🚨 Special Interests Co-Opted CMS Rulemaking Defying Science 🚨
→ Greg Segal and Jennifer Erickson, Organize, Inc.
The Greg Segal, Jennifer Erickson, and Organize Inc conspiracy to fracture the nonprofit organ donation system began during the Obama Administration after their initial failure to monetize the system. It continues through the present, despite having no medical background as CMS notes in the FOIA emails.
→ Arnold Ventures formerly Arnold Foundation
Founded by former Enron executive John Arnold, has provided at least $1.16 million in grants to Organize, Inc, Arnold also funded subsequently debunked “science” through Bridgespan, Bloomworks, as a basis for subverting the organ donation governing rule adoption and public discourse.
→ Dr. Ray Lynch
Chief of the Organ Transplant Branch, Division of Transplantation (DOT), HRSA (Health Resources and Services Administration) Dr. Lynch before his appointment in the Biden Administration testified in favor of for-profit donation and transplantation before the Senate Finance Committee. He has a history with Organize Inc. funded by Arnold Ventures.
Read sample emails obtained by a FOIA request to CMS from SID&T→
On June 18th, We Revealed the Bombshell FOIA Email Regarding the Outflanking of CMS: Who Outflanked CMS and Subverted the Process?
The Players Key to the Following FOIA Emails
Special Interests Co-Opted CMS Rulemaking Defying Science
Below are a sample of the emails obtained through a FOIA request to CMS from SID&T that lay out the development of the scheme.
From: bryan@tragos.org [mailto:bryan@tragos.org1 On Behalf Of Bryan Sivak
Sent: Tuesday, August 23, 2016 5:47 AM
To: Shantanu.Agrawal@cms.hhs.gov; Ciccarone, Michael <Michael.Cicca rone@bridgespan.org>
Subject: Intro to the Bridgespan group
Shantanu,
Given your role as the "organ czar" (maybe I should come up with a different title for that...) I wanted to connect you to a team from the Bridgespan Group (Mike Ciccarone is copied here). They are a nonprofit consulting firm that is doing research on policy changes in the organ donation and transplantation space.
They are doing a project to identify policy initiatives that could increase the number of transplants and are hoping to talk with some people at CMS and HRSA to refine these ideas and get a sense of what is required for statutory and regulatory changes. I spoke with them recently and I think they could learn a lot from you.
Mike, Shantanu is a good friend and the Director of the CMS Center for Program Integrity, as well as running point on the organ work that the agency has recently agreed to work on.
Over to you guys!
Bryan
This email marks the start of the 2016 push by Arnold Ventures (then Laura and John Arnold Foundation) to capture federal OPO policy through lobbying CMS with predetermined “research” results.
From: Ciccarone, Michael
Sent: Thursday, September 22, 2016 3:48 PM
To: 'Shantanu.Agrawal@cms.hhs.gov' <Shantanu.Agrawal@cms.hhs.gov>; 'Kate.Goodrich@cms.hhs.gov' < Kate.Goodrich@cms.hhs.gov>; 'Shari.Ling@cms.hhs.gov' <Shari. Ling@cms.hhs.gov>; 'Mary.Greenel@cms.hhs.gov' <Mary.Greenel@cms.hhs.gov>; 'Jonathan. Morse@cms.hhs.gov' <Jonathan.Morse@cms.hhs.gov>; 'Tennille.Brown@cms.hhs.gov' <Tennille.Brown@cms.hhs.gov>; 'Melissa. Heesters@cms.hhs.gov' <Melissa.Heesters@cms.hhs.gov>; 'Melissa.Cooley@cms.hhs.gov' <Melissa.Cooley@cms.hhs.gov>
Cc: 'Simms, Bridget (CMS/CPI)' <Bridget.Simms@cms.hhs.gov>; Ramirez, Juan <Juan.Ramirez@bridgespan.org>; Fu, Lily <Lily.Fu@bridgespan.org>
Subject: Introduction to the Bridgespan Group - Agenda for 2PM meeting tomorrow
Dear Dr. Agrawal and team,
We're looking forward to our conversation tomorrow at 2PM-I will come in person to the Hubert Humphrey Building, and my colleague Juan Ramirez will be joining via VTC. Please find a suggested agenda below, and some context for our work (which we can expand upon tomorrow).
Context for our work: The Bridgespan Group is a nonprofit consulting firm that collaborates with mission-driven leaders to achieve positive social change. This project, funded by the Laura and John Arnold Foundation, is focused on identifying
policy initiatives that could improve the organ donation, procurement, and transplantation space. We are three months into our research and have developed some perspectives which we are now testing with the field, and believe your insights will be invaluable at this stage.
Agenda:
Introduction to our work and objectives
Discuss areas of potential improvement to the organ donation system
Discuss process to facilitate policy change and potential barriers
I look forward to speaking with you soon, and please don't hesitate to reach out with any questions or concerns in the meantime.
Demonstrates Arnold Ventures use of funded proxies (Bridgespan) to engage CMS directly, part of their multi-year “research” and lobbying campaign that ultimately shaped the 2020 Final Rule.
From: Roach, Jesse L. (CMS/CCSQ) [mailto:Jesse.Roach@cms.hhs.gov]
Sent: Tuesday, October 17, 2017 3:25 PM
To: Walsh, Robert (HRSA) <RWalsh@hrsa.gov>; Schwartz, Daniel L. (CMS/CCSQ) <Daniel.Schwartz2@CMS.hhs.gov>; Wilkerson, Peggye A. (CMS/CCSQ) <Peggye.Wilkerson@cms.hhs.gov>; Rice, Melissa C. (CMS/CCSQ) <Melissa.Rice@cms.hhs.gov>
Cc: Jennifer Erickson (B)(6) Oviatt, Lauren E. (CMS/CCSQ) <lauren.oviatt@cms.hhs.gov>
Subject: RE: Transplant metrics for OPOs
I am copying Jennifer on this email. If everyone could give me their ability for a meeting this this week or next, that would be great. I will then set up a meeting so we can get together.
Jesse
Jennifer Erickson, sponsored by Arnold Ventures, embedding herself inside CMS to advance Arnold Ventures and Organize Inc. policy goals.
From: Wickliffe, Jim (CMS/OSORA) <Jim.Wickliffe@cms.hhs.gov>
Sent: Thursday, April 18, 2019 6:34 AM
To: Postma, Terri L. (CMS/CM) <Terri.Postma@cms.hhs.gov>; Barringer, Elise (CMS/CM) <elise.barrinqer@cms.hhs.gov>; Swygert, Tiffany T. (CMS/CM) <Tiffany.Swyqert@cms.hhs.gov>; Corning, Diane H. (CMS/CCSQ) <Diane.Corninq@cms.hhs.gov>; French, Beth A. (CMS/CM) <Beth.French@cms.hhs.gov>; Ahern, Robert J. (CMS/CM) <Robert.Ahern@cms.hhs.gov>; Henry, Renee G (CMS/CCSQ) <Renee.Henry@cms.hhs.gov>; Renals, Kayla B. (CMS/CCSQ) <Kayla.Renals@cms.hhs.gov>; Parker, Lisa M. (CMS/CCSQ) <Lisa.Parker@cms.hhs.gov>; Rice, David (CMS/CM) <David.Ricel@cms.hhs.gov>; Barco, Evell J. (CMS/OSORA) <Evell.Barco@cms.hhs.gov>; Owens, Bryan C. (CMS/OSORA) <Bryan.Owens@cms.hhs.gov>; Wilson, Lynette N. (CMS/OSORA) <Lynette.Wilson@cms.hhs.gov>; Garcia, Vanessa (CMS/OSORA) <Vanessa.Garcia@cms.hhs.gov>; Collins, Mary E. (CMS/CCSQ) <Mary.Collins@cms.hhs.gov>; Blackstock, Sheila C. (CMS/CCSQ) <Sheila.Blackstockl@cms.hhs.gov>; Jones, Martique S. (CMS/OSORA) < Martique.Jones@cms.hhs.gov>; Harris, SheIi E. (CMS/OSORA) <Sheli.Harris@cms.hhs.gov>; Lafferty, Tiffany R. (CMS/OSORA) <Tiffany.Lafferty@cms.hhs.gov>; Hubbard, Lisa A. (CMS/OSORA) <Lisa.Hubbard@cms.hhs.gov>; Cantwell, Kathleen M. (CMS/OSORA) <Kathleen.Cantwell@cms.hhs.gov>; Miller, Ruth A. (CMS/OSORA) <Ruth.Miller@cms.hhs.gov>; Swann, Renee L. (CMS/OSORA) <Renee.Swann@cms.hhs.gov>
Subject: RE: CMS-1717-P--OPPS Segment 1 (0MB PASSBACK) Attached is OMB's passback on segment 1 and below is a question related to OPPS OPO (which I believe is still being discussed, so it is not clear how germane these comments might be).
Hi Aaron and Rebecca,
Please find attached passback on Seg 1 of OPPS - please note that we did not review the OPO section per HHS request and will await a revised copy and a briefing when HHS is ready. In addition please find two broader comments stemming from the briefing:
We commend CCSQ for its interest in reforming the OPO process. We concur on the importance of this issue and agree we are overdue for change. We request that the agency strengthen its approach overall to increase the likelihood that changes lead to efficiency gains and increased organ transplantation. One specific that comes to mind is that the RFI should be turned into a proposal as we have a clear sense of logical steps to take in this space based on the proposal brought forward by ORGANIZE and the Arnold Foundation.
Would request CCSQ come back with a list of the changes they would like to make in the OPO space and an assessment for how each change will impact the system (i.e., number of additional organ procured). It would be helpful for HHS to aim for a robust shift in line with Secretary Azar's remarks. When ready, would appreciate a briefing from CCSQ on their approach. If possible to have Senior Advisor Boehler speak in that briefing to how the proposal meets the Secretary's call to transform kidney care that would be helpful.
Thank you for the background provided on skin substitutes. Recommend CMS indicate in OPPS that they will develop a quality or outcome linked basis to justify having different categories. In the interim, recommend the CMS propose paying an average amount to both categories. This is prompted by a concern that the high and low categories may set up a bad incentive structure that distorts development and puts upward pressure on cost.
Please let me know if there are any questions. Will anticipate receiving segment 2 soon.
Thanks,
Q
Explicit reference to “the proposal brought forward by Organize Inc. and the Arnold Foundation.”
Subverting Regulatory Procedure: An Organize Inc and Arnold Ventures History
Organize, Inc. was founded by hedge fund investor Greg Segal and marketer Jenna Arnold to “reform” organ donation.
In 2014, Organize, Inc. touted a hybrid for-profit/nonprofit model, hoping to license its proprietary tech and social media consulting.
Organize, Inc. sought to replace existing, no-cost OPO services with costly, unproven methods.
Organize, Inc. also announced a new data scraping technology called “53”, the development of which cost them over a million dollars. OPOs roundly rejected this technology as meaningless, and none implemented it.
Organize, Inc.’s clumsy implementation was blocked in California due to its unauthorized insertions of the few registrations it gathered into the official state organ donor registry.
Facing rejection by the OPOs, Organize, Inc. shifted focus to government officials and the media.
In 2016, Organize, Inc. partnered with White House staffer Jennifer Erickson to host the 2016 White House Organ Donation Summit.
The Summit also announced a project with the Laura and John Arnold Foundation.
As the FOIA emails report, CMS officials noted neither Erickson nor Segal have a medical background.
Laura and John Arnold Foundation, Inc.
The Foundation funded media and consultants Bridgespan Group, Bloomworks, and Project on Government Oversight (POGO) to create separate white papers attacking the OPOs and arguing for private technology to run the system instead.
Starting in 2017, Organize, Inc. began aggressively lobbying the Trump administration and Congress.
In 2018 and 2019, Organize, Inc. spent more than half-million dollars lobbying.
Organize, Inc. hired the Bridgespan Group, closely aligned with Bain Capital, as consultants.
Media Attack Campaign
Organize, Inc. hired Bridgespan Group for $114,000 in 2016.
Laura and John Arnold Foundation hire the Bridgespan Group to draft a white paper study titled “Reforming Organ Donation in America” that purports to be independent but is instead flawed and self- referential.
This non-peer-reviewed study concludes that OPOs were “monopolies,”“unaccountable,” and non- transparent.
The primary source of data is a widely criticized study co-authored by Greg Segal and Jenna Arnold (i.e., “Organize, Inc.”) funded by Laura and John Arnold Foundation.
The white paper serves as the primary source for articles, Congressional investigatory letters, blog entries, and newspaper stories.
CMS and Congress to date have ignored the 22 peer-reviewed studies clearly showing the flaws on the Bridgespan Goldberg Segal conclusions.
https://sidandt.org/the-science/peer-reviewed-science
Kaiser Health News runs a favorable editorial about Organize, Inc. after Kaiser Family Foundation receives a $1 million grant from Arnold Foundation – A VP of Kaiser Family Foundation is a Board member of Organize, Inc.
In 2020 Organize, Inc. receives funding from a new private backer, Schmidt Futures. Schmidt Futures engages Jennifer Erickson (formerly of the Bridgespan Group and Bain Capital).
Jennifer Erickson authors several articles criticizing OPOs, arguing the system needs centralized control.
In October 2020 POGO authors an article attacking OPOs for questioning the new proposed rules.
POGO received $400,000 in funding from Arnold Ventures.
POGO piece extensively quotes Bridgespan and related groups work.
Legislators under pressure open investigations into OPOs, extensively referencing the same white papers and media.
Citing identical white papers and media as fact, regulators propose new rules relying on arbitrary standards that will result in 1/3 of the nation’s OPOs closing every four years, eventually virtually eliminating OPOs.
The Laura and John Arnold Foundation was restructured as a limited liability company and renamed Arnold Ventures in January 2019.