2025 third_quarter Filing

Imports of personal protective equipment (PPE), medical consumables, and medical equipment, including Devices: Monitored and provided feedback on U.S. Department of Commerces Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices (Docket No: 250924-0160; XRIN 0694-XC134) Monitored development of the Medical Supply Chain Resiliency Act (S.998/HR.2213) United States and European Union Cooperation Agreement on Reciprocal, Fair and Balanced Trade - Monitored Implementation and passage of agreement, with focus on tariff barriers.

Acute Hospital Care at Home - Recommended Congress make certain flexibilities related to the Acute Hospital Care at Home Program permanent or, pass an extension before flexibilities expire. Issues related to hospital and provider payment - Supported increasing hospital reimbursement to ensure continued access to care for vulnerable populations, highlighted the criticality of Medicaid to sustaining vital healthcare services. Medicaid Disproportionate Share Hospital (DSH) Program - Urged Congress to avert the cuts to Medicaid DSH payments set to take place, encouraged passage of legislation to preserve DSH payments on a longer-term basis Medicaid Program; Preserving Medicaid Funding for Vulnerable Populations- Closing a Health Care-Related Tax Loophole Proposed Rule (CMS- 2448-P) - Responded to various issues and proposals provided in the Proposed Rule and encouraged the agency to identify alternative approaches that would be less disruptive to state Medicaid programs. Medicare and Medicaid Programs; CY 2026 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; Quality Reporting Programs; Overall Hospital Quality Star Ratings; and Hospital Price Transparency (CMS-1834-P) proposed rule - Responded to various issues and proposals provided in the Proposed Rule and offered our responses to the agencys various requests for information. Medicare and Medicaid Programs; CY 2026 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program (CMS-1832-P) proposed rule - Responded to various issues and proposals provided in the Proposed Rule and offered our responses to the agencys various requests for information. Medicare Program; Implementation of Prior Authorization for Select Services under the WISeR Model (CMS-5056-N) - Offered recommendations to strengthen transparency, reduce administrative burden and ensure provider perspectives inform implementation and oversight Monitored development and passage of the One Big Beautiful Bill Act (H.R.1) Physician Payment - Urged Congress to consider long-term legislative solutions to refine the current Medicare physician payment system Prior Authorization - Provided feedback to improve prior authorization (PA) processes for various plans and payers, including MA organizations and Medicaid managed care plans. Monitored development of the Medicare Advantage Prompt Pay Act (H.R.5454) Rural Emergency Hospital (REH) Designation - Urged corrective action to allow REHs to bill both the Medicare and Medicaid programs. Advocated for increased eligibility among REHs to allow for future Medicaid DSH payments to certain hospital facilities. Site-Neutral Payment Policies - 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.