CVS Caremark participates in the political process to help shape public policy and address legislation that has a direct impact on the company. The engagement ensures that the interests of our business, customers, shareholders and employees are fairly represented at all levels of government.
As a health care company, CVS Caremark believes that staying informed on political matters that impact how health care is delivered, which in turn impacts our business and our customers, is critically important. It is CVS Caremark policy that the CEO and the Board of Directors are responsible for determining the company’s policy and political interests and deciding how to further those interests in a manner that is consistent with applicable laws. Our activities include lobbying, campaign contributions, educational outreach, and other related activities that promote efforts to improve how pharmacy care is delivered in this country.
CVS Caremark’s Government Affairs team represents the company’s point of view in Washington, D.C. and in state capitals around the country. Working with the businesses, the Government Affairs team focuses on legislative and public policy issues that impact the company’s delivery of pharmacy care and long-term business interests and communicates with policymakers and stakeholders on issues that impact our business. These issues include:
- Privacy and protected health information
- Labor and workplace issues
- Restructuring of corporate tax rates
- Plan design, reimbursement and cost-savings proposals related to Medicare and Medicaid
- Health care delivery system reforms
- Proposed changes within United States Postal Service delivery schedule
- Prescription drug abuse, drug supply chain safety and prescriber education
Lobbying is highly regulated in the United States, and CVS Caremark complies with applicable U.S. federal and state 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. CVS Caremark’s federal lobbying reports can be found at http://lobbyingdisclosure.house.gov/.
As a public corporation, CVS Caremark is prohibited by federal law from making contributions to candidates or political parties in federal elections. As with many corporations, CVS Caremark offers certain eligible employees an opportunity to participate in the political process by voluntarily contributing to the CVS Caremark Employees Political Action Committee (EPAC). Political contributions to federal candidates, political party committees and political action committees are made by the company’s EPAC. Consistent with federal law, CVS Caremark pays the administrative, solicitation and compliance costs of the EPAC.
The activities of the CVS Caremark-EPAC are subject to comprehensive regulation by the federal government, including detailed disclosure requirements. The CVS Caremark-EPAC files monthly reports of receipts and disbursements with the Federal Election Commission (FEC), as well as pre-election and post-election FEC reports. All political contributions over $200 are shown in the public information made available to the FEC. Under the Lobbying Disclosure Act of 1995, CVS Caremark submits to Congress semi-annual reports, which also include a listing of CVS Caremark-EPAC’s contributions to federal candidates. Those reports are publicly available at http://lobbyingdisclosure.house.gov/.
In addition to contributions at the federal level, the CVS Caremark-EPAC also makes state-level contributions in some states, which are disclosed as required by law, and operates employee-funded state PACs in Rhode Island, Massachusetts and New York.
All contributions made by the CVS Caremark-EPAC, including the identity of the recipients and the amounts paid to each, are reported on the company’s website at http://info.cvscaremark.com/contributions.
Corporations are permitted to make political contributions at the state and local level, which are subject to regulation by individual states. Although some states have not banned corporate contributions to candidates or political parties, all states require that such contributions be disclosed either by the recipient or by the donor. Any information regarding the corporate contributions made by CVS Caremark to state candidates, political parties or ballot initiative committees is publicly available.
In 2010, the U.S. Supreme Court ruled that corporations have a First Amendment right to make independent expenditures, including advocating for the election or defeat of a clearly identified federal candidate. (See Citizens United v. FEC). Despite this ruling, CVS Caremark has not made any independent expenditures in federal, state or local elections.
CVS Caremark 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 Caremark or a CVS Caremark-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 employees of CVS Caremark, and each of its subsidiaries and affiliates. CVS Caremark requires certifications of compliance with this policy generally through the company’s annual compliance training. Certifications must be submitted following such training by all CVS Caremark representatives and director-level employees and above who maintain budgetary authority for potential political contributions. All of the company’s contributions promote the interests of the company and are made without regard for the private political preferences of company officers and executives.
In addition to EPAC contributions, details regarding CVS Caremark’s corporate political contributions, including the identity of the recipients and the amounts paid to each, are updated on the company’s website at http://info.cvscaremark.com/contributions.
Trade Association Participation
CVS Caremark participates in various federal and state trade associations or organizations that operate in support of specific industries. Trade associations participate in public relations 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.
In 2012, CVS Caremark paid approximately $1.3 million in dues to trade and industry associations for advocacy and/or political activities. Details regarding CVS Caremark’s trade association membership dues can be found at http://info.cvscaremark.com/associations and are updated annually. These reports include the amount paid for advocacy and/or political purposes for any trade or industry association with annual total dues of $25,000 or more.