Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

9. Check if this filing amends a previously filed version of this report

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code MMM

16. Specific lobbying issues

Medicare payment reform - Sent letter of support to the bill sponsors of the Strengthening Medicare for Patients and Providers Act (H.R. 6160) that would add an inflationary update to Medicare Part B reimbursement as measured by the Medicare Economic Index (MEI). Sent letter to congressional leadership with our end of 2025 Medicare payment reform priorities - add an inflationary update, reform the budget neutrality aspect of Medicare, permanently extend the 1.0 work GPCI floor.

Prior Authorization - Supported the Improving Seniors Timely Access to Care Act (S. 1816, H.R. 3514) in Congress to reform prior authorization, joined a letter to congressional leadership in support of the bill. Joined letter to Congress on the need to reform the Medicare Wasteful and Inappropriate Service Reduction (WISeR) Model that is being tested under the CMS Innovation Center. Sent a letter of support to the bill sponsors for reintroducing the Safe Step Act (H.R. 5509) to reform step therapy protocols.

Telehealth - Joined a letter to OMB and the DEA urging for the extension of flexibilities related to prescribing controlled substances via telehealth. Joined a letter to Congress to act to extend telehealth flexibilities long-term that were at the time expired during the government shutdown. Sent letter to congressional leadership with our end of 2025 telehealth policy priorities.

Physician-Owned Hospitals - Joined a letter to Congress in support of repealing the ban on physician-owned hospitals. Joined a letter of support of the Patient Access to Higher Quality Health Care Act of 2025 (H.R. 4002) that would repeal statutory restrictions on the whole hospital exception to Stark physician self- referral law.

Cybersecurity - Joined a letter to HHS opposing the finalization of the proposed rule to make changes to HIPAA cybersecurity regulations.

Artificial Intelligence (AI) - Joined a coalition letter on artificial intelligence policies for medical groups in response to the White House Office of Science and Technology Policy request for information on AI reform.

Value-Based Care - Sent letter to congressional leadership supporting the Preserving Patient Access to Accountable Care Act (H.R. 786, S. 1460). Joined a letter to CMS urging them to use existing authority to ensure ACOs and MIPS eligible clinicians are held harmless from challenges posed by increased billing for skin substitutes.

Expiration of healthcare policies due to lapse in federal government funding - Sent letter to congressional leadership urging them to reinstate the healthcare provisions (telehealth flexibilities, the 1.0 work GPCI floor) that expired on September 30 as part of the government shutdown. Urged CMS to release claims that were being held as a result of the pause on processing Medicare claims from the government shutdown. Sent letter to CMS requesting guidance on the rebilling of claims following the government shutdown and subsequent legislation extending numerous healthcare policies. Supported Congress extending healthcare policies that expired during the government shutdown and urged permanent reform to enshrine these policies.

Enhanced ACA Tax Credits - Urged Congress to extend the enhanced Marketplace premium tax credits as part of our end of 2025 legislative priorities.

Clinical Lab Cuts -Joined a coalition letter of support to the bill sponsors for the RESULTS Act (H.R. 5269) that would reform the clinical laboratory fee schedule and stop potential cuts to laboratory reimbursement. Included support for the RESULTS Act in our end of 2025 legislative priorities.

Medicare Advantage - Sent letter of support to bill sponsors of the Medicare Advantage Prompt Pay Act (H.R. 5454) that would help ensure prompt payment to medical groups from Medicare Advantage plans.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Centers For Medicare and Medicaid Services (CMS), Health & Human Services - Dept of (HHS), Drug Enforcement Administration (DEA), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code HCR

16. Specific lobbying issues

Medicare payment reform - Sent letter of support to the bill sponsors of the Strengthening Medicare for Patients and Providers Act (H.R. 6160) that would add an inflationary update to Medicare Part B reimbursement as measured by the Medicare Economic Index (MEI). Sent letter to congressional leadership with our end of 2025 Medicare payment reform priorities - add an inflationary update, reform the budget neutrality aspect of Medicare, permanently extend the 1.0 work GPCI floor.

Prior Authorization - Supported the Improving Seniors Timely Access to Care Act (S. 1816, H.R. 3514) in Congress to reform prior authorization, joined a letter to congressional leadership in support of the bill. Joined letter to Congress on the need to reform the Medicare Wasteful and Inappropriate Service Reduction (WISeR) Model that is being tested under the CMS Innovation Center. Sent a letter of support to the bill sponsors for reintroducing the Safe Step Act (H.R. 5509) to reform step therapy protocols.

Telehealth - Joined a letter to OMB and the DEA urging for the extension of flexibilities related to prescribing controlled substances via telehealth. Joined a letter to Congress to act to extend telehealth flexibilities long-term that were at the time expired during the government shutdown. Sent letter to congressional leadership with our end of 2025 telehealth policy priorities.

Physician-Owned Hospitals - Joined a letter to Congress in support of repealing the ban on physician-owned hospitals. Joined a letter of support of the Patient Access to Higher Quality Health Care Act of 2025 (H.R. 4002) that would repeal statutory restrictions on the whole hospital exception to Stark physician self- referral law.

Cybersecurity - Joined a letter to HHS opposing the finalization of the proposed rule to make changes to HIPAA cybersecurity regulations.

Artificial Intelligence (AI) - Joined a coalition letter on artificial intelligence policies for medical groups in response to the White House Office of Science and Technology Policy request for information on AI reform.

Value-Based Care - Sent letter to congressional leadership supporting the Preserving Patient Access to Accountable Care Act (H.R. 786, S. 1460). Joined a letter to CMS urging them to use existing authority to ensure ACOs and MIPS eligible clinicians are held harmless from challenges posed by increased billing for skin substitutes.

Expiration of healthcare policies due to lapse in federal government funding - Sent letter to congressional leadership urging them to reinstate the healthcare provisions (telehealth flexibilities, the 1.0 work GPCI floor) that expired on September 30 as part of the government shutdown. Urged CMS to release claims that were being held as a result of the pause on processing Medicare claims from the government shutdown. Sent letter to CMS requesting guidance on the rebilling of claims following the government shutdown and subsequent legislation extending numerous healthcare policies. Supported Congress extending healthcare policies that expired during the government shutdown and urged permanent reform to enshrine these policies.

Enhanced ACA Tax Credits - Urged Congress to extend the enhanced Marketplace premium tax credits as part of our end of 2025 legislative priorities.

Clinical Lab Cuts -Joined a coalition letter of support to the bill sponsors for the RESULTS Act (H.R. 5269) that would reform the clinical laboratory fee schedule and stop potential cuts to laboratory reimbursement. Included support for the RESULTS Act in our end of 2025 legislative priorities.

Medicare Advantage - Sent letter of support to bill sponsors of the Medicare Advantage Prompt Pay Act (H.R. 5454) that would help ensure prompt payment to medical groups from Medicare Advantage plans.

17. House(s) of Congress and Federal agencies Check if None

U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Health & Human Services - Dept of (HHS), Centers For Medicare and Medicaid Services (CMS), Drug Enforcement Administration (DEA), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

21. Client new principal place of business (if different than line 20)

22. New General description of client’s business or activities

LOBBYIST UPDATE

23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

FOREIGN ENTITIES

27. Add the following foreign entities:

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization

CONVICTIONS DISCLOSURE

29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery, extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
No Yes