VIZIENT INC

21st Century Cures Initiative: Encouraged Congress to consider whether use of the Vizient Vulnerability Index is appropriate as stakeholders consider innovative approaches to advance further technological progress. CMS FY 2025 Hospital Inpatient Prospective Payment System (IPPS) for Acute Care Hospitals and Quality Programs and Medicare Promoting Interoperability Program Requirements for Eligible Hospitals and Critical Access Hospitals proposed rule - Responded to various issues and proposals provided in the Proposed Rule and offered our responses to the agencys various requests for information. CMS Medicare Drug Price Negotiation Program: Draft Guidance - Encouraged CMS to consider minimizing provider burden, including avoiding disruptions to current purchasing and reimbursement practices ; urged CMS to avoid final guidance that enables a retrospective payment of the 340B discount 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. Medicare-supported Graduate Medical Education - Supported passage of the Resident Physician Shortage Reduction Act (H.R. 2389/S. 1302), responded to the Senate Bipartisan Medicare Graduate Medical Education (GME) Working Group Draft Proposal Outline and Questions for Consideration. Medicare Program; Request for Information on Medicare Advantage Data - Recommended several opportunities to the agency to improve upon MA data collection, encouraged CMS to ensure that the data collection burden is not directly or indirectly passed on to hospitals and other providers. Medicare Program; Strengthening Oversight of Accrediting Organizations (AOs) and Preventing AO Conflict of Interest, and Related Provisions proposed rule - Responded to the proposed rule urging CMS to minimize potential delays in accreditation or fewer educational offerings that could negatively impact providers. Encouraged CMS to finalize efforts to increase oversight of AO conflicts of interest.

340B Drug Pricing Program - Continued to urge action to ensure covered entities have access to 340B discounted prices through contract pharmacies. Highlighted critical importance of the 340B program for hospitals. Responded to the discussion draft of the Supporting Underserved and Strengthening Transparency, Accountability, and Integrity Now and for the Future of 340B Act (SUSTAIN 340B Act) and supplemental request for information (RFI). Buffer inventory - Engagements with CMS on reimbursement for hospitals that stockpile buffer supplies of essential medicines Children's Hospital Graduate Medical Education (CHGME) - Continued to urge Congress to reauthorize CHGME program through the Childrens Hospital GME Support Reauthorization Act of 2023 (H.R. 3887). Offered support for providing $738 million in funding the CHGME program. Drug shortages -Supported elements to increase transparency in prescription drug supply chain and increase reimbursement for generic prescription drugs; issues related to compounding; issues related to buffer inventory. Continued supporting passage of The Drug Shortage Prevention Act (H.R. 3008) and The Drug Origin Transparency Act (H.R. 3810) and engaged on the Stop Drug Shortages Act (McMorris Rodgers, No Bill Number) discussion draft. Healthcare Workforce - Monitored development of the Bipartisan Primary Care and Health Workforce Act (S.2840) and the Safety from Violence for Healthcare Employees (SAVE) Act (H.R. 2584/S. 2768). Hospital Group Purchasing - Advocated to highlight the value that hospital group purchasing organizations provide to hospitals and suppliers. Provided education on how GPOs work in the healthcare supply chain and the role they play in delivering value to healthcare providers, as well as key differences between traditional GPOs and PBMs. Medical Device Sterilization - Conducted education and outreach on the potential negative impact on the healthcare supply chain of pending regulations limiting the use of Ethylene Oxide as a medical device sterilant. Mental and Behavioral Health - Highlighted the need for legislation to address significant challenges to mental and behavioral health treatment, including increased demand for services, limited access to treatment, and clinician shortages. Office of the National Coordinator (ONC) Standards Bulletin 2024-1 (SB24-1) - Offered recommendations to constructively improve Draft USCDI v5 to support efforts related to health equity. Payer-mandated White Bagging - Urged support for policy updates related to payer-mandated white bagging for medications. Social Determinants of Health - Encouraged Congress and agencies to ensure tools like the Vizient Vulnerability Index are being utilized to understand and identify social drivers of health at the neighborhood level. Telehealth - Continued supporting passage of the CONNECT for Health Act (S. 2016/H.R. 4189). Continued to advocate for the adoption of permanent telehealth policies to extend flexibilities beyond the current 2024 expiration date.

Not-for-Profit Hospital Tax-exemption - Provided education and information on hospital tax exemption and what is required to justify and maintain tax-exempt status.

Sec. 301 China Tariffs - Continued to advocate for clarity around the expiration of tariff exclusions for products necessary to respond to the COVID-19 pandemic. Supported extending exclusions for key healthcare products. Provided feedback to the U.S. Trade Representatives (USTR) Request for Comments on Proposed Modifications and Machinery Exclusion Process in Four-Year Review of Actions Taken in the Section 301 Investigation: Chinas Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation (Docket No. USTR-2024-0007)

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).