NCUIH September Policy Update: 2027 Policy Priorities, Appropriations Status, Medicaid Resources, and UIO Summit Preparation

In this Edition:

  • Questions for UIOs: Request for Input and Feedback
  • New and Forthcoming NCUIH Medicaid Resources
  • New Maternal Health Resources
  • Fiscal Year 2027 Appropriations Status
  • NCUIH Regulation Tracker Updates
  • Comment Opportunity: HRSA 340B Rebate Model Pilot Program
  • Submitted Federal Comments
  • NCUIH Participates in the National Tribal Health Conference
  • NCUIH Participates in NCAI Tribal Impact Week
  • Urban Indian Organization and Federal Partners Summit – NCUIH’s Preparation and Input Sessions
  • Upcoming Events and Policy Dates
  • 2027 NCUIH Annual Conference
  • Current Funding Opportunities

Questions for UIOs: Request for Input and Feeback

Request for Information on H R 1 Medicaid Exclusions

As a member of the Centers for Medicare & Medicaid Services Tribal Technical Advisory Group (TTAG), NCUIH is working to support proper implementation of the exclusions for American Indian and Alaska Native (AI/AN) people under the new H.R. 1 Medicaid provisions.

  • What definition is your state using for the exclusions for American Indian and Alaska Native people?
  • Are you concerned that your state may not include everyone who should qualify for the American Indian and Alaska Native exclusion?

Responses can be sent to policy@ncuih.org.

New and Forthcoming NCUIH Medicaid Resources

Overview of the Impact of Medicaid on Health Care for American Indian and Alaska Native People

This updated resource explains why Medicaid matters for American Indian and Alaska Native people and UIOs. It provides data, background, and information that UIO staff and leaders can use for education and understanding Medicaid’s role in Native health care.

Medicaid Is Changing

This quick-reference resource explains the new Medicaid work and renewal requirements, who may be protected by the American Indian and Alaska Native exemption, and the basic policy changes that staff, leaders, and patients should understand.

Forthcoming Medicaid Implementation Resources

NCUIH is developing two additional resources to help UIOs respond to the new Medicaid requirements:

  • UIO Implementation Guide: Steps UIO staff should have in place and actions staff can take when applicable protections are not recognized correctly.
  • Patient Handout: Steps patients should take after receiving a Medicaid work or renewal notice.

New Maternal Health Resources

NCUIH has released new resources highlighting best practices for improving American Indian and Alaska Native maternal health outcomes:

  • When the Data Gets It Wrong: Racial Misclassification of American Indian and Alaska Native Pregnant People is a blog post on addressing racial misclassification to improve data accuracy, interventions, programming, and maternal health outcomes.
  • American Indian and Alaska Native Led Maternal Mortality Review Committees is a one-page resource with recommendations to support the establishment of American Indian and Alaska Native-led Maternal Mortality Review Committees.

View the resources at ncuih.org/maternal-health.

Fiscal Year 2027 Appropriations Status

On September 2, 2026, the Continuing Appropriations and Extensions Act, 2027 (H.R.6500) was signed into law by the President. The Continuing Resolution (CR) funds the federal government through December 11, 2026 at Fiscal Year (FY) 2026 levels. The CR:

  • Prevents the administration from implementing the Office of Management and Budget’s (OMB) proposed grants rule for the duration of the continuing resolution.
  • OMB’s proposed Regulation for Federal Financial Assistance which will impact how nearly all grant awards are administered and overseen. NCUIH previously submitted comments on the proposal.
  • Extends authorizations for important health, veterans, infrastructure, and other programs for the duration of the continuing resolution.

Read on NCUIH’s blog.

NCUIH Regulation Tracker Updates

NCUIH tracks regulations and other federal agency actions that affect UIOs and American Indian and Alaska Native people living in urban areas. Recent regulations NCUIH has tracked:

  • Four letters from the Indian Health Service (IHS) addressing efforts to combat the syphilis epidemic, open positions at Tribal facilities and UIOs, the Continuing Appropriations and Extensions Act, 2027, and Director Mark Cruz’s dual role as IHS Director and U.S. Department of Health and Human Services Advisor.
  • Two letters from the Health Resources and Services Administration (HRSA) initiating Tribal Consultation on the 340B Rebate Model Pilot Program.

Visit ncuih.org/policy/regulation-tracker to follow current agency actions.

Comment Opportunity HRSA 340B Rebate Model Pilot Program

On August 3, the Health Resources and Services Administration (HRSA) published a notice launching the 340B Rebate Model Pilot Program, which is scheduled to take effect January 1, 2027. Under the pilot, covered entities, including UIOs participating in the 340B Drug Pricing Program, would pay the full price upfront for a limited set of drugs and receive a manufacturer rebate within 10 days. HRSA held a Tribal Consultation on September 16, 2026 in response to requests from Tribal leaders and Tribal-serving organizations. Tribal stakeholders are encouraged to submit written testimony or comments directly to HRSA.

Read more on NCUIH’s blog.

Submitted Federal Comments

NCUIH Submits Comments to IHS on Health Information Technology Modernization

On September 4, NCUIH submitted comments to IHS on its Health Information Technology Modernization Roadmap to Cohorts following the August 6 Tribal Consultation and Urban Confer. NCUIH recommended that IHS clarify the criteria for Cohort One and continue engaging UIOs throughout implementation of Health Information Technology Modernization.

NCUIH Submits Comments to CMS on Current Procedural Terminology

On September 14, NCUIH submitted comments to the Centers for Medicare & Medicaid Services in response to its Current Procedural Terminology Request for Information – potential updates to health care coding policies. NCUIH emphasized the need to minimize administrative burden on Indian Health Care Providers – including UIOs, ensure a smooth implementation process for any future changes, and protect reliable reimbursement for services.

NCUIH Joins Indian Country Partners at the National Indian Health Board’s National Tribal Health Conference

From August 17-20, NCUIH participated in the National Indian Health Board’s National Tribal Health Conference in Phoenix, Arizona, where NCUIH and UIO leaders connected with newly confirmed IHS Director, Mark Cruz. NATIVE Health CEO, Walter Murillo (Choctaw), moderated a panel with Kelly Rowe (Grand Ronde) and Angie Wilson (Klamath) to discuss A New Era for Traditional Healing: Celebrating Progress and Shaping the Future, highlighting traditional healing practices and on-the-ground implementation experience.

NCUIH Submits Comments to Arizona Medicaid Program on Traditional Healing Demonstration

On September 6, NCUIH submitted comments on an Arizona Medicaid amendment for UIOs seeking to participate in the Traditional Healing program. NCUIH asked Arizona to ensure timely implementation of Traditional Healing reimbursement at UIOs and to identify and secure the non-federal share needed to reimburse UIOs, which do not currently receive 100% FMAP.

NCUIH Participates in NCAI Tribal Impact Days

   

   

NCUIH joined the National Congress of American Indians (NCAI) for Tribal Impact Days in Washington, D.C. During a session in the Senate Committee on Indian Affairs Hearing Room, NCUIH heard from Senators Tina Smith (D-MN), Lisa Murkowski (R-AK), and other members of Congress about their work on behalf of Indian Country. NCUIH also connected with NCAI Executive Director Larry Wright, Jr., Tribal leaders, and Native organizations working on federal policy priorities. The week concluded at the National Museum of the American Indian with a reception celebrating the Tribal Supreme Court Project’s 25 years of coordinating Supreme Court strategy on cases affecting Tribal Nations.

SAVE THE DATE: UIO and Federal Partners Summit Preparation and Input Sessions

NCUIH is preparing UIOs for the upcoming Urban Indian Organization and Federal Partners Summit in Washington, D.C. set to be held on November 19, 2026, in Washington D.C. NCUIH will host two virtual sessions to gather input, share available information, and help UIOs prepare for the Summit.

October 21: UIO Summit Preparation and Input Session. This virtual session will gather UIO input and support early preparation for the Summit. Invite forthcoming.

November 10: UIO Summit Preparation Session. This virtual session will go over general Summit prep and logistics for UIOs. Invite forthcoming.

  • NCUIH also plans to host an in-person gathering for UIOs in Washington, D.C. RSVP required. Details to follow.

Upcoming Events and Policy Dates

  • September 22-24: U.S. Department of Health and Human Services Secretary’s Tribal Advisory Committee Meeting, San Diego, California.
  • September 30: NCUIH 2027 Policy Priorities Survey deadline.
  • October 1: Written comments due to HRSA on the 340B Rebate Model Pilot Program.
  • October 13: National Indian Health Board Medicare Medicaid and Health Reform Policy Committee Face-to-Face Meeting, Washington, D.C.
  • October 14-15: Centers for Medicare & Medicaid Services Tribal Technical Advisory Group Face-to-Face Meeting, Washington, D.C.
  • October 15: IHS Division of Urban Indian Affairs UIO Chief Executive Officer Monthly Conference Call, virtual.
  • October 21: NCUIH Monthly Policy Work Group and UIO Summit Preparation and Input Session, virtual.
  • November 10: UIO Summit Preparation Session, virtual, pending IHS approval.

2027 NCUIH Annual Conference

The 2027 NCUIH Annual Conference will be held May 3-6, 2027, at Westin Washington, D.C. Downtown.

We are excited to welcome Urban Indian Organizations, health care professionals, policymakers, community leaders, advocates, and partners from across the country. Through educational sessions, networking opportunities, and advocacy-focused discussions, attendees will connect, share best practices, strengthen partnerships, and explore solutions to critical issues impacting urban Indian health. Together, we will advance efforts to improve the health and well-being of urban Indian communities.

Conference Agenda:

  • May 3: Board Training – Board Training is free and does not require conference registration. Select the “IHS and NCUIH-Sponsored Events” ticket and choose “Yes, register me” for Board Training.
  • May 4-5: Conference Programming
  • May 6: Hill Day – Participation is limited to staff and leadership of IHS-funded UIOs. Pre-registration is required and will be sent out in March 2027.

Important Deadlines:

  • Early Bird Registration Deadline: December 18, 2026
  • Call for Proposals Submission Deadline: November 3, 2026
  • Award Nominations Open: October 5, 2026

Learn more at ncuih.org/conference.

Current Funding Opportunities

Indian Health Service Fiscal Year 2026 Urban Emergency Fund

  • Purpose: To help UIOs address costs associated with one-time, non-recurring emergencies and disaster relief efforts.
  • Award: A limited discretionary fund with up to $250,000 available.
  • Application deadline: As soon as reasonably practicable after the emergency occurs.

Visit the NCUIH website to explore the full list of funding opportunities.

About NCUIH

The National Council of Urban Indian Health (NCUIH) is a national representative for the 41 Urban Indian Organizations contracting with the Indian Health Service under the Indian Health Care Improvement Act. NCUIH is devoted to the support and development of high quality and accessible health and public health services for American Indian and Alaska Native people living in urban areas.

NCUIH respects and supports Tribal sovereignty and the unique government-to-government relationship between our Tribal Nations and the United States. NCUIH works to support those federal laws, policies, and procedures that respect and uplift Tribal sovereignty and the government-to-government relationship. NCUIH does not support any federal law, policy, or procedure that infringes upon or in any way diminishes Tribal sovereignty or the government-to-government relationship.

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NCUIH Calls for Meaningful Urban Indian Organization Engagement in State Implementation of New H.R. 1 Medicaid Community Engagement Requirements

On July 31, 2026, the National Council of Urban Indian Health (NCUIH) submitted written comments to the Centers for Medicare and Medicaid Services’ (CMS) Administrator, Dr. Mehmet Oz, regarding CMS’ interim final rule with comment period (IFC), “Medicaid Program; Community Engagement Requirement for Certain Individuals.” In the written comments, NCUIH recommended that CMS advise states to engage meaningfully with Urban Indian Organizations (UIOs) through Urban Confer when developing, modifying, or implementing policies, procedures, or operational processes related to the American Indian and Alaska Native exclusion.

Background on the IFC

On July 4, 2025, the President signed the H.R. 1 into law. The H.R. 1 delivers many elements of President Trump’s legislative agenda, including new requirements for access to Medicaid and Supplemental Nutrition Assistance Program (SNAP). Indians, Urban Indians, California Indians, and individuals determined eligible as an Indian for the Indian Health Service under regulations promulgated by the Secretary are excluded from the Medicaid requirements in the H.R. 1 and included in exclusions for the SNAP work requirements.

On June 3, 2026, CMS published the (IFC) in the Federal Register to interpret and implement the community engagement requirement in the H.R. 1.

NCUIH’s Recommendations

In its comments, NCUIH recommended CMS:

  • Advise states to accept self-attestation as sufficient to establish eligibility for the American Indian and Alaska Native exclusion
  • Advise states to partner with UIOs, Tribes, and Tribal Organizations to prevent procedural disenrollments of American Indian and Alaska Native beneficiaries
  • Require states to collect data on implementation of the American Indian and Alaska Native exclusion
  • Use strong, consistent language in every instance of the final rule when discussing states not reverifying American Indian and Alaska Native status
  • Advise states to engage meaningfully with UIOs through Urban Confer when developing, modifying, or implementing policies, procedures, or operational processes related to the American Indian and Alaska Native exclusion

NCUIH will continue to closely follow the development and implementation of CMS’ final rule.

NCUIH Resources:

  • Overview of the Impact of Medicaid on Health Care for American Indian and Alaska Native People: This updated resource explains why Medicaid matters for American Indian and Alaska Native people and UIOs. It provides data, background, and information that UIO staff and leaders can use for education and understanding Medicaid’s role in Native health care.
  • Medicaid Is Changing: This quick-reference resource explains the new Medicaid work and renewal requirements, who may be protected by the American Indian and Alaska Native exemption, and the basic policy changes that staff, leaders, and patients should understand.
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House Unanimously Passes NCUIH-Endorsed Bipartisan Bill to Elevate Indian Health Service Leadership Within HHS

On September 15, 2026, the House unanimously passed the bipartisan Stronger Engagement for Indian Health Needs Act of 2025 (H.R.741). The bill, which was introduced in the House of Representatives by Congressmen Greg Stanton (D-AZ-04) and David Joyce (R-OH-14), would formally elevate the IHS Director’s position within the federal government, strengthening Tribal representation in federal health decision-making and reinforcing the federal government’s trust responsibility to provide health care to American Indian and Alaska Native people.

The bill was endorsed by the National Council of Urban Indian Health (NCUIH), National Congress of American Indians, and the National Indian Health Board.

Representative Stanton Press Release.

Next Steps

The bill will now need to be passed by the Senate. The Senate currently has companion legislation which was introduced by U.S. Senators Catherine Cortez Masto (D-NV) and Mike Rounds (R-SD).

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Congress Extends Government Funding Through December

On September 2, 2026, the Continuing Appropriations and Extensions Act, 2027 (H.R.6500) was signed into law by the President. The Continuing Resolution (CR) will maintain funding for the federal government at the Fiscal Year (FY) 2026 levels through December 11, 2026. Additionally, the CR also delays OMB’s proposed overhaul of the Uniform Guidance rule governing federal financial assistance, prohibiting the agency from finalizing that rule before December 11, 2026.

Congress will now have until the end of the CR to negotiate and pass full-year FY 2027 appropriations bill. NCUIH will monitor congressional negotiations as they work towards a final full year appropriations bill.

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HRSA to Hold Tribal Consultation on 340B Rebate Model Pilot Program

WASHINGTON, D.C. (September 3, 2026) – The Health Resources and Services Administration (HRSA) will hold a Tribal Consultation on its 340B Rebate Model Pilot Program on Wednesday, September 16, 2026, from 3:00 to 5:00 p.m. ET. The virtual session, held via Zoom and initiated pursuant to Executive Order 13175, was announced in an August 28, 2026, Dear Tribal Leader Letter from RADM Krista Pedley, Acting Associate Administrator, in response to requests from Tribal leaders and Tribal-serving organizations. Tribal stakeholders who are unable to attend are encouraged to submit written testimony or comments directly to HRSA.

The National Council of Urban Indian Health (NCUIH) encourages Tribal representatives to register and engage in this important consultation. Feedback that may be helpful to include could address anticipated cash-flow or operational impacts specific to your organization, how current 340B savings support patient care, administrative or staffing capacity needed to manage rebate claims, and any experience with delayed or denied claims in similar programs.

In the Dear Tribal Leader Letter announcing the Consultation, RADM Krista Pedley, HRSA’s Acting Associate Administrator, wrote that HRSA intends to use the session to discuss how the Rebate Pilot will help the agency balance Tribal stakeholder concerns against its goal of testing a rebate model in the 340B Program, gather data on how the 340B ceiling price is effectuated through rebates, generate data relevant to other federal drug pricing programs including the Medicare Drug Price Negotiation Program, and improve transparency to inform future policy decisions. HRSA framed the session as an opportunity to hear directly from Tribes, describing its intent to “welcome concerns and input” as the agency works to implement the Pilot, and characterizing the Consultation as part of the agency’s broader government-to-government relationship with Tribal Nations.

Background

On August 3, 2026, HRSA published a Federal Register notice launching the 340B Rebate Model Pilot Program, effective January 1, 2027. Under the Pilot, covered entities, including UIOs participating in 340B, would pay full price upfront for a limited set of drugs and receive a rebate from the manufacturer within a 10-day window. HRSA states that this design is expected to keep cash-flow impact minimal for covered entities generally.

NCUIH appreciates HRSA’s engagement on this issue and has shared with the agency that a 10-day rebate window may still pose challenges for Indian Health Care Providers operating on tight margins, particularly if a rebate claim is denied and enters an appeals process, which could further delay payment. NCUIH’s analysis shows that UIO 340B participants’ cash outlay could rise by as much as $342,716.14 annually under this model. Twenty-five of the 41 IHS-funded UIOs currently participate in the 340B program, and many operate with limited cash reserves and narrow margins that leave little capacity to absorb delayed rebate payments.

Tribes and Indian Health Care Providers have engaged in advocacy on HRSA’s 340B Rebate Model Pilot Program since it was announced, and across both iterations of the proposed program. NCUIH has consistently advocated for an exemption for Indian Health Care Providers, including UIOs.

In December 2025, NCUIH sent a letter to HRSA Administrator Thomas J. Engels requesting an exemption for UIOs and Indian Health Care Providers from the Pilot, and published a press release and one-pager on the issue, impact, and policy ask.

In April 2026, NCUIH submitted formal comments to HRSA requesting an exemption for Indian Health Care Providers, including UIOs, consistent with requests developed alongside the HHS Secretary’s Tribal Advisory Committee (STAC) and the CMS Tribal Technical Advisory Group (TTAG). See the TTAG comment letter to HRSA (April 20, 2026).

Participant Information

What: HRSA Tribal Consultation on the 340B Rebate Model Pilot Program
Date: Wednesday, September 16, 2026 Time: 3:00 – 5:00 p.m. ET
Location: Virtual (Zoom) Registration: Register here
Written comment deadline: Thursday, October 1, 2026, to tribalconsultation@hrsa.gov
Questions: Commander Sharyl Trail, Director, HRSA Office of Tribal Affairs, strail@hrsa.gov

Resources

The Need for Exemption for Indian Health Care Providers from 340B Pilot
HRSA Federal Register Notice on the 340B Rebate Model Pilot Program (August 3, 2026)

About NCUIH

The National Council of Urban Indian Health (NCUIH) is a national representative for the 41 Urban Indian Organizations contracting with the Indian Health Service under the Indian Health Care Improvement Act. NCUIH is devoted to the support and development of high quality and accessible health and public health services for American Indian and Alaska Native people living in urban areas.

NCUIH respects and supports Tribal sovereignty and the unique government-to-government relationship between our Tribal Nations and the United States. NCUIH works to support those federal laws, policies, and procedures that respect and uplift Tribal sovereignty and the government-to-government relationship. NCUIH does not support any federal law, policy, or procedure that infringes upon or in any way diminishes Tribal sovereignty or the government-to-government relationship.

NCUIH Contact: Meredith Raimondi, Senior Vice President of Policy and Communications, mraimondi@ncuih.org

 

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