CVS Health is committed to supporting the development of sound public policy in health care, and we participate in the political process to address legislation that has a direct impact on our company and the industry as a whole. Reflecting our purpose to help people on their path to better health, we work with federal and state policymakers to ensure people get the right care, at the right time and in the right setting.
It is CVS Health’s policy that the CEO and the Board are responsible for determining the company’s public policy and political interests in a manner consistent with applicable laws. The Nominating and Corporate Governance Committee reviews and considers the company’s policies and practices, including expenditures regarding political contributions and direct and indirect lobbying. It also reviews and considers the company’s policies and practices regarding other significant public policy issues.
Articulating Our Public Policy Principles
Our Public Policy Principles outline our priorities for participating in the public policy sphere. We are committed to addressing health care costs, quality and access because they are essential factors in helping people on their path to better health. To advance our policies, we work with federal and state policymakers, others in our industry, the broader business community, and non-profit and civic partners.
Keeping Our Lobbying Activities Focused
Lobbying is highly regulated in the United States, and we comply with applicable federal and stat laws, including the Lobbying Disclosure Act and Honest Leadership and Open Government Act that require reporting on lobbying activities and certification of compliance with Congressional gift rules.
Our Government Affairs team represents the company’s point of view in Washington, in state capitals and with regulatory agencies around the country. We focus on legislative and public policy issues that impact the company’s delivery of health care and long-term business interests. We communicate with policymakers and stakeholders on issues that impact our business, health plan clients and customers. In addition to our efforts to advocate for health care access, quality and affordability, we continued our commitment to address prescription drug abuse in 2015, joining President Obama’s ongoing efforts to combat this national epidemic.
For example, we participate in the Alliance to Prevent the Abuse of Medicines, a non-profit partnership of key stakeholders representing every aspect of the prescription drug supply chain, to develop and offer policy solutions aimed at decreasing prescription drug abuse. We are involved in other initiatives related to prescription drug abuse as well, which are described in detail here.
Beginning in 2015, we posted copies of our federal lobby reports on our website to make the information more accessible to our stakeholders.
Transparency Regarding Political Donations
All of the Company’s contributions promote the interests of the Company and are made without regard to the private political preferences of the Company’s officers and directors and in strict compliance with applicable laws. CVS Health is prohibited by federal law from making corporate contributions directly to candidates or political parties in federal elections. We make contributions at the state level as allowed by state laws, and to other organizations as described below, in each case in alignment with our public policy priorities and business interests.
Our Political Activities and Contributions Report discloses all of our political contributions, which may be made, depending on our priorities for the particular year, to candidates for state and federal office, political action committees and entities organized under Section 501(c)(4) or Section 527 of the Internal Revenue Code. Note that CVS Health makes contributions only to those 527 organizations that are campaign committees or political parties that are regulated by the Federal Election Commission or state campaign finance laws, whose transparency rules enable us to understand how our funds are used.
With respect to 501(c)(4) and 527 organizations, we disclose amounts paid to advocacy and/or political purposes for any organization whose CVS Health contribution is $25,000 or greater.
Disclosing CVS Health Colleagues Political Action
As with many corporations, we offer certain eligible colleagues an opportunity to participate in the political process by voluntarily contributing to the CVS Health Employees Political Action Committee (EPAC). Political to federal candidates, certain state candidates, political party committees and political action committees are made by our EPAC.
Consistent with federal law, CVS Health pays the administrative, solicitation and compliance costs ofthe committee. The activities of the CVS Health EPAC are subject to comprehensive regulation by the federal government and certain state governments, including detailed disclosure requirements.
Under the Lobbying Disclosure Act of 1995, CVS Health submits to Congress semi-annual reports, which also include a listing of CVS Health EPAC’s contributions to federal candidates. We report these contributions in the Political Activities and Contributions report on our website. Included on our website are disclosures of the contributions the CVS Health EPAC also makes at the state level. We also operate employee-funded state Political Action Committees (PACs) in Rhode Island, Massachusetts and New York.
CVS Health has a policy governing political contributions made from corporate and EPAC funds to ensure that all potential political contributions made by or on behalf of CVS Health or a CVS Health EPAC are reviewed and approved internally for compliance with all federal, state and local laws, and that all of the company’s political activities are conducted in accordance with high ethical standards. This policy applies to all colleagues of CVS Health, and each of its subsidiaries and affiliates. CVS Health does not make independent expenditures in federal, state or local elections. CVS Health requires certifications of compliance with this policy, generally through the company’s annual compliance training. Certifications must be submitted following training by all CVS Health representatives and colleagues at the director-level and above who maintain budgetary authority for potential political contributions.
CVS Health participates in various federal and state trade associations or organizations that operate in support of specific industries. Trade associations participate in activities such as education, advertising and lobbying to influence public policy. Many associations offer other services, such as producing conferences, networking or charitable events or offering classes or educational materials. Some associations also make political contributions or operate a PAC.
Details regarding CVS Health’s 2015 membership dues can be found in our annual Trade Association and Coalition Participation Report, along with past reports. These reports include the names of trade and industry associations to which we pay annual total dues of $25,000 or more and the amount of dues paid. The amount of such dues totaled $4.0 million in 2015, of which approximately $1.5 million was used for advocacy and/or political activities.