How to read the money
Income and expense are whole-filing amounts associated with this lobbyist, not personal compensation or an allocated share.
No topic inference: each bill number appears in source LDA issue text assigned to this lobbyist.
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. Commented on the following proposed rules out of CMS: -CY 2025 Home Health Prospective Payment System Proposed Rule Fact Sheet (CMS-1803-P) -CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS 1809-P) -CY 2025 Medicare Physician Fee Schedule Proposed Rule (CMS-1807-P)-Medicare Shared Savings Program Proposals. Sent a letter to the following offices in support of the bills listed below. -Reps. Bilirakis, Buchanan, Castor, Donalds, Dunn, Franklin, Frost, Lee, Luna, Soto, Steube -Sens. Rubio and Scott -Legislation: HR 4286, HR 6693, HR 4363, S 2213, HR 4531, HR 2412, HR 7742, S 3756
Specific issues are shown only where the LDA source assigned them to this lobbyist. Targets apply to the associated filing.
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2026 · third_quarter · Q3
Advocated for protection of the existing 340B drug pricing program and concerns around a rebate model at HRSA + general preservation of the 340B drug pricing program. Also discussed the concern around exclusion of section 1115 approved uncompensated care pool "waiver days" (low income pool days in Florida).
Opposed 340B rebate models and other policies to add burden and compliance to the 340B drug pricing program. Advocated against codification of a variety of price transparency provisions in the Patients Deserve Price Tags Act that exist in rule but will not meaningfully address healthcare affordability. Submitted comment letter on the Outpatient Prospective Payment System to CMS with concerns around site neutral reimbursement, 340B payment reductions, and 340B remedy clawback escalation to 3.0% annually.
Source: Senate LDA
Increasing Access to Lung Cancer Screening Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. Commented on the following proposed rules out of CMS: -CY 2025 Home Health Prospective Payment System Proposed Rule Fact Sheet (CMS-1803-P) -CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS 1809-P) -CY 2025 Medicare Physician Fee Schedule Proposed Rule (CMS-1807-P)-Medicare Shared Savings Program Proposals. Sent a letter to the following offices in support of the bills listed below. -Reps. Bilirakis, Buchanan, Castor, Donalds, Dunn, Franklin, Frost, Lee, Luna, Soto, Steube -Sens. Rubio and Scott -Legislation: HR 4286, HR 6693, HR 4363, S 2213, HR 4531, HR 2412, HR 7742, S 3756
Comprehensive Cancer Survivorship Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. Commented on the following proposed rules out of CMS: -CY 2025 Home Health Prospective Payment System Proposed Rule Fact Sheet (CMS-1803-P) -CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS 1809-P) -CY 2025 Medicare Physician Fee Schedule Proposed Rule (CMS-1807-P)-Medicare Shared Savings Program Proposals. Sent a letter to the following offices in support of the bills listed below. -Reps. Bilirakis, Buchanan, Castor, Donalds, Dunn, Franklin, Frost, Lee, Luna, Soto, Steube -Sens. Rubio and Scott -Legislation: HR 4286, HR 6693, HR 4363, S 2213, HR 4531, HR 2412, HR 7742, S 3756
Support for Patients and Communities Reauthorization Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. Commented on the following proposed rules out of CMS: -CY 2025 Home Health Prospective Payment System Proposed Rule Fact Sheet (CMS-1803-P) -CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS 1809-P) -CY 2025 Medicare Physician Fee Schedule Proposed Rule (CMS-1807-P)-Medicare Shared Savings Program Proposals. Sent a letter to the following offices in support of the bills listed below. -Reps. Bilirakis, Buchanan, Castor, Donalds, Dunn, Franklin, Frost, Lee, Luna, Soto, Steube -Sens. Rubio and Scott -Legislation: HR 4286, HR 6693, HR 4363, S 2213, HR 4531, HR 2412, HR 7742, S 3756
Lower Costs, More Transparency Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package.
Lower Costs, More Transparency Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated against 340B oversight and transparency provisions that would result in cuts to the program and block savings from benefiting patients in need. Advocated against potential CRAs for the Mental Health Parity and Equity Rule. Advocated for greater scrutiny around parity and prior authorization issues in mental health care. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package. Advocated for the inclusion of the SUPPORT Act, Preventing Maternal Deaths Act, PREEMIE Act, and extension of telehealth flexibilities in year end healthcare package.
Lower Costs, More Transparency Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package.
Lower Costs, More Transparency Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package.
Lung Cancer Screening and Prevention Act of 2023
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. Commented on the following proposed rules out of CMS: -CY 2025 Home Health Prospective Payment System Proposed Rule Fact Sheet (CMS-1803-P) -CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS 1809-P) -CY 2025 Medicare Physician Fee Schedule Proposed Rule (CMS-1807-P)-Medicare Shared Savings Program Proposals. Sent a letter to the following offices in support of the bills listed below. -Reps. Bilirakis, Buchanan, Castor, Donalds, Dunn, Franklin, Frost, Lee, Luna, Soto, Steube -Sens. Rubio and Scott -Legislation: HR 4286, HR 6693, HR 4363, S 2213, HR 4531, HR 2412, HR 7742, S 3756
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. We also discussed with Cong. Soto, Wenstrup, staff of Rep. Blumenaeur, Senate Finance Majority staff.
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. Commented on the following proposed rules out of CMS: -CY 2025 Home Health Prospective Payment System Proposed Rule Fact Sheet (CMS-1803-P) -CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS 1809-P) -CY 2025 Medicare Physician Fee Schedule Proposed Rule (CMS-1807-P)-Medicare Shared Savings Program Proposals. Sent a letter to the following offices in support of the bills listed below. -Reps. Bilirakis, Buchanan, Castor, Donalds, Dunn, Franklin, Frost, Lee, Luna, Soto, Steube -Sens. Rubio and Scott -Legislation: HR 4286, HR 6693, HR 4363, S 2213, HR 4531, HR 2412, HR 7742, S 3756
Met with new staff in Congresswoman Laurel Lees district office to discuss general healthcare issues in district. This included issues with the 340B drug pricing program and labor issues, specifically the SAVE Act S. 2768 that she cosponsors. Also discussed new facilities opening in the district. Met with Congresswoman Kathy Castor in a group and discussed access issues, specifically medicaid disenrollment in Florida and our support of Florida's 1115 waiver application for CHIP coverage for up to 300% of the FPL. Continued conversations and advocacy with Congressman Bilirakis office to discuss 340B drug pricing program on the aforementioned FY 24 IPPS rule policy pertaining to Medicare DSH calculation. Worked with Congressman Bilirakis' office to push for inclusion in a healthcare package. Also worked on a similar solution to extend 340B eligibility for providers eligible as of 1/1/2020 to waive DSH eligibility requirements for two years. Communicated with Senator Rubio and Congressman Bilirakis' offices in support of this proposal. Met with Senate Finance Majority and House Ways and Means Minority staff to advocate for the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act.
Lobbied in favor of legislative package that would patch the physician fee schedule conversion factor rate cut with a 2.5% patch. Additionally to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act.
Met with new staff in Congresswoman Laurel Lees district office to discuss general healthcare issues in district. This included issues with the 340B drug pricing program and labor issues, specifically the SAVE Act S. 2768 that she cosponsors. Also discussed new facilities opening in the district. Met with Congresswoman Kathy Castor in a group and discussed access issues, specifically medicaid disenrollment in Florida and our support of Florida's 1115 waiver application for CHIP coverage for up to 300% of the FPL. Continued conversations and advocacy with Congressman Bilirakis office to discuss 340B drug pricing program on the aforementioned FY 24 IPPS rule policy pertaining to Medicare DSH calculation. Worked with Congressman Bilirakis' office to push for inclusion in a healthcare package. Also worked on a similar solution to extend 340B eligibility for providers eligible as of 1/1/2020 to waive DSH eligibility requirements for two years. Communicated with Senator Rubio and Congressman Bilirakis' offices in support of this proposal. Met with Senate Finance Majority and House Ways and Means Minority staff to advocate for the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act.
Comprehensive Cancer Survivorship Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. Commented on the following proposed rules out of CMS: -CY 2025 Home Health Prospective Payment System Proposed Rule Fact Sheet (CMS-1803-P) -CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS 1809-P) -CY 2025 Medicare Physician Fee Schedule Proposed Rule (CMS-1807-P)-Medicare Shared Savings Program Proposals. Sent a letter to the following offices in support of the bills listed below. -Reps. Bilirakis, Buchanan, Castor, Donalds, Dunn, Franklin, Frost, Lee, Luna, Soto, Steube -Sens. Rubio and Scott -Legislation: HR 4286, HR 6693, HR 4363, S 2213, HR 4531, HR 2412, HR 7742, S 3756
Met with new staff in Congresswoman Laurel Lees district office to discuss general healthcare issues in district. This included issues with the 340B drug pricing program and labor issues, specifically the SAVE Act S. 2768 that she cosponsors. Also discussed new facilities opening in the district. Met with Congresswoman Kathy Castor in a group and discussed access issues, specifically medicaid disenrollment in Florida and our support of Florida's 1115 waiver application for CHIP coverage for up to 300% of the FPL. Continued conversations and advocacy with Congressman Bilirakis office to discuss 340B drug pricing program on the aforementioned FY 24 IPPS rule policy pertaining to Medicare DSH calculation. Worked with Congressman Bilirakis' office to push for inclusion in a healthcare package. Also worked on a similar solution to extend 340B eligibility for providers eligible as of 1/1/2020 to waive DSH eligibility requirements for two years. Communicated with Senator Rubio and Congressman Bilirakis' offices in support of this proposal. Met with Senate Finance Majority and House Ways and Means Minority staff to advocate for the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act.
Bipartisan Primary Care and Health Workforce Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package.
Bipartisan Primary Care and Health Workforce Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package.
Bipartisan Primary Care and Health Workforce Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated against 340B oversight and transparency provisions that would result in cuts to the program and block savings from benefiting patients in need. Advocated against potential CRAs for the Mental Health Parity and Equity Rule. Advocated for greater scrutiny around parity and prior authorization issues in mental health care. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package. Advocated for the inclusion of the SUPPORT Act, Preventing Maternal Deaths Act, PREEMIE Act, and extension of telehealth flexibilities in year end healthcare package.
Bipartisan Primary Care and Health Workforce Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package.
Lobbied in favor of legislative package that would patch the physician fee schedule conversion factor rate cut with a 2.5% patch. Additionally to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act.
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. Commented on the following proposed rules out of CMS: -CY 2025 Home Health Prospective Payment System Proposed Rule Fact Sheet (CMS-1803-P) -CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS 1809-P) -CY 2025 Medicare Physician Fee Schedule Proposed Rule (CMS-1807-P)-Medicare Shared Savings Program Proposals. Sent a letter to the following offices in support of the bills listed below. -Reps. Bilirakis, Buchanan, Castor, Donalds, Dunn, Franklin, Frost, Lee, Luna, Soto, Steube -Sens. Rubio and Scott -Legislation: HR 4286, HR 6693, HR 4363, S 2213, HR 4531, HR 2412, HR 7742, S 3756
Met with new staff in Congresswoman Laurel Lees district office to discuss general healthcare issues in district. This included issues with the 340B drug pricing program and labor issues, specifically the SAVE Act S. 2768 that she cosponsors. Also discussed new facilities opening in the district. Met with Congresswoman Kathy Castor in a group and discussed access issues, specifically medicaid disenrollment in Florida and our support of Florida's 1115 waiver application for CHIP coverage for up to 300% of the FPL. Continued conversations and advocacy with Congressman Bilirakis office to discuss 340B drug pricing program on the aforementioned FY 24 IPPS rule policy pertaining to Medicare DSH calculation. Worked with Congressman Bilirakis' office to push for inclusion in a healthcare package. Also worked on a similar solution to extend 340B eligibility for providers eligible as of 1/1/2020 to waive DSH eligibility requirements for two years. Communicated with Senator Rubio and Congressman Bilirakis' offices in support of this proposal. Met with Senate Finance Majority and House Ways and Means Minority staff to advocate for the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act.
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. We also discussed with Cong. Soto, Wenstrup, staff of Rep. Blumenaeur, Senate Finance Majority staff.
Resident Physician Shortage Reduction Act of 2023
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Met with HRSA to discuss current concerns around the 340B drug pricing program, specifically pandemic era flexibility in offsite departments being 340B eligible prior to a cost report being filed. Submitted comment letters for Proposed Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2024 Rates [CMS-1785-P], and Medicare Program; Medicare Disproportionate Share Hospital (DSH) Payments: Counting Certain Days Associated With Section 1115 Demonstrations in the Medicaid Fraction Proposed Rule CMS-1788-P. We also submitted a statement for the record to the House Ways and Means Committee on the subject of the Oversight Subcommittee Hearing on Tax-Exempt Hospitals and the Community Benefit Standard held on April 26th, 2023. Met with Florida Congressional members and staff, Rep. Bilirakis, Rep. Castor, Rep. L Lee, Rep. Luna, Sen. Rubio, Rep. V Buchanan, Rep. S. Franklin, Sen. Scott, and Ways and Means Committee staff to discuss workforce issues for hospitals, including the graduate medical education program (Resident Physician Shortage Reduction Act of 2023 (H.R. 2389)) and visa needs (Healthcare Workforce Resilience Act of 2023 (HWRA)). Also discussed stress points with the 340B drug pricing program in terms of additional regulatory actions, and community benefit activities within the larger context of hospital financial constraints. Met with Florida Congressional members and staff for Reps. Castor and Luna, Committee staff from Senate Finance and HHS Representatives to discuss integration of behavioral health services into the traditional healthcare setting, and issues affecting the behavioral health workforce. Met with Florida Congressional members and staff for Reps. Castor, Luna, Bilirakis, L. Lee and S. Franklin, and Senators Rubio and Scott. We discussed stress points for children's hospitals, such as pediatric drug and supply shortages that can be remedied with greater transparency from manufacturers as well as additional incentives to produce domestically. We also discussed the need for greater GME funding to states such as Florida (Resident Physician Shortage Reduction Act of 2023 (H.R. 2389)). BayCare will continue to advocate for better payment rates in Medicare for the various proposed rules that impact payment to our doctors and hospitals.
Lower Costs, More Transparency Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Pertaining to Docket No. FDA-2023-N-2177: Medical Devices: Laboratory Developed Tests Proposed Rule, we advocated for more flexibility and no additional regulatory burden that will inhibit sophisticated laboratories such as BayCare's from acting effectively in real time situations to mitigate emerging health concerns in the community. Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy.
Lower Costs, More Transparency Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Met with staff in Congresswoman Laurel Lees staff to discuss general healthcare issues in district. Specifically labor issues, regarding the cost of staffing, and the SAVE Act S. 2768. Hosted CMS Deputy Administrator to discuss: 1) 340B eligibility challenges around the policy implemented in the FY 24 IPPS rule pertaining to the Medicare DSH calculation and using uncompensated care pool days under Floridas Low Income Pool Program. 2) expansion of the acute hospital-at-home waiver program to include observation patients. Hosted Congresswoman Kathy Castor press conference to discuss relevant toy safety and online safety items for children during the holiday season, utilizing the U.S. Public Interest Research Group annual report, Trouble in Toyland. Met virtually for an introductory conversation with Congressman Vern Buchanans health staff to discuss H@H program expansion and give overview of BayCare Health System operations. Meetings with staff in: Congressman Bilirakis office to discuss 340B drug pricing program on the aforementioned FY 24 IPPS rule policy pertaining to Medicare DSH calculation, Senator Scotts office to discuss 340B program oversight generally and Healthcare legislative packages, H.R.5378 and S. 2840, introductory meeting to discuss who BayCare is and our scope with Cong. Scott Franklins staff, discussion against price transparency provisions in S. 2840 and H.R. 5378 with Senator Rubios staff and further discussion around the potential legislative expansion to the hospital-at-home waiver program with observation patients, meeting with Congresswoman Laurel Lees staff on the SAVE Act H.R. 5378. Meeting with Congresswoman Kathy Castors staff to discuss outcomes within the BayCare@Home program and our vision for expansion of the current acute hospital-at-home waiver to include observation patients. Introductory meeting with new regional Senator Rubio staffer to discuss who BayCare is and the work we do in the community. Provided formal comment letter for the Laboratory Developed Test Rule - Docket No. FDA-2023-N-2177: Medical Devices: Laboratory Developed Tests Proposed Rule
Lower Costs, More Transparency Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Hosted roundtable with Congresswoman Kathy Castor to discuss issues pertaining to drug and medical supply shortages. Advocated for PAHPA reauthorization to include additional information on drug supply and production, specifically for pediatric drugs. Met with Congressman Gus Bilirakis and advocated for protection of the 340B drug pricing program. Specifically, we requested assistance in changing a policy implemented in the FY 24 IPPS rule pertaining to the Medicaid DSH calculation and using uncompensated care pool days under Floridas Low Income Pool Program. Also hosted roundtable with Congressman Bilirakis on the current struggles in the nursing industry. Met with House Ways & Means majority staff to discuss expansion of the current hospital-at-home waiver program. Also met with staff to build relationships for Congressman Scott Franklin, Congresswoman Laurel Lee, Congresswoman Kathy Castor, and Senator Marco Rubio. Discussion included scope of BayCare, concerns about legislation (HR5378) on site neutral payments particularly pertaining to drug administration and cosponsorship of the SAVE Act to codify assault on hospital staff as a federal crime. Met with Congresswoman Lunas staff in district. Responded to an RFI from CMS on a future episodic based payment model, advocated for expansion of the acute hospital-at-home waiver among other changes to drive innovation and equity in healthcare. Provided formal comment letters for the following proposed rules: -CY 2024 Physician Fee Schedule - CMS-1784-P -Remedy for the 340B-Acquired Drug Payment Policy for Calendar Years 2018-2022 - CMS 1793-P -CY 2024 Home Health Prospective Payment System - CMS-1780-P
Met with staff in Congresswoman Laurel Lees staff to discuss general healthcare issues in district. Specifically labor issues, regarding the cost of staffing, and the SAVE Act S. 2768. Hosted CMS Deputy Administrator to discuss: 1) 340B eligibility challenges around the policy implemented in the FY 24 IPPS rule pertaining to the Medicare DSH calculation and using uncompensated care pool days under Floridas Low Income Pool Program. 2) expansion of the acute hospital-at-home waiver program to include observation patients. Hosted Congresswoman Kathy Castor press conference to discuss relevant toy safety and online safety items for children during the holiday season, utilizing the U.S. Public Interest Research Group annual report, Trouble in Toyland. Met virtually for an introductory conversation with Congressman Vern Buchanans health staff to discuss H@H program expansion and give overview of BayCare Health System operations. Meetings with staff in: Congressman Bilirakis office to discuss 340B drug pricing program on the aforementioned FY 24 IPPS rule policy pertaining to Medicare DSH calculation, Senator Scotts office to discuss 340B program oversight generally and Healthcare legislative packages, H.R.5378 and S. 2840, introductory meeting to discuss who BayCare is and our scope with Cong. Scott Franklins staff, discussion against price transparency provisions in S. 2840 and H.R. 5378 with Senator Rubios staff and further discussion around the potential legislative expansion to the hospital-at-home waiver program with observation patients, meeting with Congresswoman Laurel Lees staff on the SAVE Act H.R. 5378. Meeting with Congresswoman Kathy Castors staff to discuss outcomes within the BayCare@Home program and our vision for expansion of the current acute hospital-at-home waiver to include observation patients. Introductory meeting with new regional Senator Rubio staffer to discuss who BayCare is and the work we do in the community. Provided formal comment letter for the Laboratory Developed Test Rule - Docket No. FDA-2023-N-2177: Medical Devices: Laboratory Developed Tests Proposed Rule
Bipartisan Primary Care and Health Workforce Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Met with staff in Congresswoman Laurel Lees staff to discuss general healthcare issues in district. Specifically labor issues, regarding the cost of staffing, and the SAVE Act S. 2768. Hosted CMS Deputy Administrator to discuss: 1) 340B eligibility challenges around the policy implemented in the FY 24 IPPS rule pertaining to the Medicare DSH calculation and using uncompensated care pool days under Floridas Low Income Pool Program. 2) expansion of the acute hospital-at-home waiver program to include observation patients. Hosted Congresswoman Kathy Castor press conference to discuss relevant toy safety and online safety items for children during the holiday season, utilizing the U.S. Public Interest Research Group annual report, Trouble in Toyland. Met virtually for an introductory conversation with Congressman Vern Buchanans health staff to discuss H@H program expansion and give overview of BayCare Health System operations. Meetings with staff in: Congressman Bilirakis office to discuss 340B drug pricing program on the aforementioned FY 24 IPPS rule policy pertaining to Medicare DSH calculation, Senator Scotts office to discuss 340B program oversight generally and Healthcare legislative packages, H.R.5378 and S. 2840, introductory meeting to discuss who BayCare is and our scope with Cong. Scott Franklins staff, discussion against price transparency provisions in S. 2840 and H.R. 5378 with Senator Rubios staff and further discussion around the potential legislative expansion to the hospital-at-home waiver program with observation patients, meeting with Congresswoman Laurel Lees staff on the SAVE Act H.R. 5378. Meeting with Congresswoman Kathy Castors staff to discuss outcomes within the BayCare@Home program and our vision for expansion of the current acute hospital-at-home waiver to include observation patients. Introductory meeting with new regional Senator Rubio staffer to discuss who BayCare is and the work we do in the community. Provided formal comment letter for the Laboratory Developed Test Rule - Docket No. FDA-2023-N-2177: Medical Devices: Laboratory Developed Tests Proposed Rule
Bipartisan Primary Care and Health Workforce Act
Client: BAYCARE HEALTH SYSTEM · Firm: BAYCARE HEALTH SYSTEM
Pertaining to Docket No. FDA-2023-N-2177: Medical Devices: Laboratory Developed Tests Proposed Rule, we advocated for more flexibility and no additional regulatory burden that will inhibit sophisticated laboratories such as BayCare's from acting effectively in real time situations to mitigate emerging health concerns in the community. Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy.
Advocated to the Domestic Policy Council around the inclusion of 1115 uncompensated care pool waiver days in the Medicaid numerator of the Medicare DSH percentage specifically as it pertains to 340B Drug Pricing Program qualification. Discussed key issues pertaining to Florida's Directed Payment Program and rules impacting state directed payment models. Advocated for the Improving Seniors Timely Access to Care Act to improve MA plan accountability. Advocated for parity to behavioral health reimbursement. Advocated for the importance of not-for-profit tax exempt status. Advocated broadly for reimbursement to improve food is medicine programs. Advocated for streamlined access to vital, innovative services such as Proton Therapy.
Filing targets: Centers For Medicare and Medicaid Services (CMS), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2026 · second_quarter · Q2
Advocated for protection of the existing 340B drug pricing program and concerns around a rebate model at HRSA + general preservation of the 340B drug pricing program. Also discussed the concern around exclusion of the waiver days (low income pool days in Florida).
Submitted final IPPS rule pertaining to a variety of hospital payment and regulatory provisions. Opposed 340B rebate models and other policies to add burden and compliance to the 340B drug pricing program. Advocated against codification of a variety of price transparency provisions in the Patients Deserve Price Tags Act that exist in rule but will not meaningfully address healthcare affordability.
Participated in meetings alongside Florida Hospital Association with Representatives Castor, Bilirakis, Buchanan, and the staff of Senator Moody, Scott and Franklin. Discussed key issues pertaining to Florida's Directed Payment Program and rules impacting state directed payment models. Advocated for the Seniors Timely Access to Care Act to improve MA plan accountability. Advocated for the inclusion of 1115 UCC waiver days in the Medicaid numerator of the Medicare DSH percentage. Advocated broadly for reimbursement to improve food is medicine programs. Advocated for streamlined access to vital, innovative services such as Proton Therapy.
Filing targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2026 · first_quarter · Q1
Advocated for protection of the existing 340B drug pricing program and concerns around a rebate model at HRSA + general preservation of the 340B drug pricing program. Also discussed the concern around exclusion of the waiver days (low income pool days in Florida).
Lobbied for approval of Florida's DPP waiver to CMS, support for the program, Florida's Slots for Docs Graduate Medical Education as well.
Advocated for permanence/extension to various telehealth flexibilities and the Hospital-at-Home waiver program. Also for the inclusion of low income pool or UCC days in the Medicaid fraction of the DSH percentage, specifically with Florida Congressional offices and Senators. Advocated for the approval of Florida's Directed Payment Program year 5.
Filing targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2025 · fourth_quarter · Q4
Advocated for permanence/extension to various telehealth flexibilities and the Hospital-at-Home waiver program. Also for the inclusion of low income pool or UCC days in the Medicaid fraction of the DSH percentage.
Lobbied for approval of Florida's DPP waiver to CMS, support for the program, Florida's Slots for Docs Graduate Medical Education as well.
Advocated for protection of the existing 340B drug pricing program and concerns around a rebate model at HRSA + general preservation of the 340B drug pricing program. Also discussed the concern around exclusion of the waiver days (low income pool days in Florida).
Filing targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2025 · third_quarter · Q3
Lobbied against various provisions pertaining to provider taxes, coverage changes, community engagement requirements that would have a detrimental impact to healthcare in Florida contained within the OBBBA. This includes provisions that reduce retroactive coverage and coverage for legally present individuals.
Advocated against proposals to cut Medicaid access and/or reimbursement. Advocated for extension of the Enhanced Premium Tax Credits to ensure Americans have access to health coverage. Advocated for continued support of the 340B drug pricing program. Advocated for extension of telehealth flexibilities and Hospital-at-Home waiver program (AHCAH at CMS). On AHCAH, advocated for extension of current program to include observation patients.
Advocated for protection of the existing 340B drug pricing program and concerns around a rebate model at HRSA.
Filing targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2025 · second_quarter · Q2
Lobbied against various provisions pertaining to provider taxes, coverage changes, community engagement requirements that would have a detrimental impact to healthcare in Florida contained within the OBBBA. This includes provisions that reduce retroactive coverage and coverage for legally present individuals.
Advocated against proposals to cut Medicaid access and/or reimbursement. Advocated for extension of the APTCs to ensure Americans have access to health coverage. Advocated for continued support of the 340B drug pricing program.
Advocated for protection of the existing 340B drug pricing program.
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2025 · first_quarter · Q1
Lobbied against potential reductions in Medicaid reimbursement and cuts to local provider participation fund taxing mechanisms to support the medicaid shortfall.
Advocated against proposals to cut Medicaid access and/or reimbursement. Advocated for extension of the APTCs to ensure Americans have access to health coverage. Advocated for continued support of the 340B drug pricing program.
Advocated for protection of the existing 340B drug pricing program.
Filing targets: HOUSE OF REPRESENTATIVES, SENATE
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2024 · fourth_quarter · Q4
Discussed current activity in Congress on 340B and the lack of accountability on drug manufacturers as well as the programming BayCare provides the community with the 340B savings. These programs include the Medication Assistance Program to ensure all in our community have access to the prescription drugs they require (we take referrals from anyone, not just BayCare patients/providers) and the Pharmacy Transition of Care team that helps improve medication adherence and transition/care coordination for those returning home with various prescriptions. Also discussed the concern with the removal of 1115 waiver days or uncompensated care pool days in the inclusion of the Medicaid DSH calculation for the purposes of 340B qualification. Specifically advocated for language that would factor in uncompensated care pool days only for 340B, not Medicare DSH. Discussed this with Senator Rubio, Congressman Bilirakis', Congressman Buchanan, Congresswoman Castor, Congressman Soto, Congressman Franklin.
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated against 340B oversight and transparency provisions that would result in cuts to the program and block savings from benefiting patients in need. Advocated against potential CRAs for the Mental Health Parity and Equity Rule. Advocated for greater scrutiny around parity and prior authorization issues in mental health care. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package. Advocated for the inclusion of the SUPPORT Act, Preventing Maternal Deaths Act, PREEMIE Act, and extension of telehealth flexibilities in year end healthcare package.
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2024 · third_quarter · Q3
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. Commented on the following proposed rules out of CMS: -CY 2025 Home Health Prospective Payment System Proposed Rule Fact Sheet (CMS-1803-P) -CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS 1809-P) -CY 2025 Medicare Physician Fee Schedule Proposed Rule (CMS-1807-P)-Medicare Shared Savings Program Proposals. Sent a letter to the following offices in support of the bills listed below. -Reps. Bilirakis, Buchanan, Castor, Donalds, Dunn, Franklin, Frost, Lee, Luna, Soto, Steube -Sens. Rubio and Scott -Legislation: HR 4286, HR 6693, HR 4363, S 2213, HR 4531, HR 2412, HR 7742, S 3756
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2024 · second_quarter · Q2
Discussed current activity in Congress on 340B and the lack of accountability on drug manufacturers as well as the programming BayCare provides the community with the 340B savings. These programs include the Medication Assistance Program to ensure all in our community have access to the prescription drugs they require (we take referrals from anyone, not just BayCare patients/providers) and the Pharmacy Transition of Care team that helps improve medication adherence and transition/care coordination for those returning home with various prescriptions. Also discussed the concern with the removal of 1115 waiver days or uncompensated care pool days in the inclusion of the Medicaid DSH calculation for the purposes of 340B qualification. Specifically advocated for language that would factor in uncompensated care pool days only for 340B, not Medicare DSH. Discussed this with Senator Rubio, Congressman Bilirakis', Congressman Buchanan, Congresswoman Castor, Congressman Soto, Congressman Franklin and the staff of Senator Blackburn (TN).
Lobbied in favor of legislation to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act. We also discussed with Cong. Soto, Wenstrup, staff of Rep. Blumenaeur, Senate Finance Majority staff.
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2024 · first_quarter · Q1
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package.
Met with new staff in Congresswoman Laurel Lees district office to discuss general healthcare issues in district. This included issues with the 340B drug pricing program and labor issues, specifically the SAVE Act S. 2768 that she cosponsors. Also discussed new facilities opening in the district. Met with Congresswoman Kathy Castor in a group and discussed access issues, specifically medicaid disenrollment in Florida and our support of Florida's 1115 waiver application for CHIP coverage for up to 300% of the FPL. Continued conversations and advocacy with Congressman Bilirakis office to discuss 340B drug pricing program on the aforementioned FY 24 IPPS rule policy pertaining to Medicare DSH calculation. Worked with Congressman Bilirakis' office to push for inclusion in a healthcare package. Also worked on a similar solution to extend 340B eligibility for providers eligible as of 1/1/2020 to waive DSH eligibility requirements for two years. Communicated with Senator Rubio and Congressman Bilirakis' offices in support of this proposal. Met with Senate Finance Majority and House Ways and Means Minority staff to advocate for the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act.
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2023 · fourth_quarter · Q4
Discussed current activity in Congress on 340B and the lack of accountability on drug manufacturers as well as the programming BayCare provides the community with the 340B savings. These programs include the Medication Assistance Program to ensure all in our community have access to the prescription drugs they require (we take referrals from anyone, not just BayCare patients/providers) and the Pharmacy Transition of Care team that helps improve medication adherence and transition/care coordination for those returning home with various prescriptions. Also discussed the concern with the removal of 1115 waiver days or uncompensated care pool days in the inclusion of the Medicaid DSH calculation for the purposes of 340B qualification.
Pertaining to Docket No. FDA-2023-N-2177: Medical Devices: Laboratory Developed Tests Proposed Rule, we advocated for more flexibility and no additional regulatory burden that will inhibit sophisticated laboratories such as BayCare's from acting effectively in real time situations to mitigate emerging health concerns in the community. Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy.
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2023 · third_quarter · Q3
In the comment letters submitted for CMS-1784-P, CMS-1793-P, and CMS-1780-P BayCare advocated for adequate reimbursement for providers. Particularly for CMS-1780-P, where cuts extending the past two years threaten the access to care for Medicare beneficiaries by underpaying home health providers. For the RFI on a Future Episodic-based Payment Model, BayCare stressed the improvements possible if hospital-at-home offered via the CMS waiver were expanded to include observation level patients. BayCare also cautioned about the lack of adequate funding for drug administration, particularly infusion, and the detriment that could have for continuity of care for those that are uninsured, being removed from state Medicaid plans during redetermination, or insured but unable to manage copay responsibilities.
Discussed current activity in Congress on 340B and the lack of accountability on drug manufacturers as well as the programming BayCare provides the community with the 340B savings. These programs include the Medication Assistance Program to ensure all in our community have access to the prescription drugs they require (we take referrals from anyone, not just BayCare patients/providers) and the Pharmacy Transition of Care team that helps improve medication adherence and transition/care coordination for those returning home with various prescriptions. Also discussed the concern with the removal of 1115 waiver days or uncompensated care pool days in the inclusion of the Medicaid DSH calculation for the purposes of 340B qualification.
BAYCARE HEALTH SYSTEM via BAYCARE HEALTH SYSTEM
2023 · second_quarter · Q2
Met with HRSA to discuss current concerns around the 340B drug pricing program, specifically pandemic era flexibility in offsite departments being 340B eligible prior to a cost report being filed. Submitted comment letters for Proposed Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2024 Rates [CMS-1785-P], and Medicare Program; Medicare Disproportionate Share Hospital (DSH) Payments: Counting Certain Days Associated With Section 1115 Demonstrations in the Medicaid Fraction Proposed Rule CMS-1788-P. We also submitted a statement for the record to the House Ways and Means Committee on the subject of the Oversight Subcommittee Hearing on Tax-Exempt Hospitals and the Community Benefit Standard held on April 26th, 2023. Met with Florida Congressional members and staff, Rep. Bilirakis, Rep. Castor, Rep. L Lee, Rep. Luna, Sen. Rubio, Rep. V Buchanan, Rep. S. Franklin, Sen. Scott, and Ways and Means Committee staff to discuss workforce issues for hospitals, including the graduate medical education program (Resident Physician Shortage Reduction Act of 2023 (H.R. 2389)) and visa needs (Healthcare Workforce Resilience Act of 2023 (HWRA)). Also discussed stress points with the 340B drug pricing program in terms of additional regulatory actions, and community benefit activities within the larger context of hospital financial constraints. Met with Florida Congressional members and staff for Reps. Castor and Luna, Committee staff from Senate Finance and HHS Representatives to discuss integration of behavioral health services into the traditional healthcare setting, and issues affecting the behavioral health workforce. Met with Florida Congressional members and staff for Reps. Castor, Luna, Bilirakis, L. Lee and S. Franklin, and Senators Rubio and Scott. We discussed stress points for children's hospitals, such as pediatric drug and supply shortages that can be remedied with greater transparency from manufacturers as well as additional incentives to produce domestically. We also discussed the need for greater GME funding to states such as Florida (Resident Physician Shortage Reduction Act of 2023 (H.R. 2389)). BayCare will continue to advocate for better payment rates in Medicare for the various proposed rules that impact payment to our doctors and hospitals.
Filing targets: HOUSE OF REPRESENTATIVES, SENATE
Lobbied in favor of legislative package that would patch the physician fee schedule conversion factor rate cut with a 2.5% patch. Additionally to ensure that uncompensated care pool days can be included in the medicaid fraction of the medicare DSH %. In the FY 2024 IPPS CMS changed a rule that would prevent these days from being included. Discussed this solution with members/staff of the following offices: Buchanan (FL), Luna, Bilirakis, Lee (FL), Castor, Rubio, Scott, Soto, Franklin. Advocated on behalf of the At-HOME Services Act (S. 3756, H.R.7742). To expand hospital-at-home waiver to include observation patients for medicare payment. Ongoing conversations with Senator Rubio's office, Congresswoman Castor's office, and Congressman Buchanan's office in advancing At-HOME Services Act.
Filing targets: HOUSE OF REPRESENTATIVES, SENATE
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package.
Discussed current activity in Congress on 340B and the lack of accountability on drug manufacturers as well as the programming BayCare provides the community with the 340B savings. These programs include the Medication Assistance Program to ensure all in our community have access to the prescription drugs they require (we take referrals from anyone, not just BayCare patients/providers) and the Pharmacy Transition of Care team that helps improve medication adherence and transition/care coordination for those returning home with various prescriptions. Also discussed the concern with the removal of 1115 waiver days or uncompensated care pool days in the inclusion of the Medicaid DSH calculation for the purposes of 340B qualification. Specifically advocated for language that would factor in uncompensated care pool days only for 340B, not Medicare DSH. Discussed this with Senator Rubio, Congressman Bilirakis', Congressman Buchanan, Congresswoman Castor, Congressman Soto, Congressman Franklin and the staff of Senator Blackburn (TN).
Filing targets: Centers For Medicare and Medicaid Services (CMS), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), SENATE
Advocated against healthcare price transparency provisions within HR 5378 and S 2840 that would provide additionally burdensome reporting to further care sites that will hamper hospital negotiations with payors and require FTEs and excessive hours to satisfy, advocated against SITE neutrality provisions that would limit payment based on originating location of services. Advocated for 340B DSH language % to include uncompensated care pool days (low income pool days in Florida), or 340B eligibility waiver to not consider DSH langauge % for two years to be included in a healthcare package.
Filing targets: Centers For Medicare and Medicaid Services (CMS), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), SENATE
Discussed current activity in Congress on 340B and the lack of accountability on drug manufacturers as well as the programming BayCare provides the community with the 340B savings. These programs include the Medication Assistance Program to ensure all in our community have access to the prescription drugs they require (we take referrals from anyone, not just BayCare patients/providers) and the Pharmacy Transition of Care team that helps improve medication adherence and transition/care coordination for those returning home with various prescriptions. Also discussed the concern with the removal of 1115 waiver days or uncompensated care pool days in the inclusion of the Medicaid DSH calculation for the purposes of 340B qualification. Specifically advocated for language that would factor in uncompensated care pool days only for 340B, not Medicare DSH. Discussed this with Senator Rubio, Congressman Bilirakis', Congressman Buchanan, and Congresswoman Castor's offices.
Filing targets: Centers For Medicare and Medicaid Services (CMS), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE
Met with staff in Congresswoman Laurel Lees staff to discuss general healthcare issues in district. Specifically labor issues, regarding the cost of staffing, and the SAVE Act S. 2768. Hosted CMS Deputy Administrator to discuss: 1) 340B eligibility challenges around the policy implemented in the FY 24 IPPS rule pertaining to the Medicare DSH calculation and using uncompensated care pool days under Floridas Low Income Pool Program. 2) expansion of the acute hospital-at-home waiver program to include observation patients. Hosted Congresswoman Kathy Castor press conference to discuss relevant toy safety and online safety items for children during the holiday season, utilizing the U.S. Public Interest Research Group annual report, Trouble in Toyland. Met virtually for an introductory conversation with Congressman Vern Buchanans health staff to discuss H@H program expansion and give overview of BayCare Health System operations. Meetings with staff in: Congressman Bilirakis office to discuss 340B drug pricing program on the aforementioned FY 24 IPPS rule policy pertaining to Medicare DSH calculation, Senator Scotts office to discuss 340B program oversight generally and Healthcare legislative packages, H.R.5378 and S. 2840, introductory meeting to discuss who BayCare is and our scope with Cong. Scott Franklins staff, discussion against price transparency provisions in S. 2840 and H.R. 5378 with Senator Rubios staff and further discussion around the potential legislative expansion to the hospital-at-home waiver program with observation patients, meeting with Congresswoman Laurel Lees staff on the SAVE Act H.R. 5378. Meeting with Congresswoman Kathy Castors staff to discuss outcomes within the BayCare@Home program and our vision for expansion of the current acute hospital-at-home waiver to include observation patients. Introductory meeting with new regional Senator Rubio staffer to discuss who BayCare is and the work we do in the community. Provided formal comment letter for the Laboratory Developed Test Rule - Docket No. FDA-2023-N-2177: Medical Devices: Laboratory Developed Tests Proposed Rule
Filing targets: Centers For Medicare and Medicaid Services (CMS), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE
Hosted roundtable with Congresswoman Kathy Castor to discuss issues pertaining to drug and medical supply shortages. Advocated for PAHPA reauthorization to include additional information on drug supply and production, specifically for pediatric drugs. Met with Congressman Gus Bilirakis and advocated for protection of the 340B drug pricing program. Specifically, we requested assistance in changing a policy implemented in the FY 24 IPPS rule pertaining to the Medicaid DSH calculation and using uncompensated care pool days under Floridas Low Income Pool Program. Also hosted roundtable with Congressman Bilirakis on the current struggles in the nursing industry. Met with House Ways & Means majority staff to discuss expansion of the current hospital-at-home waiver program. Also met with staff to build relationships for Congressman Scott Franklin, Congresswoman Laurel Lee, Congresswoman Kathy Castor, and Senator Marco Rubio. Discussion included scope of BayCare, concerns about legislation (HR5378) on site neutral payments particularly pertaining to drug administration and cosponsorship of the SAVE Act to codify assault on hospital staff as a federal crime. Met with Congresswoman Lunas staff in district. Responded to an RFI from CMS on a future episodic based payment model, advocated for expansion of the acute hospital-at-home waiver among other changes to drive innovation and equity in healthcare. Provided formal comment letters for the following proposed rules: -CY 2024 Physician Fee Schedule - CMS-1784-P -Remedy for the 340B-Acquired Drug Payment Policy for Calendar Years 2018-2022 - CMS 1793-P -CY 2024 Home Health Prospective Payment System - CMS-1780-P
Filing targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE
Discussed current activity in Congress on 340B and the lack of accountability on drug manufacturers as well as the programming BayCare provides the community with the 340B savings. These programs include the Medication Assistance Program to ensure all in our community have access to the prescription drugs they require (we take referrals from anyone, not just BayCare patients/providers) and the Pharmacy Transition of Care team that helps improve medication adherence and transition/care coordination for those returning home with various prescriptions. We also discussed specific challenges regarding rule changes made in offsite facilities not being immediately alongside the conclusion of the PHE.
In the comment letter submitted for Medicare Disproportionate Share Hospital (DSH) Payments: Counting Certain Days Associated With Section 1115 Demonstrations in the Medicaid Fraction Proposed Rule CMS-1788-P we advocated that by unnecessarily reducing funding for states that operate uncompensated care funding pools, CMS would put a strain on resources at community hospitals that rely on those resources which would result in less proactive programming targeting community health improvement and overall potentially a decline in quality of care/outcomes. In the Proposed Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2024 Rates [CMS-1785-P] comment letter, BayCare advocated for greater level of payment to providers given the current financial constraints in healthcare in order to preserve and maintain the high level of care afforded to patients. BayCare also applauded the change of severity level designation for diagnosis codes by describing homelessness from non-complication or comorbidity to complication or comorbidity, noting the impact these factors have on resource utilization and in turn increasing payment to provide greater support to this population by deepening wrap around services available.
Filing targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), SENATE