On February 13, 2023, the Indian Health Service (IHS) sent a Dear Urban Indian Organization Leader letter (DULL) clarifying use of funds requirements from the Fiscal Year (FY) 2022 Urban Indian Organization (UIO) Infrastructure Study as a follow-up to the virtual Urban Confer convened by the IHS on June 23, 2022. In the letter, IHS emphasized that “…the joint explanatory statement accompanying the Consolidated Appropriations Act, 2022 (CAA, 2022) does not mean Congress intends to allocate additional funding for UIO Infrastructure Activities. Instead, Congress intends to ensure that the additional funding provided remains in the Direct Operations accounts of IHS management use.” IHS notes that this aligns with UIO Confer recommendations to avoid using the funding for any additional UIO Infrastructure Study activities.
In 2021, Congress allocated $1 million in funds for IHS to conduct an Urban Indian Infrastructure study through the Consolidated Appropriations Act, 2021. The purpose of the Infrastructure Study aims to better understand the most critical deficiencies facing UIOs. On March 15, 2022, Congress provided $800,666 in additional funding to IHS for the Infrastructure Study through the CAA, 2022. On June 16, 2022, IHS requested input from UIO leaders regarding the additional funding from the CAA, 2022 on how these funds can be utilized by IHS. On June 23, 2022, UIO Leaders and NCUIH attended an Urban Confer where IHS explained that the Infrastructure Study will be completed by December 31, 2022, with results scheduled for release in January 2023. Results have not been released as of February 2023.
NCUIH’s Recommendations to IHS
On August 23, 2022, NCUIH submitted comments to IHS in response to the June 16, 2022 DULL regarding the use of funding available for the Urban Indian Infrastructure Study. NCUIH made the following recommendations regarding the Infrastructure Study:
- Provide UIOs with the findings from the first Infrastructure Study prior to making any decisions regarding use of the additional funds
- It is crucial that UIOs are aware of the scope, results, and usefulness of the Infrastructure Study before they make any recommendations regarding the use of the further funding.
- Given the timeline presented during the Urban Confer, there was an 8-month window in which UIOs and IHS will be able to review the Infrastructure Study results following their scheduled release in January 2023 and decide as to the best use of the additional funding
- OUIHP should provide a timeline of the Planning Process to UIOs
- NCUIH requested a timeline be released to UIOs delineating when the initial Infrastructure Study will be released, the contracting process necessary to use the additional funding, and the deadline for the obligation of the additional funding.
- The requested timeline will provide clarity to UIOs. With a clearer picture in mind, the planning process and use of the additional FY22 funds for the Infrastructure Study becomes more cooperative between UIOs and IHS.
- IHS should host an additional Urban Confer after releasing the results of the Infrastructure Study.
- NCUIH notes that informed feedback from UIOs creates a scenario where the additional funding can be best used to support the needs of UIOs.
NCUIH continues to advocate for transparency in the process of the Infrastructure Study and greater support to address the critical infrastructure needs at UIOs. NCUIH will continue to keep UIOs informed as more information is made available from IHS.