023: Hospital Bundling Provision; Section 6401-6402: Program Integrity Provisions; Section 6501-6503, 6505, 6508: Medicaid Program Integrity Provisions; Section 3141: Changes to the Rural Floor of the Hospital Wage Index. H.R. 4872, Health Care & Education Affordability Reconciliation Act of 2010: provisions relating to hospitals and physicians, including: Section 2302: 340B program; Section 1104 and Section 1203: Medicare and Medicaid DSH Payments; Sections 1108 and 1109 involving geographic disparities in Medicare payment; Section 1105: Market basket updates; Section 1201: Federal funding for States. H.R. 3630 (introduced by 112th Congress), Middle Class Tax Relief and Job Creation Act of 2011, Title II, Subtitle C--Medicare Extensions; Other Health Provisions, Part 1--Medicare extensions, Section 2201, Physician payment update. Section 2202: Ambulance Add-ons; Section 2203: Medicare payment for outpatient therapy services; Section 2204: Work geographic Adjustment; Part 3--Offsets, Section 2223: Parity in Medicare payments for hospital outpatient department evaluation and management office visit services; Section 2224, Reduction of bad debt treated as an allowable cost; Section 2225, Rebasing of State DSH allotments for FY 2021. Part 2 of Subtitle C--Other Health Provisions, Section 2213: Modification to requirements for qualifying for exception to Medicare prohibition on certain physician referrals for hospitals. Other issues: 2014 Inpatient/Long term care hospital Prospective Payment System rule, entire rule. 2014 Outpatient Prospective Payment System rule, entire rule. Medicaid DSH Reduction rule, entire rule. Medicare and Medicaid Recovery Audit Contractor programs, including CMS' proposed changes to the rebilling policy for hospitals, CMS1455P. Medicare and Medicaid Electronic Health Record Payment Incentive Programs. Simpson/Bowles Budget proposal released in April 2013, entire proposal. Implementation of the state health insurance exchanges. 340B Drug Discount Program. Critical Access Hospitals/OIG report and potential changes to CAH designation. Proposals involving site-neutral payment policies impacting payments to hospitals.

S. 1012 / H.R. 1250: Medicare Audit Improvement Act of 2013 S. 183 / H.R. 2053: Hospital Payment Fairness Act of 2013 H.R. 2329: Administrative Relief and Accurate Medicare Payments Act of 2013 H.R. 3698: Two Midnight Rule Delay ActS. 2082: Two-Midnight Rule Coordination and Improvement Act of 2014 S. 1143 / H.R. 2801: Protecting Access to Rural Therapy Services Act S. 842 / H.R. 1787: Rural Hospital Access Act of 2013 H.R. 2578: Rural Hospital Fairness Act of 2013 H.R. 3769: Delays enforcement of physician supervision requirements for CAHs H.R. 4302: Protecting Access to Medicare Act of 2014 S. 2037 / H.R. 3991: Critical Access Hospital Relief Act of 2014 S. 2187: Rural Community Hospital Demonstration Extension Act of 2014

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

"Medicare Audit Improvement Act of 2013 (H.R. 1250) "Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) "Protecting Seniors' Access to Medicare Act of 2013 (H.R. 351 and S. 351) "The DSH Reduction Relief Act of 2013 (H.R. 1920)Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Two Midnight Rule Delay Act (H.R. 3698) Medicare physician fee schedule fix Structural changes to Medicare combining Parts A and B Severe sepsis protocols Federal Housing Administrations Hospital Mortgage Insurance Program (242) Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, Medicaid provider taxes, and sequestration. Medicare and Medicaid Programs; Electronic Health Record Incentive Payment Programs certification requirements. Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Medicare Advantage Plan implementation of sequestration reductions Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures Medicare and Medicaid Disproportionate Share Hospital (DSH) Payments FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy Vital Access Provider (VAP) program Medicare Readmissions legislation

Client expense: $230,000 · Firm income: Not reported

"Medicare Audit Improvement Act of 2013 (H.R. 1250) "Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) "Protecting Seniors' Access to Medicare Act of 2013 (H.R. 351 and S. 351) "The DSH Reduction Relief Act of 2013 (H.R. 1920)Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Two Midnight Rule Delay Act (H.R. 3698) Medicare physician fee schedule fix Structural changes to Medicare combining Parts A and B Severe sepsis protocols Federal Housing Administrations Hospital Mortgage Insurance Program (242) Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, Medicaid provider taxes, and sequestration. Medicare and Medicaid Programs; Electronic Health Record Incentive Payment Programs certification requirements. Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Medicare Advantage Plan implementation of sequestration reductions Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures Medicare and Medicaid Disproportionate Share Hospital (DSH) Payments FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy Vital Access Provider (VAP) program Medicare Readmissions legislation

Client expense: $230,000 · Firm income: Not reported

S. 1012 / H.R. 1250: Medicare Audit Improvement Act of 2013 S. 183 / H.R. 2053: Hospital Payment Fairness Act of 2013 H.R. 2329: Administrative Relief and Accurate Medicare Payments Act of 2013 H.R. 3698: Two Midnight Rule Delay ActS. 1143 / H.R. 2801: Protecting Access to Rural Therapy Services Act S. 842 / H.R. 1787: Rural Hospital Access Act of 2013 H.R. 2578: Rural Hospital Fairness Act of 2013 Bipartisan Budget Act of 2013 Pathway for SGR Reform Act of 2013 SGR Repeal and Medicare Beneficiary Access Act of 2013 H.R. 3769: Delays enforcement of physician supervision requirements for CAHs

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Submitted comments on the Hatch Entitlement Reform in support of the several key reforms proposed for the Medicare program as alternative reductions to provider payments; Support S 351 Protecting Seniors Access to Medicare Act, a bill to repeal the provisions of the Patient Protection and Affordable Care Act providing for the Independent Payment Advisory Board; Support HR 297 and S1557, Children's Hospital GME Support Reauthorization Act of 2013, the bill would reauthorize the CHGME program foran additional five years through fiscal year (FY) 2017; Support HR 1250 and S 1012 Medicare Audit Improvement Act of 2013, a bill to amend title XVIII of the Social Security Act to improve operations of recovery auditors under the Medicare integrity program, to increase transparency and accuracy in audits conducted by contractors; Support S. 596 Fostering Independence Through Technology Act of 2014, a bill to establish pilot projects under the Medicare program to provide incentives for home health agencies to furnish remote patient monitoring services that reduce expenditures under such program; Requested the Health Resource and Service Admin (HRSA) to delay the compliance date by at least six months to allow sufficient time for affected hospitals to make the necessary modifications to their existing inventory management practices as required by the new GPO guidance and recommend that HRSA continue to work with affected 340B hospitals to provide guidance and education on the GPO compliance issues.; Discussion of the Medicaid ACA implementation --DSH, expansion, eligibility at CMS; Discussion of the implementation of the American Taxpayer Relief Act (ATRA) specifically, the outpatient therapy provision and extension of the MDH program and enhanced low-volume adjustment at CMS; Urged CMS to allow the second option of reporting given that individual electronic health records (EHRs) or hospitals may not be ready to report inpatient quality reporting (IQR) measures electronically by a date certain of the implementation of the Medicare and Medicaid EHR Incentive Programs with CMS and the Office of the National Coordinator for Health Information Technology (ONC); Support HR 1787 and S 842 Rural Hospital Access Act of 2013, a bill to amend title XVIII of the Social Security Act to provide for an extension of the Medicare-dependent hospital (MDH) program and the increased payments under the Medicare low-volume hospital program; Support HR 1920 and S 1555 DSH Reduction Relief Act of 2013, a bill to amend titles XVIII and XIX of the Social Security Act to provide for a delay in the implementation schedule of the reductions in disproportionate share hospital payments; AHA submitted a statement to the Presidents and Other Bipartisan Proposals to Reform Medicare Post-Acute Care Payments hearing to provide input on proposals to reform Medicares post-acute care payment systems; AHA submitted a statement to the Program Integrity: Oversight of Recovery Audit Contractors hearing supporting increased oversight of Recovery Audit Contractors (RACs); Support HR 2578 Rural Hospital Fairness Act of 2013, a bill to amend title XVIII of the Social Security Act to extend for one year the hold harmless provision for small rural hospitals and sole community hospitals under the Medicare prospective payment system for hospital outpatient department services related to enhanced physician supervision requirements; AHA submitted a statement to the Health Care Quality: The Path Forward hearing in support of improving transparency for the public, continuing and enhancing support of efforts to improve the safety and quality of the care delivered, and reduce unnecessary hospital expenditures; Support HR 2931 Fairness in Health Care Claims, Guidance and Investigations Act, a bill to amend the false claims provisions of title 31, United States Code, with respect to health care programs; Request additional guidance on and delay of two-midnight rule from CMS; Request issue corrected data on OPPS proposed rule and delay comment period from CMS; Discussion of ACAs patient safety evaluation system with CMS; Discussed the improvements to the National Practitioner Data Bank and new compliance efforts at HRSA; Discussions of Medicaid presumptive eligibility; Medicaid DSH; and request release of DSH audit rule with CMS; Follow up on GPO exclusion related to 340(b) entities; discussions to help shape upcoming proposed rule on 340B with HRSA; Discussed the Qualified Health Plans (QHP) 90day grace period with HHS and its implications for hospitals; Support HJ Res 59, a continuing Appropriations Resolution for 2014, which includes a provision that averts Medicare physician payment cuts as Congress continues to work on a replacement of the flawed SGR formula; Support HR 3444 Critical Access Hospital Flexibility Act of 2013, to amend title XVIII of the Social Security Act to provide flexibility in the manner in which beds are counted for purposes of determining whether a hospital may be designated as a critical access hospital under the Medicare program; Support H.R.3698 Two-Midnight Rule Delay Act of 2013, to delay the enforcement of the Medicare two-midnight rule for short inpatient hospital stays until the implementation of a new Medicare payment methodology for short inpatient hospital stays; Support HR 3717 Helping Families in Mental Health Crisis Act of 2013, the bill focuses programs and resources on psychiatric care for patients and families most in need of services; Support critical access hospital (CAH) 96 hours rule, physicians at (CAHs) must certify a condition of payment, at a hospital within 96 hours after admission to the CAH. Requested CMS and ONC to extend the EHR Incentive program regulatory timelines for 2014 and allow all providers greater flexibility in Stage 2 by giving all hospitals the option to make the transition to the 2014 Edition Certified EHR and the Stage 2 requirements (or the revised Stage 1 requirements, as applicable) over the course of 2014 or 2015; Requested CMS to expedite its ICD-10 testing plans to ensure that testing begins no later than January 2014, be made available to all hospitals and include extensive end-to-end testing by Medicare contractors and state Medicaid agencies of both the electronic transaction and the adjudication of the claim.

"Medicare Audit Improvement Act of 2013 (H.R. 1250) "Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) "Protecting Seniors' Access to Medicare Act of 2013 (H.R. 351 and S. 351) "The DSH Reduction Relief Act of 2013 (H.R. 1920)Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Medicare physician fee schedule fix Structural changes to Medicare combining Parts A and B Severe sepsis protocols Federal Housing Administrations Hospital Mortgage Insurance Program (242) Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, and Medicaid provider taxes. Medicare and Medicaid Programs; Electronic Health Record Incentive Payment Programs certification requirements. Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Medicare Advantage Plan implementation of sequestration reductions Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures Medicare and Medicaid Disproportionate Share Hospital (DSH) Payments FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy Vital Access Provider (VAP) program Medicare Readmissions legislation

Client expense: Not reported · Firm income: Not reported

"Medicare Audit Improvement Act of 2013 (H.R. 1250) "Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) "Protecting Seniors' Access to Medicare Act of 2013 (H.R. 351 and S. 351) "The DSH Reduction Relief Act of 2013 (H.R. 1920)Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Two Midnight Rule Delay Act (H.R. 3698) Medicare physician fee schedule fix Structural changes to Medicare combining Parts A and B Severe sepsis protocols Federal Housing Administrations Hospital Mortgage Insurance Program (242) Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, Medicaid provider taxes, and sequestration. Medicare and Medicaid Programs; Electronic Health Record Incentive Payment Programs certification requirements. Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Medicare Advantage Plan implementation of sequestration reductions Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures Medicare and Medicaid Disproportionate Share Hospital (DSH) Payments FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy Vital Access Provider (VAP) program Medicare Readmissions legislation

Client expense: $210,000 · Firm income: Not reported

SEE ATTACHED PAGEIROQUOIS HEALTHCARE ALLIANCE NYS Medicaid 1115 Waiver NYS Vital Access Provider (VAP) funds Two-Midnight Rule Delay Act of 2013 (H.R. 3698) To delay the enforcement of the Medicare two-midnight rule for short inpatient hospital stays until the implementation of a new Medicare payment methodology for short inpatient hospital stays, and for other purposes. Rural Hospital Access Act (H.R. 1787/S. 842) Related to Medicare Dependent Hospital (MDH) and Medicare Low Volume (LV) Hospital, legislation to reauthorize for one year the MDH program and extend the current, expiring criteria for the LV adjustment. Rural Hospital Fairness Act of 2013 (H.R. 2578) Legislation that would reinstitute the TOPS (Transitional Outpatient Payments)program. Medicare Audit Improvement Act of 2013 (H.R. 1250/S. 1012) Legislation that would institute improvements in the Recovery Audit Contractor (RAC) program and other Medicare audit programs. The bill makes important changes to the RAC program that would streamline processes, establish more reasonable standards, and create greater fairness in RAC operations. 340B Drug Discount Program Allows hospitals that care for a disproportionate share of poor patients to purchase outpatient drugs at discounted rates. These hospitals experience chronic underpayments from public payers, like Medicaid. Maintaining the Special Medicare Status of Certain Rural Hospitals Special Medicare designations for certain rural hospitals preserve patient access to emergency, acute care, and other services largely in rural communities across Upstate New York; The Sole Community Hospital (SCH) and Critical Access Hospital (CAH) permanent programs should be fully protected as currently delineated.

Client expense: $220,000 · Firm income: Not reported

H.R. 1250/S. 1012 Medicare Audit Improvement Act of 2013, entire bill. H.R. 2578, the Rural Hospital Fairness Act of 2013, entire bill. S. 1143, Protecting Access to Rural Therapy Services Act, entire bill. H.R. 1787/S. 842, the Rural Hospital Access Act of 2013, entire bills.S. 183, Hospital Payment Fairness Act of 2013. S. 1053/H.R. 2302, the HELP Hospice Act, entire bill. H.R. 2053/ S. 183, to amend title XVIII of the Social Security Act to apply budget neutrality on a state-specific basis in the calculation of the Medicare hospital wage index floor for non-rural areas, entire bill. H.R. 1920, DSH Reduction Relief Act of 2013, entire bill. H.R. 2801/S. 1143, Protecting Access to Rural Therapy Services (PARTS) Act, entire bill. H.R. 2810, Medicare Patient Access and Quality Improvement Act of 2013. Proposals surrounding the Sustainable Growth Rate (SGR) and deficit/debt reduction as related to hospitals and physicians, including H.R.2810, the Medicare Patient Access and Quality Improvement Act of 2013, entire bill. Bi-partisan, bi-cameral proposal in Senate Finance Committee to permanently repeal SGR and amendments. H. Resolution 356/ S Resolution 26, The Importance of Rural Health Access for American Communities. President Obama's budget for FY 2014, budget proposal with a focus on Medicare and Medicaid policies. H.R. 3698, Two Midnight Rule Delay Act of 2013. H.R. 3590, Patient Protection and Affordable Care Act, provisions relating to hospitals, hospice and physicians including: Section 3001: hospital value-based purchasing; Section 3125: low-volume hospital payment; Section 3401: productivity adjustments; Section 3121: outpatient hold harmless for hospitals; Sections 7101-7103: 340B Program; Section 3401: Independent Payment Advisory Board; Section 3015: hospital readmissions program; Section 3124: Extension of Medicare Dependent Hospital program; Section 3137: Section 508 Reclassification; Section 9007: non-profit hospital provision; Section 3105: ambulance services; Section 3008 and Section 2702: payment adjustment for hospital acquired conditions; Section 3133: Medicare DSH; Section 2551: Disproportionate Share Hospitals; Section 5501: Primary Care Provisions; Section 5503: Graduate Medical Education; Sections 2001-2081: Expansion of Medicaid, CHIP; Sections 1311-1343: CO-OPs and Exchanges; Section 3022: Accountable Care Organizations; Section 3023: Hospital Bundling Provision; Section 6401-6402: Program Integrity Provisions; Section 6501-6503, 6505, 6508: Medicaid Program Integrity Provisions; Section 3141: Changes to the Rural Floor of the Hospital Wage Index. H.R. 4872, Health Care & Education Affordability Reconciliation Act of 2010: provisions relating to hospitals and physicians, including: Section 2302: 340B program; Section 1104 and Section 1203: Medicare and Medicaid DSH Payments; Sections 1108 and 1109 involving geographic disparities in Medicare payment; Section 1105: Market basket updates; Section 1201: Federal funding for States. H.R. 3630 (introduced by 112th Congress), Middle Class Tax Relief and Job Creation Act of 2011, Title II, Subtitle C--Medicare Extensions; Other Health Provisions, Part 1--Medicare extensions, Section 2201, Physician payment update. Section 2202: Ambulance Add-ons; Section 2203: Medicare payment for outpatient therapy services; Section 2204: Work geographic Adjustment; Part 3--Offsets, Section 2223: Parity in Medicare payments for hospital outpatient department evaluation and management office visit services; Section 2224, Reduction of bad debt treated as an allowable cost; Section 2225, Rebasing of State DSH allotments for FY 2021. Part 2 of Subtitle C--Other Health Provisions, Section 2213: Modification to requirements for qualifying for exception to Medicare prohibition on certain physician referrals for hospitals. H.R. 3630 (introduced by 112th Congress), Middle Class Tax Relief and Job Creation Act of 2012, entire bill.Other issues: 2014 Inpatient/Long term care hospital Prospective Payment System rule, entire rule. 2014 Outpatient Prospective Payment System rule, entire rule. Medicaid DSH Reduction rule, entire rule. Medicare and Medicaid Recovery Audit Contractor programs, including CMS' proposed changes to the rebilling policy for hospitals, CMS1455P. Medicare and Medicaid Electronic Health Record Payment Incentive Programs. Simpson/Bowles Budget proposal released in April 2013, entire proposal. Implementation of the state health insurance exchanges. 340B Drug Discount Program. Critical Access Hospitals/OIG report and potential changes to CAH designation. Proposals involving site-neutral payment policies impacting payments to hospitals.

"Medicare Audit Improvement Act of 2013 (H.R. 1250) "Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) "Protecting Seniors' Access to Medicare Act of 2013 (H.R. 351 and S. 351) "The DSH Reduction Relief Act of 2013 (H.R. 1920)Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Medicare physician fee schedule fix Severe sepsis protocols Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, and Medicaid provider taxes Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures Medicare and Medicaid Disproportionate Share Hospital (DSH) Payments FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy Vital Access Provider (VAP) program

Client expense: Not reported · Firm income: Not reported

Submitted comments on the Hatch Entitlement Reform in support of the several key reforms proposed for the Medicare program as alternative reductions to provider payments; Support S 351 Protecting Seniors Access to Medicare Act, a bill to repeal the provisions of the Patient Protection and Affordable Care Act providing for the Independent Payment Advisory Board; Support HR 297, Children's Hospital GME Support Reauthorization Act of 2013, the bill would reauthorize the CHGME program for anadditional five years through fiscal year (FY) 2017; Support HR 1250 and S 1012 Medicare Audit Improvement Act of 2013, a bill to amend title XVIII of the Social Security Act to improve operations of recovery auditors under the Medicare integrity program, to increase transparency and accuracy in audits conducted by contractors; Support S. 596 Fostering Independence Through Technology Act of 2014, a bill to establish pilot projects under the Medicare program to provide incentives for home health agencies to furnish remote patient monitoring services that reduce expenditures under such program; Requested the Health Resource and Service Admin (HRSA) to delay the compliance date by at least six months to allow sufficient time for affected hospitals to make the necessary modifications to their existing inventory management practices as required by the new GPO guidance and recommend that HRSA continue to work with affected 340B hospitals to provide guidance and education on the GPO compliance issues.; Discussion of the Medicaid ACA implementation --DSH, expansion, eligibility at CMS; Discussion of the implementation of the American Taxpayer Relief Act (ATRA) specifically, the outpatient therapy provision and extension of the MDH program and enhanced low-volume adjustment at CMS; Urged CMS to allow the second option of reporting given that individual electronic health records (EHRs) or hospitals may not be ready to report inpatient quality reporting (IQR) measures electronically by a date certain of the implementation of the Medicare and Medicaid EHR Incentive Programs with CMS and the Office of the National Coordinator for Health Information Technology (ONC); Opposing CMSs proposed rule on Part A to Part B rebilling as too limiting regarding what claims would qualify for rebilling; Support HR 1787 and S 842 Rural Hospital Access Act of 2013, a bill to amend title XVIII of the Social Security Act to provide for an extension of the Medicare-dependent hospital (MDH) program and the increased payments under the Medicare low-volume hospital program; Support HR 1920 and S 1555 DSH Reduction Relief Act of 2013, a bill to amend titles XVIII and XIX of the Social Security Act to provide for a delay in the implementation schedule of the reductions in disproportionate share hospital payments; AHA submitted a statement to the Presidents and Other Bipartisan Proposals to Reform Medicare Post-Acute Care Payments hearing to provide input on proposals to reform Medicares post-acute care payment systems; AHA submitted a statement to the Program Integrity: Oversight of Recovery Audit Contractors hearing supporting increased oversight of Recovery Audit Contractors (RACs); Support HR 2578 Rural Hospital Fairness Act of 2013, a bill to amend title XVIII of the Social Security Act to extend for one year the hold harmless provision for small rural hospitals and sole community hospitals under the Medicare prospective payment system for hospital outpatient department services related to enhanced physician supervision requirements; AHA submitted a statement to the Health Care Quality: The Path Forward hearing in support of improving transparency for the public, continuing and enhancing support of efforts to improve the safety and quality of the care delivered, and reduce unnecessary hospital expenditures; Support HR 2931 Fairness in Health Care Claims, Guidance and Investigations Act, a bill to amend the false claims provisions of title 31, United States Code, with respect to health care programs; Request additional guidance on and delay of two-midnight rule from CMS; Request issue corrected data on OPPS proposed rule and delay comment period from CMS; Discussion of ACAs patient safety evaluation system with CMS; Discussed the improvements to the National Practitioner Data Bank and new compliance efforts at HRSA; Discussions of Medicaid presumptive eligibility; Medicaid DSH; and request release of DSH audit rule with CMS; Follow up on GPO exclusion related to 340(b) entities; discussions to help shape upcoming proposed rule on 340B with HRSA; Discussed the Qualified Health Plans (QHP) 90day grace period with HHS and its implications for hospitals.

SEE ATTACHED PAGEIroquois Healthcare Alliance Rural Hospital Access Act (H.R. 1787/S. 842) Related to Medicare Dependent Hospital (MDH) and Medicare Low Volume (LV) Hospital, legislation to reauthorize for one year the MDH program and extend the current, expiring criteria for the LV adjustment. Rural Hospital Fairness Act of 2013 (H.R. 2578) Legislation that would reinstitute the TOPS (Transitional Outpatient Payments)program. Medicare Audit Improvement Act of 2013 (H.R. 1250/S. 1012) Legislation that would institute improvements in the Recovery Audit Contractor (RAC) program and other Medicare audit programs. The bill makes important changes to the RAC program that would streamline processes, establish more reasonable standards, and create greater fairness in RAC operations. 340B Drug Discount Program Allows hospitals that care for a disproportionate share of poor patients to purchase outpatient drugs at discounted rates. These hospitals experience chronic underpayments from public payers, like Medicaid. Maintaining the Special Medicare Status of Certain Rural Hospitals Special Medicare designations for certain rural hospitals preserve patient access to emergency, acute care, and other services largely in rural communities across Upstate New York; The Sole Community Hospital (SCH) and Critical Access Hospital (CAH) permanent programs should be fully protected as currently delineated. NYS Medicaid 1115 Waiver NYS Vital Access Provider (VAP) funds

Client expense: $130,000 · Firm income: Not reported

"Medicare Audit Improvement Act of 2013 (H.R. 1250) "Resident Physician Shortage Reduction Act (S. 577/H.R. 1180) "Protecting Seniors' Access to Medicare Act of 2013 (H.R. 351 and S. 351) "The DSH Reduction Relief Act of 2013 (H.R. 1920)Rural Hospital Access Act (H.R. 1787) Rural Hospital Fairness Act (H.R. 2578) Medicare physician fee schedule fix Structural changes to Medicare combining Parts A and B Severe sepsis protocols Federal Housing Administrations Hospital Mortgage Insurance Program (242) Medicare and Medicaid Recovery Audit Contractor (RAC) Programs Funding for National Institutes of Health Medicare and Medicaid Payment reductions, including Graduate Medical Education, bad debt payments, post-acute care payments, CAH payments, IPPS coding offset, rural hospital payments, Medicare Dependent Hospital authorization, inpatient coding offset, outpatient department hold harmless for certain rural and Sole Community Hospitals, hospital outpatient department (HOPD) evaluation and management (E/M) services, and Medicaid provider taxes. Medicare and Medicaid Programs; Electronic Health Record Incentive Payment Programs certification requirements. Medicaid, New York State Medicaid Redesign Team, 1115 Waiver Medicare Advantage Plan implementation of sequestration reductions Hospital and health system pricing transparency Clinical quality measures and electronic clinical quality measures Medicare and Medicaid Disproportionate Share Hospital (DSH) Payments FY 2014 Inpatient Prospective Payment System Final Rule (CMS-1599-F) Two-Midnight Policy Vital Access Provider (VAP) program Medicare Readmissions legislation

Client expense: $210,000 · Firm income: Not reported

H.R. 1250/S. 1012 Medicare Audit Improvement Act of 2013, entire bill. H.R. 2578, the Rural Hospital Fairness Act of 2013, entire bill. S. 1143, Protecting Access to Rural Therapy Services Act, entire bill. H.R. 1787/S. 842, the Rural Hospital Access Act of 2013, entire bills.S. 183, Hospital Payment Fairness Act of 2013. S. 1053/H.R. 2302, the HELP Hospice Act, entire bill. H.R. 2053/ S. 183, to amend title XVIII of the Social Security Act to apply budget neutrality on a state-specific basis in the calculation of the Medicare hospital wage index floor for non-rural areas, entire bill. H.R. 1920, DSH Reduction Relief Act of 2013, entire bill. H.R. 2801/S. 1143, Protecting Access to Rural Therapy Services (PARTS) Act, entire bill. H.R. 2810, Medicare Patient Access and Quality Improvement Act of 2013. H. Resolution 356/ S Resolution 26, The Importance of Rural Health Access for American Communities. President Obama's budget for FY 2014, budget proposal with a focus on Medicare and Medicaid policies. H.R. 3590, Patient Protection and Affordable Care Act, provisions relating to hospitals, hospice and physicians including: Section 3001: hospital value-based purchasing; Section 3125: low-volume hospital payment; Section 3401: productivity adjustments; Section 3121: outpatient hold harmless for hospitals; Sections 7101-7103: 340B Program; Section 3401: Independent Payment Advisory Board; Section 3015: hospital readmissions program; Section 3124: Extension of Medicare Dependent Hospital program; Section 3137: Section 508 Reclassification; Section 9007: non-profit hospital provision; Section 3105: ambulance services; Section 3008 and Section 2702: payment adjustment for hospital acquired conditions; Section 3133: Medicare DSH; Section 2551: Disproportionate Share Hospitals; Section 5501: Primary Care Provisions; Section 5503: Graduate Medical Education; Sections 2001-2081: Expansion of Medicaid, CHIP; Sections 1311-1343: CO-OPs and Exchanges; Section 3022: Accountable Care Organizations; Section 3023: Hospital Bundling Provision; Section 6401-6402: Program Integrity Provisions; Section 6501-6503, 6505, 6508: Medicaid Program Integrity Provisions; Section 3141: Changes to the Rural Floor of the Hospital Wage Index. H.R. 4872, Health Care & Education Affordability Reconciliation Act of 2010: provisions relating to hospitals and physicians, including: Section 2302: 340B program; Section 1104 and Section 1203: Medicare and Medicaid DSH Payments; Sections 1108 and 1109 involving geographic disparities in Medicare payment; Section 1105: Market basket updates; Section 1201: Federal funding for States. Proposals surrounding the Sustainable Growth Rate (SGR) and deficit/debt reduction as related to hospitals and physicians, including H.R.2810, the Medicare Patient Access and Quality Improvement Act of 2013, entire bill. H.R. 3630 (introduced by 112th Congress), Middle Class Tax Relief and Job Creation Act of 2011, Title II, Subtitle C--Medicare Extensions; Other Health Provisions, Part 1--Medicare extensions, Section 2201, Physician payment update. Section 2202: Ambulance Add-ons; Section 2203: Medicare payment for outpatient therapy services; Section 2204: Work geographic Adjustment; Part 3--Offsets, Section 2223: Parity in Medicare payments for hospital outpatient department evaluation and management office visit services; Section 2224, Reduction of bad debt treated as an allowable cost; Section 2225, Rebasing of State DSH allotments for FY 2021. Part 2 of Subtitle C--Other Health Provisions, Section 2213: Modification to requirements for qualifying for exception to Medicare prohibition on certain physician referrals for hospitals. H.R. 3630 (introduced by 112th Congress), Middle Class Tax Relief and Job Creation Act of 2012, entire bill. H.R. 8, American Taxpayer Relief Act of 2012, entire bill with focus on Title VI and Title X.Other issues: 2014 Inpatient/Long term care hospital Prospective Payment System rule, entire rule. 2014 Outpatient Prospective Payment System rule, entire rule. Medicaid DSH Reduction rule, entire rule. Medicare and Medicaid Recovery Audit Contractor programs, including CMS' proposed changes to the rebilling policy for hospitals, CMS1455P. Medicare and Medicaid Electronic Health Record Payment Incentive Programs. Simpson/Bowles Budget proposal released in April 2013, entire proposal. Implementation of the state health insurance exchanges. 340B Drug Discount Program. Critical Access Hospitals/OIG report and potential changes to CAH designation. Proposals involving site-neutral payment policies impacting payments to hospitals.

S. 1012 / H.R. 1250: Medicare Audit Improvement Act of 2013 S. 183 / H.R. 2053: Hospital Payment Fairness Act of 2013 H.R. 2329: Administrative Relief and Accurate Medicare Payments Act of 2013 S. 1555 / H.R. 1920: DSH Reduction Relief ActS. 1143 / H.R. 2801: Protecting Access to Rural Therapy Services Act S. 842 / H.R. 1787: Rural Hospital Access Act of 2013 H.R. 2578: Rural Hospital Fairness Act of 2013 H.Res. 356: Importance of Rural Health Access for American Communities

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Submitted comments on the Hatch Entitlement Reform in support of the several key reforms proposed for the Medicare program as alternative reductions to provider payments; Support S 351 Protecting Seniors Access to Medicare Act, a bill to repeal the provisions of the Patient Protection and Affordable Care Act providing for the Independent Payment Advisory Board; Support HR 297, Children's Hospital GME Support Reauthorization Act of 2013, the bill would reauthorize the CHGME program for anadditional five years through fiscal year (FY) 2017; Support HR 1250 and S 1012 Medicare Audit Improvement Act of 2013, a bill to amend title XVIII of the Social Security Act to improve operations of recovery auditors under the Medicare integrity program, to increase transparency and accuracy in audits conducted by contractors; Support S. 596 Fostering Independence Through Technology Act of 2014, a bill to establish pilot projects under the Medicare program to provide incentives for home health agencies to furnish remote patient monitoring services that reduce expenditures under such program; Requested the Health Resource and Service Admin (HRSA) to delay the compliance date by at least six months to allow sufficient time for affected hospitals to make the necessary modifications to their existing inventory management practices as required by the new GPO guidance and recommend that HRSA continue to work with affected 340B hospitals to provide guidance and education on the GPO compliance issues.; Discussion of the Medicaid ACA implementation --DSH, expansion, eligibility at CMS; Discussion of the implementation of the American Taxpayer Relief Act (ATRA) specifically, the outpatient therapy provision and extension of the MDH program and enhanced low-volume adjustment at CMS; Urged CMS to allow the second option of reporting given that individual electronic health records (EHRs) or hospitals may not be ready to report inpatient quality reporting (IQR) measures electronically by a date certain of the implementation of the Medicare and Medicaid EHR Incentive Programs with CMS and the Office of the National Coordinator for Health Information Technology (ONC); Opposing CMSs proposed rule on Part A to Part B rebilling as too limiting regarding what claims would qualify for rebilling; Support HR 1787 and S 842 Rural Hospital Access Act of 2013, a bill to amend title XVIII of the Social Security Act to provide for an extension of the Medicare-dependent hospital (MDH) program and the increased payments under the Medicare low-volume hospital program; Support HR 1920 DSH Reduction Relief Act of 2013, a bill to amend titles XVIII and XIX of the Social Security Act to provide for a delay in the implementation schedule of the reductions in disproportionate share hospital payments; AHA submitted a statement to the Presidents and Other Bipartisan Proposals to Reform Medicare Post-Acute Care Payments hearing to provide input on proposals to reform Medicares post-acute care payment systems; AHA submitted a statement to the Program Integrity: Oversight of Recovery Audit Contractors hearing supporting increased oversight of Recovery Audit Contractors (RACs); Support HR 2578 Rural Hospital Fairness Act of 2013, a bill to amend title XVIII of the Social Security Act to extend for one year the hold harmless provision for small rural hospitals and sole community hospitals under the Medicare prospective payment system for hospital outpatient department services related to enhanced physician supervision requirements; AHA submitted a statement to the Health Care Quality: The Path Forward hearing in support of improving transparency for the public, continuing and enhancing support of efforts to improve the safety and quality of the care delivered, and reduce unnecessary hospital expenditures.

Submitted comments on the Hatch Entitlement Reform in support of the several key reforms proposed for the Medicare program as alternative reductions to provider payments; Support S 351 Protecting Seniors Access to Medicare Act, a bill to repeal the provisions of the Patient Protection and Affordable Care Act providing for the Independent Payment Advisory Board; Support HR 297, Children's Hospital GME Support Reauthorization Act of 2013, the bill would reauthorize the CHGME program for anadditional five years through fiscal year (FY) 2017; Support HR 1250 and S 1012 Medicare Audit Improvement Act of 2013, a bill to amend title XVIII of the Social Security Act to improve operations of recovery auditors under the Medicare integrity program, to increase transparency and accuracy in audits conducted by contractors; Support S. 596 Fostering Independence Through Technology Act of 2014, a bill to establish pilot projects under the Medicare program to provide incentives for home health agencies to furnish remote patient monitoring services that reduce expenditures under such program; Requested the Health Resource and Service Admin (HRSA) to delay the compliance date by at least six months to allow sufficient time for affected hospitals to make the necessary modifications to their existing inventory management practices as required by the new GPO guidance and recommend that HRSA continue to work with affected 340B hospitals to provide guidance and education on the GPO compliance issues.; Discussion of the Medicaid ACA implementation --DSH, expansion, eligibility at CMS; Discussion of the implementation of the American Taxpayer Relief Act (ATRA) specifically, the outpatient therapy provision and extension of the MDH program and enhanced low-volume adjustment at CMS; Urged CMS to allow the second option of reporting given that individual electronic health records (EHRs) or hospitals may not be ready to report inpatient quality reporting (IQR) measures electronically by a date certain of the implementation of the Medicare and Medicaid EHR Incentive Programs with CMS and the Office of the National Coordinator for Health Information Technology (ONC); Opposing CMSs proposed rule on Part A to Part B rebilling as too limiting regarding what claims would qualify for rebilling; Support HR 1787 and S 842 Rural Hospital Access Act of 2013, a bill to amend title XVIII of the Social Security Act to provide for an extension of the Medicare-dependent hospital (MDH) program and the increased payments under the Medicare low-volume hospital program; Support HR 1920 DSH Reduction Relief Act of 2013, a bill to amend titles XVIII and XIX of the Social Security Act to provide for a delay in the implementation schedule of the reductions in disproportionate share hospital payments; AHA submitted a statement to the Presidents and Other Bipartisan Proposals to Reform Medicare Post-Acute Care Payments hearing to provide input on proposals to reform Medicares post-acute care payment systems; AHA submitted a statement to the Program Integrity: Oversight of Recovery Audit Contractors hearing supporting increased oversight of Recovery Audit Contractors (RACs); Support HR 2578 Rural Hospital Fairness Act of 2013, a bill to amend title XVIII of the Social Security Act to extend for one year the hold harmless provision for small rural hospitals and sole community hospitals under the Medicare prospective payment system for hospital outpatient department services related to enhanced physician supervision requirements; AHA submitted a statement to the Health Care Quality: The Path Forward hearing in support of improving transparency for the public, continuing and enhancing support of efforts to improve the safety and quality of the care delivered, and reduce unnecessary hospital expenditures.

H.R. 1250/S. 1012, Medicare Audit Improvement Act of 2013, entire bill. H.R. 2578, the Rural Hospital Fairness Act of 2013, entire bill. S. 1180, the Medicare Data Access for Transparency and Accountability Act, entire bill. S. 1143, Protecting Access to Rural Therapy Services Act, entire bill.H.R. 1787/S. 842, the Rural Hospital Access Act of 2013, entire bills. S. 1053/H.R. 2302, the HELP Hospice Act, entire bills. S. 183, Hospital Payment Fairness Act of 2013, entire bill. H.R.2053, To amend title XVIII of the Social Security Act to apply budget neutrality on a State-specific basis in the calculation of the Medicare hospital wage index floor for non-rural areas, entire bill. H.R. 1920, DSH Reduction Relief Act of 2013, entire bill. H.R. 45, To repeal the Patient Protection and Affordable Care Act and health care-related provisions in the Health Care and Education Reconciliation Act of 2010, entire bill. President Obama's budget for FY 2014, budget proposal with a focus on Medicare and Medicaid policies. Simpson/Bowles Budget proposal released in April 2013, entire proposal. H.R. 4872, Health Care & Education Affordability Reconciliation Act of 2010: provisions relating to hospitals and physicians, including: Section 2302: 340B program; Section 1104 and Section 1203: Medicare and Medicaid DSH Payments; Sections 1108 and 1109 involving geographic disparities in Medicare payment; Section 1105: Market basket updates; Section 1201: Federal funding for States. H.R. 3590, Patient Protection and Affordable Care Act, provisions relating to hospitals, hospice and physicians including: Section 3001: hospital value-based purchasing; Section 3125: low-volume hospital payment; Section 3401: productivity adjustments; Section 3121: outpatient hold harmless for hospitals; Sections 7101-7103: 340B Program; Section 3401: Independent Payment Advisory Board; Section 3015: hospital readmissions program; Section 3124: Extension of Medicare Dependent Hospital program; Section 3137: Section 508 Reclassification; Section 9007: non-profit hospital provision; Section 3105: ambulance services; Section 3008 and Section 2702: payment adjustment for hospital acquired conditions; Section 3133: Medicare DSH; Section 2551: Disproportionate Share Hospitals; Section 5501: Primary Care Provisions; Section 5503: Graduate Medical Education; Sections 2001-2081: Expansion of Medicaid, CHIP; Sections 1311-1343: CO-OPs and Exchanges; Section 3022: Accountable Care Organizations; Section 3023: Hospital Bundling Provision; Section 6401-6402: Program Integrity Provisions; Section 6501-6503, 6505, 6508: Medicaid Program Integrity Provisions; Section 3141: Changes to the Rural Floor of the Hospital Wage Index. H.R. 3630 (introduced by 112th Congress), Middle Class Tax Relief and Job Creation Act of 2011, Title II, Subtitle C--Medicare Extensions; Other Health Provisions, Part 1--Medicare extensions, Section 2201, Physician payment update. Section 2202: Ambulance Add-ons; Section 2203: Medicare payment for outpatient therapy services; Section 2204: Work geographic Adjustment; Part 3--Offsets, Section 2223: Parity in Medicare payments for hospital outpatient department evaluation and management office visit services; Section 2224, Reduction of bad debt treated as an allowable cost; Section 2225, Rebasing of State DSH allotments for FY 2021. Part 2 of Subtitle C--Other Health Provisions, Section 2213: Modification to requirements for qualifying for exception to Medicare prohibition on certain physician referrals for hospitals. H.R. 3630 (introduced by 112th Congress), Middle Class Tax Relief and Job Creation Act of 2012, entire bill. H.R. 8, American Taxpayer Relief Act of 2012, entire bill with focus on Title VI and Title X.Other issues: 2014 Inpatient/Long term care hospital Prospective Payment System proposed rule, entire rule. Medicaid DSH Reduction proposed rule, entire rule. 2014 Skilled Nursing Facility Prospective Payment System proposed rule, entire rule. 2014 Hospice payment proposed rule, entire rule. 2014 Inpatient Rehab Facility Prospective Payment System, proposed rule, entire rule. 2014 Home Health Prospective Payment System, proposed rule, entire rule. CMS 3267-P, Medicare and Medicaid Programs; Part IIRegulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction; Proposed Rule, entire rule. Medicare and Medicaid Recovery Audit Contractor programs, including CMS' proposed changes to the rebilling policy for hospitals, CMS1455P. Geographic Variation in Medicare spending, IOM studies on high value and Medicare geographic adjusters. Medicare and Medicaid Electronic Health Record Payment Incentive Programs. Hospital wage index reform, including Section 3137(b) of the Affordable Care Act, and Section 508 reclassification policy. 2013 Outpatient Prospective Payment System rule, entire rule. Proposals surrounding the Sustainable Growth Rate (SGR) and deficit/debt reduction as related to hospitals and physicians. Accountable Care Organizations and the Innovation Center's demonstration programs. Implementation of the state health insurance exchanges. Dual Eligible Demonstration Programs. 340B Drug Discount Program. Medicaid provider taxes.

S. 1012 / H.R. 1250: Medicare Audit Improvement Act of 2013 S. 183 / H.R. 2053: Hospital Payment Fairness Act of 2013 H.R. 2329: Administrative Relief and Accurate Medicare Payments Act of 2013 H.R. 1920: DSH Reduction Relief ActS. 1143: Protecting Access to Rural Therapy Services Act S. 842 / H.R. 1787: Rural Hospital Access Act of 2013 H.R. 2578: Rural Hospital Fairness Act of 2013

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE