ARCH Act

H.R.5378, Lower Costs, More Transparency Act, Issues related to site neutral payment cuts, hospital price transparency, unique health identifier, 340B Program; H.R. 3173 / S. 4532, Improving Seniors' Timely Access to Care, all provisions; S.4350 / H.R. 8260, Hospital Inpatient Services Modernization Act of 2024, all provisions; H.R. 7623, Telehealth Modernization Act, Issues pertaining to Telehealth, Hospital at Home, Unique Health Identifier; S. 1110, the Rural Hospital Support Act, all provisions; H.R. 6430, Assistance for Rural Community Hospitals (ARCH)Act, all provisions; H. Jes Res 139 / S.J. Res 91 A, joint resolution for congressional disapproval of a rule relating to "Medicare and Medicaid Programs; Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting", All provisions; S. 2016/ H.R. 4189, The CONNECT for Health Act of 2023, specifically telehealth waivers, geographic restrictions, originating site requirements, in person requirement behavioral health, RHCs and FQHCs access; H.R. 1110, KEEP Telehealth Option Act, All provisions; H.R. 5541, the Temporary Reciprocity to Ensure Access to Treatment (TREAT) Act, All provisions; HR 2389/ S. 1302, Resident Physician Shortage Reduction Act of 2023, All provisions ; H.R. 977/S. 470, Patient Access to Higher Quality Care Act, all provisions; H.R. 4946, Medicare Mental Health Inpatient Equity Act of 2023, all provisions; H.R. 6033,Supporting Patient Education and Knowledge (SPEAK) Act of 2023all provisions; H.R. 1406, Sustainable Cardiopulmonary Rehabilitation Services in the Home Act, all provisions; DRAFT, DRAFT Clarifying that Rural Emergency Hospitals are eligible for Medicaid hospital reimbursement; DRAFT, DRAFT, Expanding services Rural Emergency Hospitals (REHs) are paid at the enhanced outpatient prospective payment system rate, allow eligibility for Small Rural Hospital improvement Grants; DRAFT, DRAFT, Issues pertaining to freestanding emergency departments; H.R. 1666, Protecting Access to Ground Ambulance Medical Services Act of 2023, All provisions; H. R. 8246, Second Chances for Rural Hospitals Act, Issues pertaining to expansion of physician-owned Rural Emergency Hospitals; Draft Bill, Issues pertaining to proposed changes to the Medicare Graduate Medical Education program and solutions to address workforce shortages in rural areas; Centers for Medicare & Medicaid Services (CMS), Medicare Severity-Long Term Care-Diagnosis Related Groups (MS-LTC-DRGs) used as part of the LTCH prospective payment system (PPS), Feedback on Medicare Severity-Long Term Care-Diagnosis Related Groups (MS-LTC-DRGs) used as part of the LTCH prospective payment system (PPS); Centers for Medicare & Medicaid Services (CMS), Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2026, Navigators and non-navigator assistance personnel working within hospitals and health systems to assist consumers; Centers for Medicare & Medicaid Services (CMS) Medicare Part C Utilization Management Annual Data Submission and Audit Protocol Data Request, Proposed Medicare Part C Utilization Management and data submission and audit protocol; Medicare Payment Advisory Commission (MedPAC), Physician fee schedule payments, advanced alternative payment model (A-APM) incentives and Medicare Advantage (MA) network adequacy; Centers for Medicare & Medicaid Services (CMS), Affordable drugs, Medicare $2 Drug List Model request for information; Centers for Medicare & Medicaid Services (CMS), Changes to the Fiscal Year 2025 Hospital Inpatient Prospective Payment System (IPPS) Rates Due to Court Decision, Low Wage Index Policy changes due to recent court change; Centers for Medicare & Medicaid Services (CMS), Medicare Transaction Facilitator and the Medicare drug negotiation program, Information collection request (ICR) regarding the Medicare Transaction Facilitator (MTF) and the Medicare drug negotiation program; Site Neutral Payments, Issues related to site neutral payment cuts for drug administration; Provider Reimbursements, Issues related to provider reimbursement, site neutral payment cuts, Medicare/Medicaid program funding, facility fees, DSH cuts; Medicaid Disproportionate Share Hospital (DSH) program, Medicaid DSH program; Health Plan Accountability, Issues specific to prior authorization, patient access to care, adequate provider networks, inappropriate denials, reducing account receivables, prompt pay and cost-based reimbursement for critical access hospitals under Medicare Advantage; Physician Payments, Issues pertaining to proposed solutions to improve MACRA, alternative payment models, mental health of workforce, scheduled physician reimbursement cuts for 2025, extension of Medicare's Advanced Alternative Payment Model (AAPM) incentive payments; Rural Hospitals, Issues pertaining to the sustainability of MDHS, CAHs, SCHs, REH's; National Provider Identifier (NPI), Unique identifiers for off-campus Hospital Outpatient Departments (HOPDs); Organ Transplant Final Rule, Increasing Organ Transplant Access (IOTA) Final Rule, IOTA Model impact on hospitals.

Client expense: $6,570,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Medicare Payment Advisory Commission (MedPAC), SENATE

Support HR 2665, the Supporting Safety Net Hospitals Act, which would repeal cuts to the Medicaid Disproportionate Share Hospital Program. Request congressional member sign on to bi-partisan letter expressing support for Medicaid Disproportionate Share hospital program and addressing scheduled cuts. Support the Rural Hospital Support Act (S. 1110) and the Assistance for Rural Community Hospitals Act (H.R. 6430), which extend or make permanent the Low Volume Adjustment and Medicare Dependent Hospital programs. Support the Improving Seniors Timely Access to Care Act (H.R. 8702/S. 4532), which would streamline prior authorization in Medicare Advantage and improve access to care. Support for the Hospital Inpatient Modernation Act (S. 4350/H.R. 8260), which extends telehealth flexibilities and the Hospital at Home program. Oppose efforts to advance Medicare site neutral payment policies, as seen in the Lower Costs, More Transparency Act (HR 5378). Support the Telehealth Modernization Act (H.R. 7623), which extends COVID telehealth flexibilities for two years and Hospital at Home for five years.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

The SAVE Act (S. 2768/H.R. 2584) Telehealth and Hospital at Home, including the Hospital Inpatient Services Modernization Act (S. 4350/H.R. 8260) Site neutral payment proposals, including the Lower Costs, More Transparency Act (H.R. 5378) Medicare Dependent Hospital and Low-Volume Adjustment programs, including the Rural Hospital Support Act (S. 110) and Assistance for Rural Community Hospitals Act (H.R. 6430) Physician Fee Schedule policy, including the Medicare Patient Access and Practice Stabilization Act (H.R. 10073) Medicaid Disproportionate Share Hospital policy

Client expense: $30,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to Medicare reimbursement for rural referral centers (RRCs), sole community hospitals (SCHs) and Medicare dependent hospitals (MDHs), including the Rural Hospital Support Act (S.1110) and the Assistance for Rural Community Hospitals Act (H.R. 6430).

Client expense: Not reported · Firm income: $60,000

Government targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE

H.R. 5378 - Lower Costs, More Transparency Act - Re: Site Neutral and Hospital Price Transparency H.R. 3173/ S.5044 - "Improving Seniors' Timely Access to Care Act" - Re: Medicare Advantage Prior Authorization provisions H.R. 6430/ S.1110 - "The Assistance for Rural Community Hospitals (ARCH) Act" - Re: Discussions around Medicare rural extenders (LVH/MDH) H.R. 8246 - Second Chances for Rural Hospitals Act; S.4322 "Rural Emergency Hospital Designation Improvement Act" Re: discussions on protecting access to rural hospitals Payment delays and denials - Re: Medicare Advantage coverage requirements H.R. 8113 - "Transparency into State Directed Payments Act of 2024" - Re: Discussed importance of Medicaid payment adequacy Discussions around Medicaid DSH funding - Re: Medicaid DSH cut delay H.R. 7623/ S. 3967 - "Telehealth Modernization Act of 2024"; H.R. 8261 Preserving Telehealth, Hospital, and Ambulance Access Act; H.R. 4189/ S. 2016 - "CONNECT for Health Act of 2023"; H.R. 3432/ S. 3651 - "Telemental Health Care Access Act of 2023" - Re: Telehealth flexibilities CMMI Models - Re: Mandatory participation S. 5026 - SEPSIS Act re: sepsis prevention Discussions re: post-acute reimbursement and network adequacy

Client expense: $570,000 · Firm income: Not reported

H.R.5378, Lower Costs, More Transparency Act, Issues related to site neutral payment cuts, hospital price transparency, unique health identifier, 340B Program; H.R. 3173 / S. 4532, Improving Seniors' Timely Access to Care, all provisions; S.4350 / H.R. 8260, Hospital Inpatient Services Modernization Act of 2024, all provisions; Draft Bill, Issues pertaining to proposed changes to the Medicare Graduate Medical Education program and solutions to address workforce shortages in rural areas; S.4338, the Pay PCPs Act , Feedback to improve physician reimbursement and value-based primary care; S. 1110, the Rural Hospital Support Act, all provisions; H.R. 6430, Assistance for Rural Community Hospitals (ARCH)Act, all provisions; H.R. 7711, Advancing Access to Telehealth Act,all provisions; H.R. 3432, Telemental Health Care Access Act, all provisions; H.R. 3875, the Expanded Telehealth Access Act, all provisions; H.R. 5611, Helping Ensure Access to Local Telehealth (HEALTH) Act of 2023, all provisions; H.R. 6033, Supporting Patient Education and Knowledge (SPEAK) Act of 2023, all provisions; Draft Bill, To amend title XVIII of the Social Security Act to adjust long-term care hospital payment rates under the Medicare program, Issues related to LTCH payment policy reforms; S. 5236, A bill to amend titles XIX and XXI of the Social Security Act to enhance financial support for rural and safety net hospitals providing maternity, labor, and delivery services to vulnerable populations, and for other purposes, Reimbursements to rural and safety net hospitals providing maternity, labor, and delivery services; H.R. 7623, Telehealth Modernization Act, Issues pertaining to Telehealth, Hospital at Home, Unique Health Identifier; H. Jes Res 139 / S.J. Res 91, A joint resolution for congressional disapproval of a rule relating to "Medicare and Medicaid Programs, Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting", All provisions; S. 2016/ H.R. 4189, The CONNECT for Health Act of 2023, Specifically telehealth waivers, geographic restrictions, originating site requirements, in person requirement behavioral health, RHCs and FQHCs access; H.R. 1110, KEEP Telehealth Option Act, All provisions; H.R. 5541, the Temporary Reciprocity to Ensure Access to Treatment (TREAT) Act, All provisions; HR 2389/ S. 1302, Resident Physician Shortage Reduction Act of 2023, All provisions; H.R. 977/S. 470, Patient Access to Higher Quality Care Act, all provisions; Draft Bill, Obstetric care in Critical Access Hospitals (CAH); Centers for Medicare & Medicaid Services (CMS), Medicare Drug Price Negotiation Program Draft Guidance, Issues pertaining to the implementation of the Medicare drug price negotiation program; Centers for Medicare & Medicaid Services (CMS), Medicare Program; Alternative Payment Model Updates and the Increasing Organ Transplant Access (IOTA) Model, Issues pertaining to Value Based Care and feedback on proposed IOTA model; Centers for Medicare & Medicaid Services (CMS), FY 2025 Inpatient Prospective Payment Systems for Acute Care Hospitals; Disproportionate Share Hospital Payments, Issues pertaining to the FY2025 Inpatient Prospective Payment Systems Rule and Disproportionate Share Hospital Payments Changes in FY25 IPPS Rule; Medicare Payment Advisory Commission (MedPAC), 2025 Priorities, Issues pertaining to 340B Drug Pricing Program, inpatient rehabilitation facility (IRF) payments, the physician fee schedule (PFS) and telehealth in the new cycle; Centers for Medicare & Medicaid Services (CMS), Calendar Year (CY) 2025 Home Health Prospective; Payment System (HH PPS) Rate Update, Issues pertaining to the CY25 Home Health Proposed Rule; Centers for Medicare & Medicaid Services (CMS), Physician fee schedule (PFS) proposed rule for calendar year (CY) 2025, Issues pertaining to physician fee schedule; Centers for Medicare & Medicaid Services (CMS), Outpatient Prospective Payment System (OPPS) Proposed rule for Calendar Year (CY2025), Issues pertaining to outpatient and ambulatory surgery center prospective payment system, conditions of participation for maternal health; Health & Human Services (HHS), Letter to HHS, Medicare Advantage Organizations' Use of Prior Authorization for Post-Acute Care; Centers for Medicare & Medicaid Services (CMS), Significant, Anomalous and Highly Suspect (SAHS) billing in Medicare Shared Savings Program (MSSP) in Calendar Year 2023, Issues pertaining to proposed rule to mitigate the impact of significant, anomalous and highly suspect (SAHS) billing activity within the Medicare Shared Savings Program (MSSP) in calendar year (CY) 2023; Site Neutral Payments, Issues related to site neutral payment cuts for drug administration; Provider Reimbursements, Issues related to provider reimbursement, site neutral payment cuts, Medicare/Medicaid program funding, facility fees, DSH cuts; Medicaid Disproportionate Share Hospital (DSH) program, Medicaid DSH program; LTCH High Cost Outlier Threshold, SFC / W&M Meeting / CMS Meeting , Issues concerning High Cost Outlier in LTCH payment policy; National Provider Identifier (NPI), Included in E&C markup statement in September , Unique identifiers for off-campus Hospital Outpatient Departments (HOPDs); Access to inpatient rehabilitation care, Letter to CMS / Supported Hill Led Effort, Access to inpatient rehabilitation care for MA enrollees; Rural Hospitals, Issues pertaining to the sustainability of MDHS, CAHs, SCHs, and REHs; Physician Payments, Issues pertaining to proposed solutions to improve MACRA, alternative payment models, mental health of workforce; Health Plan Accountability, Issues specific to prior authorization, patient access to care, adequate provider networks, inappropriate denials, reducing account receivables, prompt pay and cost-based reimbursement for critical access hospitals under Medicare Advantage.

Support HR 2665, the Supporting Safety Net Hospitals Act, which would repeal cuts to the Medicaid Disproportionate Share Hospital Program. Provide feedback on reforms to the Rural Emergency Hospital designation program: The Second Chances for Rural Hospitals Act (H.R. 8246) and the Rural Emergency Hospital Designation Improvement Act (S. 4322). Support the Rural Hospital Support Act (S. 1110) and the Assistance for Rural Community Hospitals Act (H.R. 6430), which extend or make permanent the Low Volume Adjustment and Medicare Dependent Hospital programs. Support the Improving Seniors Timely Access to Care Act (H.R. 8702/S. 4532), which would streamline prior authorization in Medicare Advantage and improve access to care. Support for the Hospital Inpatient Modernation Act (S. 4350/H.R. 8260), which extends telehealth flexibilities and the Hospital at Home program. Oppose efforts to advance Medicare site neutral payment policies, as seen in the Lower Costs, More Transparency Act (HR 5378). Submit comments to CMS on CMS-10856: Agency Information Collection Activities: Proposed Collection, specifically about attestations for providers participating in state directed payment programs. Submit comments to CMS on Re: CMS-1809-P; Proposed Rule - Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; Quality Reporting Programs, Including the Hospital Inpatient Quality Reporting Program; specifically, provisions related to the market basket payment update, the four walls exception to clinic services in Medicaid, changes to prior authorization for outpatient services, and health and safety standards of obstetrical services in hospitals/critical access hospitals.

Client expense: Not reported · Firm income: $50,000

Rural hospital policies Rural Hospital Support Act (S. 1110) & the Assistance for Rural Community Hospitals (ARCH) Act (H.R. 6430) Graduate Medical Education (GME) funding (Resident Physician Shortage Reduction Act (S.1302, H.R.2389) Telehealth Prior Authorization Reform (Improving Seniors Timely Access to Care Act; CMS proposed Medicare Advantage rule) Medicare Physician Fee Schedule Medicaid Disproportionate Share Hospital payments (H.R.2665) Site neutral payments Medicare Dependent and Low Volume Hospital Programs

Client expense: $260,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to Medicare reimbursement for rural referral centers (RRCs), sole community hospitals (SCHs) and Medicare dependent hospitals (MDHs), including the Rural Hospital Support Act (S.1110) and the Assistance for Rural Community Hospitals Act (H.R. 6430).

Client expense: Not reported · Firm income: $70,000

Government targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE

Support for elimination of Medicaid Disproportionate Share Hospital cuts Support for increased flexibility and expansion of eligible expenses eligible for reimbursement under COVID-19 FEMA Public Assistance program Support for bolstering Medicare Graduate Medical Education program including the Resident Physician Shortage Reduction Act of 2023 (H.R.2389) Support for Assistance for Rural Community Hospitals Act (H.R. 6430) and making permanent the Medicare Dependent Hospital and enhanced Low-Volume PaymentAdjustment Support for amending Medicaid DSH Cap policy established in Section 203 of CAA of 2021 Support for continuing key flexibilities beyond COVID-19 pandemic including telehealth policies and the hospitals at home program, and Substance Use Disorder Workforce Act (H.R. 7050) Support for Improving Seniors Timely Access to Care Act Support for bolstering healthcare workforce including the Healthcare Workforce Resilience Act Opposition to proposals to cut providers including Medicare site-neutral payment reductions and policies to restrict the 340B drug pricing program Support for extenders in H.R.4366 - Consolidated Appropriations Act, 2024 Support for H.R. 2377, the Saving Access to Laboratory Services Act (SALSA) Opposition to duplicative regulatory requirements for lab developed tests in H.R. 2369, VALID Act Opposition to site-neutral cuts included in Lower Cost More Transparency Act and Bipartisan Primary Care and Health Workforce Act Opposition to H.R. 2530, Nurse Staffing Standards for Hospital Patient Safety and Quality Care Act

Client expense: $110,000 · Firm income: Not reported

Support for elimination of Medicaid Disproportionate Share Hospital cuts Support for increased flexibility and expansion of eligible expenses eligible for reimbursement under COVID-19 FEMA Public Assistance program Support for bolstering Medicare Graduate Medical Education program including the Resident Physician Shortage Reduction Act of 2023 (H.R.2389) Support for Assistance for Rural Community Hospitals Act (H.R. 6430) and making permanent the Medicare Dependent Hospital and enhanced Low-Volume PaymentAdjustment Support for amending Medicaid DSH Cap policy established in Section 203 of CAA of 2021 Support for continuing key flexibilities beyond COVID-19 pandemic including telehealth policies and the hospitals at home program, and Substance Use Disorder Workforce Act (H.R. 7050) Support for Improving Seniors Timely Access to Care Act Support for bolstering healthcare workforce including the Healthcare Workforce Resilience Act Opposition to proposals to cut providers including Medicare site-neutral payment reductions and policies to restrict the 340B drug pricing program Support for extenders in H.R.4366 - Consolidated Appropriations Act, 2024 Support for H.R. 2377, the Saving Access to Laboratory Services Act (SALSA) Opposition to duplicative regulatory requirements for lab developed tests in H.R. 2369, VALID Act Opposition to site-neutral cuts included in Lower Cost More Transparency Act and Bipartisan Primary Care and Health Workforce Act Opposition to H.R. 2530, Nurse Staffing Standards for Hospital Patient Safety and Quality Care Act

Client expense: $110,000 · Firm income: Not reported

H.R. 7513, Protecting America's Seniors Access to Care Act, all provisions; H.R. 468, Building Americas Health Care Workforce Act, all provisions; H.R. 8113, Transparency into State Directed Payments Act of 2024, all provisions; H.R. 8115, To amend title XIX of the Social Security Act to allow for the deferral or disallowance of portions of payments for certain managed care violations under Medicaid, all provisions; H.R. 1110, KEEP Telehealth Option Act, all provisions; H.R. 7711, Advancing Access to Telehealth Act, all provisions; H.R. 3432, Telemental Health Care Access Act, all provisions; H.R. 3875, the Expanded Telehealth Access Act, all provisions; H.R. 5611, Helping Ensure Access to Local Telehealth (HEALTH) Act of 2023, all provisions; H.R. 6033, Patient Education and Knowledge (SPEAK) Act of 2023, all provisions; H.R. 5541, the Temporary Reciprocity to Ensure Access to Treatment (TREAT) Act, all provisions; H.R. 7863, To require the Secretary of Health and Human Services to issue guidance on furnishing behavioral health services via telehealth to individuals with limited English proficiency under Medicare program, all provisions; H.R. 134, To amend title XVIII of the Social Security Act to remove geographic requirements and expand originating sites for telehealth services, all provisions; H.R. 8261, The Preserving Telehealth, Hospital, and Ambulance Access Act, Issues pertaining to Telehealth, Hospital at Home, and MDH-LVA; S.4350 / H.R. 8260, Hospital Inpatient Services, Modernization Act of 2024, all provisions; H.R. 8235, Rural Physician Workforce Preservation Act, all provisions; S. 2016/ H.R. 4189, The CONNECT for Health Act of 2023, Specifically telehealth waivers, geographic restrictions, originating site requirements, in person requirement behavioral health, RHCs and FQHCs access; S. 1110, the Rural Hospital Support Act, all provisions; S. 1673 / H.R. 1666, Protecting Access to Ground Ambulance Medical Services Act of 2023, all provisions; H.R. 6430, Assistance for Rural Community Hospitals (ARCH)Act, all provisions; S. 803, Save Rural Hospitals Act, all provisions; H.R. 4968, GOLD Card Act of 2023, all provisions; H.R. 3173 / S. 4532, Improving Seniors' Timely Access to Care, all provisions; H.R. 5013/S. 3503, Value in Health Care Act, all provisions; HR 2389/ S. 1302, Resident Physician Shortage Reduction Act of 2023, all provisions; Draft Bill, Graduate Medical Education Bill, Issues pertaining to proposed changes to the Medicare Graduate Medical Education program and solutions to address workforce shortages in rural areas; H.J.Res. 139 / S.J. Res 91, A joint resolution for congressional disapproval of a rule relating to "Medicare and Medicaid Programs; Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting", all provisions; HR 1565, Critical Access Hospital Relief Act of 2023, all provisions; H.R. 7623, Telehealth Modernization Act, Issues pertaining to Telehealth, Hospital at Home, Unique Health Identifier; H.R.1128, Rural Health Care Access Act of 2023, all provisions; S.1571, Rural Hospital Closure Relief Act of 2023, all provisions; S. 470 / H.R. 977, The Patient Access to Higher Quality Health Care Act, all provisions; Draft Bill, Keeping Obstetrics Local Act, all provisions;H.R.5378, Lower Costs, More Transparency Act, Issues related to site neutral payment cuts, hospital price transparency, unique health identifier, 340B Program; Centers for Medicare & Medicaid Services (CMS), FY25 proposed rule for the inpatient psychiatric facility (IPF) prospective payment system (PPS), Issues pertaining to payment policy proposals for inpatient psychiatric facilities (IPFs); Centers for Medicare & Medicaid Services (CMS), FY25 proposed rule for skilled nursing facility prospective payment system , Issues pertaining to payment policy proposals for skilled nursing facilities (SNFs); Centers for Medicare & Medicaid Services (CMS)FY25 proposed rule for inpatient rehabilitation facility prospective payment system, Issues pertaining to payment policy proposals for inpatient rehabilitation facilities (IRFs); Centers for Medicare & Medicaid Services (CMS), FY25 proposed rule Hospital Inpatient Prospective Payment Systems , Issues pertaining to payment policy proposals for acute-care hospitals; Centers for Medicare & Medicaid Services (CMS), FY25 proposed rule Long-Term Care Hospital Prospective Payment System, Issues pertaining to payment policy proposals for long term acute-care hospitals; Centers for Medicare & Medicaid Services (CMS), Transforming Episode Accountability Model (TEAM), Deadline expansion and proposed mandatory alternative payment model; Centers for Medicare & Medicaid Services (CMS), Medicare Advantage Data RFI, Issues pertaining to enforcement and accountability of MA plans, prompt payment, gold carding, Standarization, penalties, and plan oversight; Centers for Medicare & Medicaid Services (CMS); Anomalous DME Spending in MSSP, accountable care models; Centers for Medicare & Medicaid Services (CMS), Accrediting Organizations (AO's), Feedback to strengthen accrediting organizations oversight; Provider Reimbursements, Issues related to provider reimbursement, site neutral payment cuts, Medicare/Medicaid program funding, facility fees; Site Neutral Payments, for Q2 2024, Issues related to site neutral payment cuts for drug administration; Valued Based Care, for Q2 2024, Specifically on alternative payment models, MACRA reform, feedback on proposed TEAM model; Rural Hospitals, Issues pertaining to the sustainability of MDHS, CAHs, SCHs, and REHs; Physician Payments, Issues pertaining to proposed solutions to improve MACRA, alternative payment models, mental health of workforce; LTCH High Cost Outlier Threshold, Issues concerning High Cost Outlier in LTCH payment policy; Organ Transplant Model, Issues pertaining to Value Based Care; Rural Health Clinic Payments, Issues related to increasing payments for rural health clinics; Chronic Care Management, Issues pertaining to chronic care management for Medicare beneficiaries.

H.R. 7513, Protecting America's Seniors Access to Care Act, all provisions; H.R. 468, Building Americas Health Care Workforce Act, all provisions; H.R. 8113, Transparency into State Directed Payments Act of 2024, all provisions; H.R. 8115, To amend title XIX of the Social Security Act to allow for the deferral or disallowance of portions of payments for certain managed care violations under Medicaid, all provisions; H.R. 1110, KEEP Telehealth Option Act, all provisions; H.R. 7711, Advancing Access to Telehealth Act, all provisions; H.R. 3432, Telemental Health Care Access Act, all provisions; H.R. 3875, the Expanded Telehealth Access Act, all provisions; H.R. 5611, Helping Ensure Access to Local Telehealth (HEALTH) Act of 2023, all provisions; H.R. 6033, Patient Education and Knowledge (SPEAK) Act of 2023, all provisions; H.R. 5541, the Temporary Reciprocity to Ensure Access to Treatment (TREAT) Act, all provisions; H.R. 7863, To require the Secretary of Health and Human Services to issue guidance on furnishing behavioral health services via telehealth to individuals with limited English proficiency under Medicare program, all provisions; H.R. 134, To amend title XVIII of the Social Security Act to remove geographic requirements and expand originating sites for telehealth services, all provisions; H.R. 8261, The Preserving Telehealth, Hospital, and Ambulance Access Act, Issues pertaining to Telehealth, Hospital at Home, and MDH-LVA; S.4350 / H.R. 8260, Hospital Inpatient Services, Modernization Act of 2024, all provisions; H.R. 8235, Rural Physician Workforce Preservation Act, all provisions; S. 2016/ H.R. 4189, The CONNECT for Health Act of 2023, Specifically telehealth waivers, geographic restrictions, originating site requirements, in person requirement behavioral health, RHCs and FQHCs access; S. 1110, the Rural Hospital Support Act, all provisions; S. 1673 / H.R. 1666, Protecting Access to Ground Ambulance Medical Services Act of 2023, all provisions; H.R. 6430, Assistance for Rural Community Hospitals (ARCH)Act, all provisions; S. 803, Save Rural Hospitals Act, all provisions; H.R. 4968, GOLD Card Act of 2023, all provisions; H.R. 3173 / S. 4532, Improving Seniors' Timely Access to Care, all provisions; H.R. 5013/S. 3503, Value in Health Care Act, all provisions; HR 2389/ S. 1302, Resident Physician Shortage Reduction Act of 2023, all provisions; Draft Bill, Graduate Medical Education Bill, Issues pertaining to proposed changes to the Medicare Graduate Medical Education program and solutions to address workforce shortages in rural areas; H.J.Res. 139 / S.J. Res 91, A joint resolution for congressional disapproval of a rule relating to "Medicare and Medicaid Programs; Minimum Staffing Standards for Long-Term Care Facilities and Medicaid Institutional Payment Transparency Reporting", all provisions; HR 1565, Critical Access Hospital Relief Act of 2023, all provisions; H.R. 7623, Telehealth Modernization Act, Issues pertaining to Telehealth, Hospital at Home, Unique Health Identifier; H.R.1128, Rural Health Care Access Act of 2023, all provisions; S.1571, Rural Hospital Closure Relief Act of 2023, all provisions; S. 470 / H.R. 977, The Patient Access to Higher Quality Health Care Act, all provisions; Draft Bill, Keeping Obstetrics Local Act, all provisions;H.R.5378, Lower Costs, More Transparency Act, Issues related to site neutral payment cuts, hospital price transparency, unique health identifier, 340B Program; Centers for Medicare & Medicaid Services (CMS), FY25 proposed rule for the inpatient psychiatric facility (IPF) prospective payment system (PPS), Issues pertaining to payment policy proposals for inpatient psychiatric facilities (IPFs); Centers for Medicare & Medicaid Services (CMS), FY25 proposed rule for skilled nursing facility prospective payment system , Issues pertaining to payment policy proposals for skilled nursing facilities (SNFs); Centers for Medicare & Medicaid Services (CMS)FY25 proposed rule for inpatient rehabilitation facility prospective payment system, Issues pertaining to payment policy proposals for inpatient rehabilitation facilities (IRFs); Centers for Medicare & Medicaid Services (CMS), FY25 proposed rule Hospital Inpatient Prospective Payment Systems , Issues pertaining to payment policy proposals for acute-care hospitals; Centers for Medicare & Medicaid Services (CMS), FY25 proposed rule Long-Term Care Hospital Prospective Payment System, Issues pertaining to payment policy proposals for long term acute-care hospitals; Centers for Medicare & Medicaid Services (CMS), Transforming Episode Accountability Model (TEAM), Deadline expansion and proposed mandatory alternative payment model; Centers for Medicare & Medicaid Services (CMS), Medicare Advantage Data RFI, Issues pertaining to enforcement and accountability of MA plans, prompt payment, gold carding, Standarization, penalties, and plan oversight; Centers for Medicare & Medicaid Services (CMS); Anomalous DME Spending in MSSP, accountable care models; Centers for Medicare & Medicaid Services (CMS), Accrediting Organizations (AO's), Feedback to strengthen accrediting organizations oversight; Provider Reimbursements, Issues related to provider reimbursement, site neutral payment cuts, Medicare/Medicaid program funding, facility fees; Site Neutral Payments, for Q2 2024, Issues related to site neutral payment cuts for drug administration; Valued Based Care, for Q2 2024, Specifically on alternative payment models, MACRA reform, feedback on proposed TEAM model; Rural Hospitals, Issues pertaining to the sustainability of MDHS, CAHs, SCHs, and REHs; Physician Payments, Issues pertaining to proposed solutions to improve MACRA, alternative payment models, mental health of workforce; LTCH High Cost Outlier Threshold, Issues concerning High Cost Outlier in LTCH payment policy; Organ Transplant Model, Issues pertaining to Value Based Care; Rural Health Clinic Payments, Issues related to increasing payments for rural health clinics; Chronic Care Management, Issues pertaining to chronic care management for Medicare beneficiaries.

H.R. 5378 - Lower Costs, More Transparency Act - Re: Site Neutral and Hospital Price Transparency H.R. 5796/ S. 3410 - "The Protecting Rural Seniors' Access to Care Act" - Re: Skilled Nursing Facility Staffing Mandates H.R. 3173/ S.5044 - "Improving Seniors' Timely Access to Care Act" - Re: Medicare Advantage Prior Authorization provisions H.R. 6430/ S.1110 - "The Assistance for Rural Community Hospitals (ARCH) Act" - Re: Discussions around Medicare rural extenders (LVH/MDH) Payment delays and denials - Re: Medicare Advantage coverage requirements H.R. 8113 - "Transparency into State Directed Payments Act of 2024" - Re: Discussed importance of Medicaid payment adequacy Discussions around Medicaid DSH funding - Re: Medicare DSH cut delay H.R. 7623/ S. 3967 - "Telehealth Modernization Act of 2024"; H.R. 4189/ S. 2016 - "CONNECT for Health Act of 2023"; H.R. 3432/ S. 3651 - "Telemental Health Care Access Act of 2023" - Re: Telehealth flexibilities Mandatory CMMI Models - Re: Value-based Care

Client expense: $480,000 · Firm income: Not reported

Issues relating to Medicare reimbursement for rural referral centers (RRCs), sole community hospitals (SCHs) and Medicare dependent hospitals (MDHs), including the Rural Hospital Support Act (S.1110) and the Assistance for Rural Community Hospitals Act (H.R. 6430).

Client expense: Not reported · Firm income: $70,000

Government targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE

21st Century Cures Act: Establishment of Disincentives for Health Care Providers That Have Committed Information Blocking Proposed Rule - Urged CMS to refrain from finalizing the Proposed Rule. Encouraged CMS, ONC and OIG to provide additional clarity regarding several policies under consideration. Contract Year 2025 Policy and Technical Changes To The Medicare Advantage (MA Or Part C) and Medicare Prescription Drug Benefit (Part D) programs Proposed Rule - Encouraged CMS to consider the Vizient Vulnerability Index as the agency considers other potential social risk factors and urged CMS to continue monitoring patients out-of-pocket costs as formulary changes occur. Issues related to hospital and provider payment. Issues related to pharmacy benefit managers; monitoring the Modernizing and Ensuring PBM Accountability (MEPA) Act (S.2973). Lower Costs, More Transparency Act (H.R. 5378) - Opposed adoption of site-neutral payment policies for drug administration and increased fines related to price transparency requirements for hospitals. Urged Congress to redirect its focus from site-neutral payment policies to reducing administrative burdens and increasing, rather than reducing, payments for care delivery in rural areas. Medicaid Disproportionate Hospital (DSH) payment cuts - Urged Congress to avoid Medicaid Disproportionate Share Hospital (DSH) payment cuts scheduled to begin in FY 2024. Supported temporary delay of Medicaid DSH cuts in Consolidated Appropriations Act, 2024 (H.R. 4366). Medicare-supported Graduate Medical Education - Supported passage of the Resident Physician Shortage Reduction Act (H.R. 2389/S. 1302). The Medicare Dependent Hospital (MDH) program and the Low Volume Hospital Payment Adjustment (LVA) - Supported passage of the Assistance for Rural Community Hospitals (ARCH) Act (H.R 6430).

Client expense: $270,000 · Firm income: Not reported

Discussion with OMB/OIRA regarding OSHA Occupational Exposure to COVID-19 in Healthcare Settings Final Rule; Discussion with FDA Drug Shortage expert regarding Inflation Reduction Act Provisions that could impact duration of shortages; Discussion with ASPR Hospital Preparedness Program Staff about speaking at a meeting regarding HPP issues; Discussion with White House Office of Management & Budget, Centers for Medicare & Medicaid Services (CMS) - HHS FY 2024 Inpatient Prospective Payment System/Long Term Care Hospital Proposed Rule; Discussion with White House Office of Management & Budget, Centers for Medicare & Medicaid Services (CMS) - HHS FY 2024 Medicare Advantage Final Rule; Hill outreach about reducing hospital workplace violence; Hill outreach about the benefits of hospital mergers and acquisitions; Statement to the U.S. Senate Committee on Health, Education, Labor, and Pensions, Examining Health Care Workforce Shortages: Where Do We Go from Here?; Letter to the U.S. Senate Committee on Health, Education, Labor, and Pensions in response to an RFI on the drivers of health care workforce shortages; Support S.1110, Rural Hospitals Support Act, a bill to amend title XVIII of the Social Security Act to rebase the calculation of payments for sole community hospitals and Medicare-dependent hospitals, and for other purposes; Support H.R. 1110, Telehealth Option Act, a bill to direct the Secretary of Health and Human Services, the Medicare Payment Advisory Commission, and the Medicaid and CHIP Payment and Access Commission to conduct studies and report to Congress on actions taken to expand access to telehealth services under the Medicare, Medicaid, and Childrens Health Insurance programs during the COVID-19 emergency; Feedback on the Connect for Health Act; AHA provided feedback on the creating opportunities new for necessary and effective care technologies (CONNECT) Act; False Claims Act Case AHA Provides Statement for House Hearing on Price Transparency, Competition; Oppose H.R.977/S.470 Patient Access Higher Quality Health Care Act, a bill to repeal changes made by health care reform laws to the Medicare exception to the prohibition on certain physician referrals for hospitals, and for other purposes; Support S.940, The Rural America Health Corps Act A bill to establish a demonstration program to provide payments on eligible loans for individuals who are eligible for the National Health Service Corps Loan Repayment Program; Support the Conrad State 30 and Physician Access Reauthorization Act that would allow international doctors trained in the United States to remain in the country if they practice in areas experiencing medical shortages; Letter to CMS regarding intent to issue staffing mandates for nursing homes and urged CMS and policy makers to focus on efforts that will bolster our workforce; Support HR 2389/ S 1302, Resident Physician Shortage Reduction Act of 2023, a bill to amend title XVIII of the Social Security Act to provide for the distribution of additional residency positions; Support HR 2411/ S 1150, National Nursing Workforce Center Act of 2023, a bill to amend the Public Health Service Act to support and stabilize the existing nursing workforce, establish programs to increase the number of nurses; Support HR 2534, Preserving Rules Ordered for The Entities Covered Through 340B Act of 2023 or the PROTECT 340B Act of 2023, a bill to amend title XXVII of the Public Health Service Act to ensure the equitable treatment of covered entities and pharmacies participating in the 340B drug discount program; Support HR 2559, Strengthening Community Care Act of 2023, a bill to extend funding for community health centers and the National Health Service Corp; Statement to the House Education and the Workforce Subcommittee on Health, Employment, Labor, and Pensions hearing titled, Competition and Transparency: The Pathway Forward for a Stronger Health Care Market highlighting that mergers and acquisitions can be a helpful tool for many hospitals and pushing back against site-neutral payment policies; Letter urging Congress to continue to protect this critical program and oppose efforts to cut its benefits, which would result in reduced access to quality care for the patients and communities served by 340B hospitals; Statement to Subcommittee on Health of the Committee on Energy and Commerce on its hearing Examining Existing Federal Programs to Build a Stronger Health Workforce and Improve Primary Care; Support S 1447, Bipartisan Solution to Cyclical Violence Act of 2023, a bill to amend the Public Health Service Act to establish a grant program supporting trauma center violence intervention and violence prevention programs, and for other purposes; Support HR 3046/ S 1403, Medical Student Education Authorization Act of 2023, a bill to amend the Public Health Service Act to establish a grant program to award grants to accredited public institutions of higher education, and for other purposes; Concerns with HR 2691, Transparent Prices Required to Inform Consumer and Employers Act or the Transparent PRICE Act, a bill to promote hospital and insurer price transparency; Letter strongly opposing the draft bills, which would create additional site-neutral payment cuts and threaten access to care, especially in rural and other vulnerable communities; Comment letter to the Office of Civil Rights on its HIPAA Privacy Rule to Support Reproductive Health Care Privacy and concerns the guidance is too broad and will result in significant adverse consequences for hospitals, patients and the public at large; Statement to SFC for the hearing on Consolidation and Corporate Ownership in Health Care: Trends and Impacts on Access, Quality, and Costs; Comment letters to CMS on their Inpatient and Long-term Care Facility Prospective Payment System FY 2024 proposed rule; Letter to reauthorize key programs within the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act of 2018, supporting policies that will reduce barriers to receiving and administering behavioral health care by improving payment policies, reducing unnecessary regulatory and administrative burden, and strengthening the behavioral health workforce; Comment letter on the Environmental Protection Agencys (EPA) proposed standards for the use of ethylene oxide (EtO) to sterilize medical devices urge caution and thoughtfulness in EPAs approach to avoid disrupting health care delivery through the unintentional fracturing of the already fragile medical device supply chain; Comment on Energy and Commerce Committee Chair Rodgers drug shortages discussion draft; Support S. 2364 Mapping Americas Pharmaceutical Supply Act A bill to map the United States pharmaceutical supply chain and use data analytics to identify supply chain vulnerabilities and other national security threats; Support S. 2510 RAPID Reserve Act A bill to improve supply chain resiliency for critical drug products with vulnerable supply chains and ensure that reserves of critical drugs and active pharmaceutical ingredients are maintained to prevent supply disruptions in the event of drug shortages or public health emergencies; Support S. 1961, Pharmaceutical Supply Chain Risk Assessment Act of 2023, A bill to require an interagency risk assessment of the pharmaceutical supply chain to identify and mitigate health and national security risks, and for other purposes; support the Drug Shortage Prevention Act that will help pave the way for additional improvements to the U.S. drug supply chain, which will, in turn, improve patient access and care; Support S.1636/H.R. 3440 Protecting Rural Telehealth Access Act A bill to amend title XVIII of the Social Security Act to protect access to telehealth services under the Medicare program. Drug Shortages RFI Letter to the U.S. Senate Committee on Finance in response to a Request For Information on drug shortages; Support H.R. 4713 Rural Hospital Technical Assistance Program Act A letter to support HR 4713, the Rural Hospital Technical Assistant Program Act. A bill to make permanent a program that provides technical assistance for rural hospitals to help prevent closures; Verbal Support Train More Nurse Act, It instructs HHS and DOL to conduct a joint review of all grant programs supporting the nursing workforce and coming up with recommendations to Congress within a year on how to change the programs to increase nurse faculty, provide pathways for those who want to become nurse faculty, and increase the nursing pipeline for both RNs and LPNs; Support H.R.2412 Helping Kids Cope Act To amend the Public Health Service Act to authorize grants to increase national capacity to provide pediatric behavioral health services at childrens hospitals and through community-based providers to improve childrens access to care; and to authorize grants to begin to address large numbers of children boarding in emergency departments, to support the pediatric behavioral health workforce, and for other purposes; Meeting with OMB to discuss Proposed Minimum Staffing Requirements for Long-term Care Facilities; Meeting with OMB to discuss FY 2024 IPPS and LTCH Final Rule; Meeting with Senate Finance Committee regarding the FY 2024 LTCH Final Rule; A letter to comment on ways to improve access to care in rural and underserved areas ensuring that Americans in these rural and underserved areas have high-quality, affordable health care; Support S. 2016/ H.R. 4189, CONNECT for Health Act of 2023, a bill to support to amend title XVIII of the Social Security Act to expand access to telehealth services, and for other purposes; A letter to the Department of Veterans Affairs (VA) expressing significant concerns about Cotivitis audit and appeals process, including its inadequate appeals procedures, the scope of audits being performed and the untenable timelines that are being executed; Support S. 3211/ H.R. 6205, Healthcare Workforce Resilience Act, a bill to support Healthcare Workforce Resilience Act to enhance our Nations nurse and physician workforce by recapturing unused immigrant visas; Support for Reauthorization of PAPHA, The Pandemic and All-Hazards Preparedness Act (PAHPA), To amend the Public Health Service Act to reauthorize certain programs with respect to public health security and all-hazards preparedness and response related to the Administration for Strategic Preparedness and Response and certain programs with respect to public health security and all-hazards preparedness and response related to the Centers for Disease Control and Prevention, and for other purposes; Support H.R. 6430, Rural Community Hospitals (ARCH) Act, a bill to support the Assistance for Rural Community Hospitals (ARCH) Act; To support small rural hospitals for which Medicare patients make up a significant percentage of inpatient days or discharges, Congress established the Medicare- dependent Hospital (MDH) program in 1987, allowing eligible hospitals to receive the sum of their prospective payment system (PPS) payment rate, plus three- quarters of the amount by which their cost per discharge exceeds the PPS rate; Support H.R. 4531/ S.3393, Patients and Communities Reauthorization Act, a bill to reauthorize certain programs that provide for opioid use disorder prevention, recovery, and treatment, and for other purposes; A letter to the FDA on its laboratory developed tests (LDTs) proposed rule urging the agency to not apply its device regulations to hospital and health system LDTs because they are not devices; rather, they are diagnostic tools developed and used in the context of patient care. Instead, we urged the FDA to continue to apply its enforcement discretion to hospital and health system LDTs; Submit Statement to the Committee on Energy and Commerce Subcommittee on Health hearing, Supporting Access to Long-Term Services and Supports: An Examination of the Impacts of Proposed Regulations on Workforce and Access to Care to share the hospital fields comments on proposed regulations for minimum staffing standards for LTC facilities and their potential impact on access to care; Concern H.R. 5378 Lower Costs, More Transparency Act, A bill to promotes price transparency in the health care sector, and for other purposes; Hill Briefing on SAVE Act, Support S. 2768 / H.R. 2584, The Safety from Violence for Healthcare Employees (SAVE) Act, A bill to protect hospital personnel from violence, and for other purposes; Health Care Spending in the United States: Unsustainable for Patients, Employers, and Taxpayers; Statement to the House Committee on Energy and Commerce Subcommittee on Health regarding the topic of national health expenditures, The Independent Dispute Resolution Process (IDR), To comment on the proposed rule related to the operations of the Independent Dispute Resolution Process (IDR) established by the No Surprises Act (NSA); Examining Chronic Drug Shortages in the United States, Statement to the House Committee on Ways and Means regarding the important topic of drug shortages in the United States; Support H.R. 6205 / S. 3211, Healthcare Workforce Resilience Act, A bill to reauthorize title II of the Higher Education Act of 1965, and for other purposes; H.R. 7513; Protecting Americas Seniors Access to Care, Statement to the House Committee on Ways and Means regarding Protecting Americas Seniors Access to Care to prohibit the Secretary of Health and Human Services from finalizing a proposed rule regarding minimum staffing for nursing facilities, and to establish an advisory panel on the skilled nursing facility workforce; Enhancing Access to Care at Home in Rural and Underserved Communities, Statement to the House Committee on Ways and Means on how telehealth flexibilities, the hospital-at-home (H@H) program and home health agencies have expanded access to care for patients in their homes and the need for these programs to continue; The recent cyberattack on Change Healthcare, Letter to House and Senate leadership requesting assistance for hospitals impacted by the cyberattack; The recent cyberattack on Change Healthcare, Letter to Senate Finance Committee leadership to share concerns regarding the Administrations proposal to penalize hospitals that do not meet certain cybersecurity requirements; Support S. 3779 / H.R. 7265, Child Suicide Prevention and Lethal Means Safety Act, A bill authorizing the Secretary of Health and Human Services to award grants to establish or expand programs to implement evidence-aligned practices in health care settings for the purpose of reducing the suicide rates of covered individuals, and for other purposes; Evaluating Approaches to Diagnostic Test Regulation and the Impact of FDAs Proposed Rule.", Statement to the House Committee on Energy and Commerce Subcommittee on Health on the impact of the Food and Drug Administrations (FDA) proposed regulation of diagnostic tests; Senate RFI on the SUSTAIN 340B Act Draft, A letter to provide feedback on the Supporting Underserved and Strengthening Transparency, Accountability, and Integrity Now and for the Future of (SUSTAIN) 340B Act bipartisan discussion draft and accompanying request for information on the 340B Drug Pricing Program; Access to Health Care in America: Ensuring Resilient Emergency Medical Care, Statement to the House Committee on Ways and Means on access to emergency medical services in rural areas; Support H.R. 7623, Telehealth Modernization Act, A bill to amend title XVIII of the Social Security Act to make permanent certain telehealth flexibilities under the Medicare program; House RFI on strengthening ERISA, A letter to provide feedback on an RFI from the House Education and Workforce Committee on ways to strengthen and improve ERISA, Addressing drug shortagesAHAs statement for record to Ways and Means committee hearing on Examining Chronic Drug Shortages in the United States, Statement commenting on the impact of the FDAs proposed regulation of laboratory developed tests (LDTs), AHAs statement for the record to Energy and Commerce Subcommittee on Health on "Evaluating Approaches to Diagnostic Test Regulation and the Impact of FDAs Proposed Rule.", Response to RFI on oversight and regulation of LDTs, Response to Sen. Cassidy, Ranking Member of HELP Committee on his RFI seeking feedback on the FDAs proposed regulation of hospital LDTs, OMB meeting, including FDA officials, on the FDAs rulemaking on the regulation of hospital LDTs as medical devicesOMB/FDA; Support S 3679 / H.R. 7153, Dr. Lorna Breen Health Care Provider Protection Reauthorization Act, A bill to reauthorize the Dr. Lorna Breen Health Care Provider Protection Act, and for other purposes, Support S. 1110, the Rural Hospital Support Act, A bill to amend title XVIII of the Social Security Act to rebase the calculation of payments for sole community hospitals and Medicare-dependent hospitals, and for other purposes; Support HR 1565, Critical Access Hospital Relief Act of 2023, A bill to amend title XVIII of the Social Security Act to remove the 96-hour physician certification requirement for inpatient critical access hospital services.

Support for elimination of Medicaid Disproportionate Share Hospital cuts Support for increased flexibility and expansion of eligible expenses eligible for reimbursement under COVID-19 FEMA Public Assistance program Support for bolstering Medicare Graduate Medical Education program including the Resident Physician Shortage Reduction Act of 2023 (H.R.2389) Support for Assistance for Rural Community Hospitals Act (H.R. 6430) and making permanent the Medicare Dependent Hospital and enhanced Low-Volume PaymentAdjustment Support for amending Medicaid DSH Cap policy established in Section 203 of CAA of 2021 Support for continuing key flexibilities beyond COVID-19 pandemic including telehealth policies and the hospitals at home program, and Substance Use Disorder Workforce Act (H.R. 7050) Support for Improving Seniors Timely Access to Care Act Support for bolstering healthcare workforce including the Healthcare Workforce Resilience Act Opposition to proposals to cut providers including Medicare site-neutral payment reductions and policies to restrict the 340B drug pricing program Support for extenders in H.R.4366 - Consolidated Appropriations Act, 2024 Support for H.R. 2377, the Saving Access to Laboratory Services Act (SALSA) Opposition to duplicative regulatory requirements for lab developed tests in H.R. 2369, VALID Act Opposition to site-neutral cuts included in Lower Cost More Transparency Act and Bipartisan Primary Care and Health Workforce Act Opposition to H.R. 2530, Nurse Staffing Standards for Hospital Patient Safety and Quality Care Act

Client expense: $100,000 · Firm income: Not reported

H.R. 5378 - Lower Costs, More Transparency Act - Re: Site Neutral and Hospital Price Transparency H.R. 5796/ S. 3410 - "The Protecting Rural Seniors' Access to Care Act" - Re: Skilled Nursing Facility Staffing Mandates H.R. 3173/ S.5044 - "Improving Seniors' Timely Access to Care Act" - Re: Medicare Advantage Prior Authorization H.R. 4968 - The Gold Card Act of 2023 - Re: Reforms to the Medicare Prior Authorization Process H.R. 6430/ S.1110 - "The Assistance for Rural Community Hospitals (ARCH) Act" - Re: Making permanent rural payment programs (LVH/MDH) Re: Two-Midnight Rule - Medicare Advantage coverage requirements Re: Medicaid State Directed Payments Providing for the concurrence by the House in the Senate amendment to H.R. 4366, with an amendment (2024 Government Funding Bill) - Re: Medicare DSH cut delay H.R. 7623/ S. 3967 - "Telehealth Modernization Act of 2024"; H.R. 4189/ S. 2016 - "CONNECT for Health Act of 2023"; H.R. 3432/ S. 3651 - "Telemental Health Care Access Act of 2023" - Re: Extending telehealth provisions

Client expense: $650,000 · Firm income: Not reported

Issues relating to Medicare reimbursement for rural referral centers (RRCs), sole community hospitals (SCHs) and Medicare dependent hospitals (MDHs), including the Rural Hospital Support Act (S.1110) and the Assistance for Rural Community Hospitals Act (H.R. 6430).

Client expense: Not reported · Firm income: $60,000

Government targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE

S.2840 - Bipartisan Primary Care and Health Workforce Act - Re: Facility fees; contracting practices; price transparency H.R. 5378 - Lower Costs, More Transparency Act - Re: Site-neutral & hospital price transparency H.R. 2665/S. 3430 - Supporting Safety Net Hospitals Act, Better Mental Health Care Lower-Cost Drugs and Extenders Act of 2023 - Re: elimination of DSH cuts Improving Seniors' Timely Access to Care Act - Re: reforms to the Medicare Prior Authorization Process H.R. 4968 - The Gold Card Act of 2023 - Re: Reforms to the Medicare Prior Authorization Process H.R. 977 / S. 470 - Patient Access to Higher Quality Health Care Act of 2023 - Re: changing current law limiting self-referral to physician-owned hospitals S.803/ H.R. 3635 - Save Rural Hospitals Act of 2023 - Re: Area Wage Index floor S.1110/H.R. 6430 - Rural Hospital Support Act, Assistance for Rural Community Hospitals (ARCH) Act - Re: making permanent rural payment programs (LVH/MDH) IMD Exclusion Support Medicaid Directed Payment programs Support accountability and transparency in Medicare Advantage

Client expense: $543,000 · Firm income: Not reported

Discussion with OMB/OIRA regarding OSHA Occupational Exposure to COVID-19 in Healthcare Settings Final Rule; Discussion with FDA Drug Shortage expert regarding Inflation Reduction Act Provisions that could impact duration of shortages; Discussion with ASPR Hospital Preparedness Program Staff about speaking at a meeting regarding HPP issues; Discussion with White House Office of Management & Budget, Centers for Medicare & Medicaid Services (CMS) - HHS FY 2024 Inpatient Prospective Payment System/Long Term Care Hospital Proposed Rule; Discussion with White House Office of Management & Budget, Centers for Medicare & Medicaid Services (CMS) - HHS FY 2024 Medicare Advantage Final Rule; Hill outreach about reducing hospital workplace violence; Hill outreach about the benefits of hospital mergers and acquisitions; Hill outreach about the anticompetitive behaviors of travel nurse staffing agencies; Statement to the U.S. Senate Committee on Health, Education, Labor, and Pensions, Examining Health Care Workforce Shortages: Where Do We Go from Here?; Letter to the U.S. Senate Committee on Health, Education, Labor, and Pensions in response to an Request For Information on the reauthorization of the Pandemic and All-Hazards Preparedness Act; Letter to the U.S. Senate Committee on Health, Education, Labor, and Pensions in response to an RFI on the drivers of health care workforce shortages; Support S.1110, Rural Hospitals Support Act, a bill to amend title XVIII of the Social Security Act to rebase the calculation of payments for sole community hospitals and Medicare-dependent hospitals, and for other purposes; Support H.R. 1110Telehealth Option Act, a bill to direct the Secretary of Health and Human Services, the Medicare Payment Advisory Commission, and the Medicaid and CHIP Payment and Access Commission to conduct studies and report to Congress on actions taken to expand access to telehealth services under the Medicare, Medicaid, and Childrens Health Insurance programs during the COVID-19 emergency; Feedback on the Connect for Health Act; AHA provided feedback on the creating opportunities new for necessary and effective care technologies (CONNECT) Act; False Claims Act Case AHA Provides Statement for House Hearing on Price Transparency, Competition; Oppose H.R.977/S.470 Patient Access Higher Quality Health Care Act, a bill to repeal changes made by health care reform laws to the Medicare exception to the prohibition on certain physician referrals for hospitals, and for other purposes; Support S.940, The Rural America Health Corps Act A bill to establish a demonstration program to provide payments on eligible loans for individuals who are eligible for the National Health Service Corps Loan Repayment Program; Support the Conrad State 30 and Physician Access Reauthorization Act that would allow international doctors trained in the United States to remain in the country if they practice in areas experiencing medical shortages; Letter to CMS regarding intent to issue staffing mandates for nursing homes and urged CMS and policy makers to focus on efforts that will bolster our workforce; Support HR 2389/ S 1302, Resident Physician Shortage Reduction Act of 2023, a bill to amend title XVIII of the Social Security Act to provide for the distribution of additional residency positions; Support HR 2411/ S 1150, National Nursing Workforce Center Act of 2023, a bill to amend the Public Health Service Act to support and stabilize the existing nursing workforce, establish programs to increase the number of nurses; Support HR 2534, Preserving Rules Ordered for The Entities Covered Through 340B Act of 2023 or the PROTECT 340B Act of 2023, a bill to amend title XXVII of the Public Health Service Act to ensure the equitable treatment of covered entities and pharmacies participating in the 340B drug discount program; Support HR 2559, Strengthening Community Care Act of 2023, a bill to extend funding for community health centers and the National Health Service Corp; Support HR 2584/S.2768, Safety From Violence for Healthcare Employees Act or the SAVE Act, a bill to protect hospital personnel from violence, and for other purpose; Statement to the House Education and the Workforce Subcommittee on Health, Employment, Labor, and Pensions hearing titled, Competition and Transparency: The Pathway Forward for a Stronger Health Care Market highlighting that mergers and acquisitions can be a helpful tool for many hospitals and pushing back against site-neutral payment policies; Letter urging Congress to continue to protect this critical program and oppose efforts to cut its benefits, which would result in reduced access to quality care for the patients and communities served by 340B hospitals; Statement to Subcommittee on Health of the Committee on Energy and Commerce on its hearing Examining Existing Federal Programs to Build a Stronger Health Workforce and Improve Primary Care; Support S 1447, Bipartisan Solution to Cyclical Violence Act of 2023, a bill to amend the Public Health Service Act to establish a grant program supporting trauma center violence intervention and violence prevention programs, and for other purposes; Support HR 3046/ S 1403, Medical Student Education Authorization Act of 2023, a bill to amend the Public Health Service Act to establish a grant program to award grants to accredited public institutions of higher education, and for other purposes; Concerns with HR 2691, Transparent Prices Required to Inform Consumer and Employers Act or the Transparent PRICE Act, a bill to promote hospital and insurer price transparency; Letter strongly opposing the draft bills, which would create additional site-neutral payment cuts and threaten access to care, especially in rural and other vulnerable communities; Comment letter to the Office of Civil Rights on its HIPAA Privacy Rule to Support Reproductive Health Care Privacy and concerns the guidance is too broad and will result in significant adverse consequences for hospitals, patients and the public at large; Statement to SFC for the hearing on Consolidation and Corporate Ownership in Health Care: Trends and Impacts on Access, Quality, and Costs; Comment letters to CMS on their Inpatient and Long-term Care Facility Prospective Payment System FY 2024 proposed rule; Letter to reauthorize key programs within the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act of 2018, we encourage you to consider policies that will reduce barriers to receiving and administering behavioral health care by improving payment policies, reducing unnecessary regulatory and administrative burden, and strengthening the behavioral health workforce; Comment letter on the Environmental Protection Agencys (EPA) proposed standards for the use of ethylene oxide (EtO) to sterilize medical devices urge caution and thoughtfulness in EPAs approach to avoid disrupting health care delivery through the unintentional fracturing of the already fragile medical device supply chain; Hill briefing, Site-neutral Payment Proposals Would Jeopardize Access to Care for Patients and Communities; Comment on Energy and Commerce Committee Chair Rodgers drug shortages discussion draft; Support S. 2364 Mapping Americas Pharmaceutical Supply Act A bill to map the United States pharmaceutical supply chain and use data analytics to identify supply chain vulnerabilities and other national security threats; Support S. 2510 RAPID Reserve Act A bill to improve supply chain resiliency for critical drug products with vulnerable supply chains and ensure that reserves of critical drugs and active pharmaceutical ingredients are maintained to prevent supply disruptions in the event of drug shortages or public health emergencies; Support S. 1961Pharmaceutical Supply Chain Risk Assessment Act of 2023A bill to require an interagency risk assessment of the pharmaceutical supply chain to identify and mitigate health and national security risks, and for other purposes; Drug Shortage Prevention Act Letter to express support for the Drug Shortage Prevention Act that will help pave the way for additional improvements to the U.S. drug supply chain, which will, in turn, improve patient access and care; Bipartisan request for information on the critically important 340B Drug Pricing Program Letter on the savings 340B hospitals achieve through purchasing certain outpatient drugs at a discount allow them to provide a range of programs and services that directly benefit their patients; Support S.1636/H.R. 3440 Protecting Rural Telehealth Access Act A bill to amend title XVIII of the Social Security Act to protect access to telehealth services under the Medicare program. Drug Shortages RFI Letter to the U.S. Senate Committee on Energy and Commerce and Finance in response to a Request For Information on drug shortages; Support H.R. 4713 Rural Hospital Technical Assistance Program Act A letter to support HR 4713, the Rural Hospital Technical Assistant Program Act. A bill to make permanent a program that provides technical assistance for rural hospitals to help prevent closures; Verbal Support Train More Nurse Act It instructs HHS and DOL to conduct a joint review of all grant programs supporting the nursing workforce and coming up with recommendations to Congress within a year on how to change the programs to increase nurse faculty, provide pathways for those who want to become nurse faculty, and increase the nursing pipeline for both RNs and LPNs; Support H.R.2412 Helping Kids Cope Act To amend the Public Health Service Act to authorize grants to increase national capacity to provide pediatric behavioral health services at childrens hospitals and through community-based providers to improve childrens access to care; and to authorize grants to begin to address large numbers of children boarding in emergency departments, to support the pediatric behavioral health workforce, and for other purposes; Meeting with OMB to discuss Proposed Minimum Staffing Requirements for Long-term Care Facilities; Meeting with OMB to discuss FY 2024 IPPS and LTCH Final Rule; Meeting with Senate Finance Committee regarding the FY 2024 LTCH Final Rule; A letter to comment on ways to improve access to care in rural and underserved areas ensuring that Americans in these rural and underserved areas have high-quality, affordable health care; Support S. 2016/ H.R. 4189, CONNECT for Health Act of 2023, a bill to support to amend title XVIII of the Social Security Act to expand access to telehealth services, and for other purposes; A letter to the Department of Veterans Affairs (VA) expressing significant concerns about Cotivitis audit and appeals process, including its inadequate appeals procedures, the scope of audits being performed and the untenable timelines that are being executed; Support S. 3211/ H.R. 6205, Healthcare Workforce Resilience Act, a bill to support Healthcare Workforce Resilience Act to enhance our Nations nurse and physician workforce by recapturing unused immigrant visas; Support for Reauthorization of PAPHA, The Pandemic and All-Hazards Preparedness Act (PAHPA), To amend the Public Health Service Act to reauthorize certain programs with respect to public health security and all-hazards preparedness and response related to the Administration for Strategic Preparedness and Response and certain programs with respect to public health security and all-hazards preparedness and response related to the Centers for Disease Control and Prevention, and for other purposes; Support H.R. 6430, Rural Community Hospitals (ARCH) Act, a bill to support the Assistance for Rural Community Hospitals (ARCH) Act; To support small rural hospitals for which Medicare patients make up a significant percentage of inpatient days or discharges, Congress established the Medicare- dependent Hospital (MDH) program in 1987, allowing eligible hospitals to receive the sum of their prospective payment system (PPS) payment rate, plus three- quarters of the amount by which their cost per discharge exceeds the PPS rate; Support H.R. 4531/ S.3393, Patients and Communities Reauthorization Act, a bill to reauthorize certain programs that provide for opioid use disorder prevention, recovery, and treatment, and for other purposes; A letter to the FDA on its laboratory developed tests (LDTs) proposed rule urging the agency to not apply its device regulations to hospital and health system LDTs because they are not devices; rather, they are diagnostic tools developed and used in the context of patient care. Instead, we urged the FDA to continue to apply its enforcement discretion to hospital and health system LDTs; Submit Statement to the Committee on Energy and Commerce Subcommittee on Health hearing, Supporting Access to Long-Term Services and Supports: An Examination of the Impacts of Proposed Regulations on Workforce and Access to Care to share the hospital fields comments on proposed regulations for minimum staffing standards for LTC facilities and their potential impact on access to care.

Issues relating to Medicare reimbursement for rural referral centers (RRCs), sole community hospitals (SCHs) and Medicare dependent hospitals (MDHs), including the Rural Hospital Support Act (S.1110) and the Assistance for Rural Community Hospitals Act (H.R. 6430).

Client expense: Not reported · Firm income: $60,000

Government targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE