STATEMENT: NCUIH Responds to HHS Advisory Opinion: Safeguarding Native Healthcare Amid Policy Shifts

FOR IMMEDIATE RELEASE

WASHINGTON, D.C. (February 26, 2025) – The National Council of Urban Indian Health (NCUIH) welcomes the Advisory Opinion issued by the Department of Health and Human Services (HHS) Office of General Counsel on February 25, 2025. This opinion reaffirms that recent Executive Orders do not alter the federal government’s trust responsibility to provide healthcare for American Indian and Alaska Native (AI/AN) people. This opinion clarifies that recent Executive Orders do not alter the federal government’s distinct legal obligations to Indian Tribes and their citizens, as established by treaties, statutes, and the U.S. Constitution. It also notes that certain policies at Indian Health Service (IHS) facilities must comply with these Executive Orders.

This action reflects responsiveness to calls from Tribal leaders and Native organizations urging the administration to uphold its trust obligations. NCUIH has consistently advocated for the protection of the Indian health system, including Urban Indian Organizations (UIOs), which provide health services for AI/AN people.

Francys Crevier (Algonquin), CEO of NCUIH, stated:

“We appreciate the Administration’s affirmation of the federal trust responsibility to provide healthcare for American Indian and Alaska Native people. Native-led Urban Indian Organizations play a critical role in delivering essential services to Native populations, and any policy changes must prioritize the health and well-being of our people.”

NCUIH calls on policymakers to continue listening to Tribal voices and Native organizations and uphold the federal trust responsibility without compromise. NCUIH remains steadfast in advocating for health care access for all Native communities.

Recent news:

PRESS RELEASE: Tribal Organizations Urge Administration to Respect Tribal Sovereignty and Uphold Trust and Treaty Obligations Amid Executive Actions (Feb. 3, 2025)

NCUIH Joins NIHB, NCAI and Self-Governance Communication and Education Tribal Consortium in Requesting the Indian Health System be Exempt from Federal Hiring Freezes (Feb 4, 2025)

IHS Employee Layoffs Halted After Urgent Advocacy Efforts (Feb. 19, 2025)

NCUIH Joins NIHB in Letter to Congressional Leadership Advocating for Protecting the Indian Health System from Funding Freezes (Feb. 25, 2025)

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

NCUIH Supports the Partnership for Medicaid’s Call to Protect Medicaid and Access to Care

The National Council of Urban Indian Health (NCUIH) joined the Partnership for Medicaid (P4M) in calling on Congress to protect Medicaid, while expressing a commitment to work with policymakers to identify more sustainable strategies to strengthen Medicaid and improve on its promise of providing high quality coverage and access to care for populations in need. On February 6, P4M issued a statement urging Congress to reject cuts to Medicaid during the budget reconciliation process, and on February 24, P4M released a statement urging Congress to vote “no” on the budget resolution which includes $880 billion in cuts for the Energy and Commerce Committee, which would likely significantly impact Medicaid.  

Medicaid provides health coverage to more than 80 million Americans, including working families, children, seniors, and people with disabilities. It plays a key role in ensuring that people have access to doctors, hospitals, and treatment when they need it. In 2023, approximately 2.7 million Native people were enrolled in Medicaid across the United States, according to American Community Service data. Medicaid is a major source of health care funding, particularly for Urban Indian Organizations (UIOs), which provide essential healthcare services to Native people living in urban areas. The proposed Medicaid cuts would threaten the ability of UIOs to sustain necessary service offerings, potentially reducing access to essential health care services for urban Native people. 

NCUIH remains committed to working with policymakers and UIOs to support a strong Medicaid program. 

About the Partnership for Medicaid 

NCUIH is a member of the Partnership for Medicaid, which is a nonpartisan, nationwide coalition of organizations representing clinicians, health care providers, safety-net health plans, and counties. The goal of the coalition is to preserve and improve the Medicaid program. 

 

NCUIH Joins NIHB in Letter to Congressional Leadership Advocating for Protecting the Indian Health System from Funding Freezes

On January 31, 2025, the National Council of Urban Indian Health (NCUIH) joined the National Indian Health Board (NIHB) in sending a letter to House and Senate leadership to communicate concerns about the impacts of the Office of Management and Budget’s (OMB) now-rescinded memorandum that implemented a temporary pause in federal funding. In the Letter, NCUIH and NIHB urged Congress to communicate and work with Administration officials on guidance about the unique relationship Tribes have with the United States and include a broad Tribal exemption from any future funding restrictions or pauses.

While the recent OMB memorandum has been rescinded, we will continue to monitor this situation and any potential impacts on Indian Health Service funding.

Read the full letter here.

Background on the OMB Memorandum

In a memorandum dated January 27, 2025, the OMB Acting Director, Matthew Vaeth, instructed the heads of executive departments and agencies to temporary pause agency grant, loan, and other financial assistance programs. The now-rescinded memorandum would have temporarily paused “all activities related to obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated” by recent executive order (EOs). These EOs concern topics such as financial assistance for foreign aid, nongovernmental organizations, diversity, equity and inclusion (DEI) programs, “woke gender ideology,” and the green new deal. OMB later rescinded the memorandum in a memorandum dated January 29, 2025.

NCUIH will continue to monitor any developments.

NCUIH Joins Indian Country Coalition in Urging Senate Leadership to Honor Trust and Treaty Obligations for Native People in Upcoming Budget Reconciliation

On February 20, 2025, the National Council of Urban Indian Health (NCUIH) joined a coalition of Tribes, Tribal Organizations and other national Native organizations in sending a letter to Majority Leader Thune (R-SD) and Minority Leader Schumer (D-NY) expressing concerns and highlighting opportunities for Indian Country as Congress considers budget reconciliation legislation.

The letter addresses the proposed cuts to federal spending related to taxation, border security, education, infrastructure laws, Tribal Temporary Assistance Program for Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP) and Medicaid. Specifically, any cuts or caps to programs such as TANF, SNAP, and Medicaid would reduce access to critical resources that can have a disproportionate impact on American Indian and Alaska Native people. Work requirements for SNAP and Medicaid would directly impact access to healthy food and healthcare, which does not honor the trust and treaty responsibilities to American Indian and Alaska Native people. The letter reinforces to Senate leadership that the inclusion of long-standing tax priorities and other legislative actions affirms Tribal sovereignty and the unique relationship with the federal government is in fulfillment of trust and treaty obligations to all American Indian and Alaska Native people.

About the Indian Country Coalition

NCUIH has joined a coalition with over 20 Tribal organizations to ensure administrative actions account for the government-to-government relationship between Tribes and the United States and the trust and treaty responsibility to Tribal nations and citizens.

The coalition has been active in creating joint messages to share with policy makers, sending letters to key administration officials, and developing advocacy strategies. Access the Tribal Coalition’s online resource hub, where you can find our letters and other advocacy tools.

Full Letter Text

Dear Majority Leader Thune and Minority Leader Schumer,

On behalf of the undersigned organizations that collectively serve sovereign Tribal Nations and their citizens and communities, we write to express concern and highlight opportunities for Indian Country as Congress considers budget reconciliation legislation. While we recognize that Congress is seeking to address broader issues related to taxation and border security, we remind you that proposed changes to federal spending and programs are likely to have a disproportionate impact on Tribal Nations and our people. In addition, Tribal Nations have long sought changes to the tax code aimed at extending the governmental parity they are due. To that end, we urge that any reconciliation bill protect and advance the interests of Tribal Nations and our people, in fulfillment of trust and treaty obligations.

Unique Legal Status of Tribal Nations. Tribal Nations are and always have been inherently sovereign governments that have strong political relationships with our Tribal citizens and community members. We govern and police our lands, and we provide services aimed at keeping our communities safe and healthy. Tribal Nations also have political, government-to-government relationships with the United States, and we prepaid with our lands and resources for the trust and treaty obligations that the United States owes us in perpetuity. The U.S. Constitution singles out Tribal Nations and Native people as unique, and the U.S. Supreme Court has time and again affirmed the principle that United States actions that deliver on trust and treaty obligations to Tribal Nations, Tribal citizens, and Tribal communities do not run afoul of the U.S. Constitution’s equal protection requirements.

Scope of Trust and Treaty Obligations. The United States fulfills its trust and treaty obligations both through the direct delivery of Tribal programs and services and the provision of federal funding to Tribal Nations to deliver services to our own communities. Any Tribal program or funding delivered to Tribal Nations—including through Urban Indian Organizations and Tribal organizations serving Tribal Nations—is provided in furtherance of the United States’ trust and treaty obligations. The federal employees necessary for the functioning of Tribal programs and the disbursement of Tribal funds are also part of the trust and treaty obligations. These actions are not discretionary; they are legal obligations rooted in treaties, trust obligations, the U.S. Constitution, and long-standing federal statutes.

Concerns with Potential Changes to Federal Programs and Spending. As you consider reconciliation legislation in the Senate, we ask that you work to exempt Indian Country from the harmful impacts of changes to federal spending and policy. Reductions in the scope or funding of the programs that we access are not only violations of trust and treaty obligations, but will have devastating impacts for our people. As the budget reconciliation process continues to unfold, we would like to highlight our deep concern and opposition to the inclusion of any language that reduces services or funding to Indian Country. We call upon you to ensure that exemptions are provided for Tribal Nations, Tribal serving organizations, and Native people within any reconciliation legislation, including, but not limited to, the following changes:

Medicaid is critical method by which the United States seeks to deliver upon trust and treaty obligations to provide health care to Tribal Nations. Medicaid resources are vitally important to supplementing the chronically underfunded Indian Health System (comprised of the IHS, Tribal providers, and Urban Indian Organizations). Reforms, such as cost caps, would shift costs to states for American Indian and Alaska Native (AI/AN) Medicaid beneficiaries who currently have their costs covered by 100% Federal medical assistance percentage (FMAP) when seen at an Indian Health Service (IHS) or Tribal facility. Further, conditioning access to Medicaid with work requirements fails to honor trust and treaty obligations, and are not reflective of on-the ground realities in Indian Country. Specifically, many AI/ANs are employed but face unique barriers that make it difficult to prove this. These include limited mail access, poor broadband, insufficient transportation infrastructure, and language barriers. Additionally, Medicaid resources are a critical consideration for Tribal Nations deciding whether to take over Indian Health Programs under the Indian Self-Determination and Education Assistance Act (ISDEAA). Reducing access to Medicaid resources will disincentivize Tribal Nations from electing to take over programs from the IHS and reduce access to much needed supplemental resources for existing Tribal, IHS, and Urban Indian Organizations. This includes any changes to the FMAP or Medicaid expansion. Both AI/AN people and the Indian Health System must be made exempt from any Medicaid reforms. The last time Congress considered Medicaid reform in 2017, it provided such exemptions, and we ask you to do the same again. In addition, the first Trump Administration approved several section 1115 waivers related to work requirements that exempted AI/ANs, including in Arizona, Indiana, South Carolina, and Utah. We support the letter the National Indian Health Board sent on January 31, 2025, and encourage you to refer to that statement for further information.

Changes to Education Funding Structures. As Congress looks to restructure the core of the American education system and redirect federal funding to the states, it is essential that any block grant funding must explicitly protect Tribal Nations and Tribal education systems as eligible entities with dedicated set-asides in each program, ensuring that Tribal Nations and Tribal education systems do not have to seek federal funding through state governments. We highlight the importance of Title III programs under Higher Education Act (HEA) (20 U.S.C. § 1057), Title VI programs under the Elementary and Secondary Education Act (ESEA) (20 U.S.C. § 7401), Title I programs under ESEA (20 U.S.C. § 6301), and Impact Aid under Title VII of ESEA (20 U.S.C. § 7701), as well as all programs administered through the Office of Indian Education (OIE). As these programs may be relocated to other agencies, we want to ensure the funding and staffing levels necessary to operate these programs move with them. We encourage Congress to look to the Child Care and Development Block Grant (CCDBG) as a model for successful Tribal set-asides and direct Tribal funding. 42 U.S.C. § 618(a)(3)(B) ensures that Tribal Nations and Tribal serving Organizations receive funds directly from the federal government, enabling them to operate their own childcare programs tailored to the needs of their communities without requiring them to seek federal funding through state governments.

Changes to TANF. Nearly half of all federally recognized Tribal Nations are now served by a Tribal Temporary Assistance for Needy Families (TANF) program, which enables them to better meet community needs, deliver services in ways that honor Tribal culture, and take advantage of additional flexibilities. An indiscriminate reduction in TANF funding will jeopardize this vital funding. We urge the exemption of the Tribal TANF Block Grant from any funding reductions.

Changes to SNAP. Similarly, the Supplemental Nutrition Assistance Program (SNAP) is a critical program ensuring millions of low-income families, including AI/ANs, have access to food. As a federal program, it is also a critical mechanism by which the United States meets its trust and treaty obligations to Tribal Nations and communities. Federal programs to combat hunger like SNAP are important to Tribal communities— approximately 25 percent of Native Americans receive some type of federal food assistance, and in some Tribal communities, participation is as high as 80 percent. Our populations must be exempt from any reductions in SNAP benefits, including any reductions related to work requirements.

Repeal of Infrastructure Laws. Under recently enacted federal infrastructure packages, including the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act, Tribal Nations have access to over $14 billion in direct funding and are eligible for billions more in funding through competitive grants, loans, loan guarantees, tax credits, and contracts. This funding is essential to addressing centuries of unmet infrastructure obligations across Indian Country, and we urge you to ensure it continues to flow to Tribal communities and enterprises.

Inclusion of Tribal Tax Priorities. With bipartisan, bicameral support, the Tribal Tax and Investment Reform Act amends the Internal Revenue Code to bring parity for Tribal governments to access the same financing opportunities and engage in the same economic development and job creation activities available to state governments. Enactment of this legislation will remove persistent barriers to accessing the necessary capital required to support economic development and growth in Tribal communities, including through parity in the issuance of tax-exempt bonds. To that end, we urge the inclusion of all the bill’s provisions in any reconciliation legislation. We further request the addition of language recognizing and protecting the sovereignty of Tribal governments, including our ability to retain the revenue generated within our borders through taxation that does not have to compete with taxes states attempt to collect for activities on our lands.

In recognition of the government-to-government relationship between Tribal Nations and the United States, and the federal trust and treaty obligations owed to us, we ask that you work to protect Indian Country from becoming collateral damage in the budget reconciliation process. We have prepaid for the services and funding delivered to us, much of which could be jeopardized without an exemption from larger policy change or reductions. We stand ready to work with you on the inclusion of our long-standing tax priorities and other legislative action that upholds and recognizes our sovereignty and unique relationship.

Sincerely,
Affiliated Tribes of Northwest Indians
American Indian Higher Education Consortium
Great Plains Tribal Chairman’s Association, Inc.
Indian Gaming Association Midwest Alliance of Sovereign Tribes
National Congress of American Indians
National Council of Urban Indian Health
National Indian Child Welfare Association
National Indian Education Association
National Indian Health Board
Native American Finance Officers Association
Self-Governance Communication & Education Tribal Consortium
United South and Eastern Tribes Sovereignty Protection Fund

IHS Employee Layoffs Halted After Urgent Advocacy Efforts

On February 14,2025, the National Council of Urban Indian Health  (NCUIH) issued an urgent action alert calling on advocates to contact Congress and demand and immediate stop to the layoffs of probationary Indian Health Service (IHS) employees. That same day, NCUIH joined several national Native organizations in a letter to the Office of Personnel Management (OPM), urging federal leadership to protect IHS employees serving Indian Country. With IHS facing a 30% vacancy rate, further reductions in staffing would severely impact healthcare access for American Indians and Alaska Native people.

Following these advocacy efforts, a February 17 report confirmed that HHS Secretary Kennedy rescinded the layoffs of 950 IHS employees. NCUIH will continue to monitor these developments and we remain committed to ensuring the federal government upholds its trust responsibility.

ACTION ALERT: URGENT—Federal Layoffs Devastating Tribal Programs Are Happening TODAY, According to ICT News

FOR IMMEDIATE RELEASE

Dear Advocates,

We need your immediate action—federal layoffs targeting essential tribal programs have begun TODAY, and the impacts will be catastrophic for Indian Country. According to ICT News, thousands of workers could be affected in health, education and other programs across Indian Country. The news reports that Trump administration has started laying off thousands of federal employees, threatening vital healthcare, education, law enforcement, and social services across tribal communities.

What’s Happening Right Now?

Mass Layoffs Underway: According to ICT News, the Trump administration has started laying off thousands of federal workers, including over 850 Indian Health Service (IHS) employees—doctors, nurses, pharmacists, and more.

Critical Services at Risk: Tribal healthcare facilities, schools, and public safety programs are losing essential staff. Communities that rely on these services will face immediate disruptions.

Trust Obligations:These layoffs will severely impact the federal government’s ability to fulfill the trust responsibility to Tribes and Native people.

According to ICT, the layoffs, targeted at probationary workers hired within the last year or two, are expected to impact programs at the Indian Health Service, Bureau of Indian Affairs, Bureau of Indian Education, and more. If no action is taken immediately, tribal communities will lose life-saving healthcare, childcare services, emergency response capabilities, educational support, and justice services.

Why This Is an Emergency

According to ICT, the layoffs are happening NOW. Without swift intervention from Congress, these cuts will send shockwaves through Indian Country.

How You Can Help—Act Now!

  1. Contact Congress Immediately: Call or email your representatives TODAY to demand they stop these layoffs and protect tribal programs.
  2. Spread the Word: Share this alert widely on social media to raise awareness about this urgent issue.

Sample Email to Your Representative:

Dear Representative [NAME],

I am writing with urgency as federal layoffs devastating tribal programs have already begun today. These cuts threaten the health and safety of Indian Country by targeting critical services such as healthcare, education, law enforcement, and social services.

According to ICT, over 850 Indian Health Service employees—including doctors and nurses—are being terminated right now, leaving tribal communities without access to essential care. These layoffs violate the U.S. government’s trust and treaty responsibilities to Tribal Nations and put lives at risk.

I urge you to take immediate action to stop these harmful layoffs and ensure that tribal programs are protected from further cuts. Please act now to uphold the federal government’s legal obligations to Indian Country.

Thank you for your swift attention to this urgent matter.

Additional information: https://ictnews.org/news/abrupt-federal-layoffs-expected-to-hit-tribal-programs

Sincerely,

[Your Name]

Time Is Running Out—Contact Congress Now!

These layoffs are happening as we speak—your voice can make a difference in protecting tribal communities from devastating harm. Let’s stand together to demand action before it’s too late!

Find Your Members of Congress

Use this link to find your members: https://www.congress.gov/members/find-your-member

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

FINAL REPORT: Urban Indian Health at Risk – Federal Funding Disruptions Threaten Critical Services

Today, February 12, 2025, we are providing an update on the National Council of Urban Indian Health (NCUIH) report regarding the potential impact of federal funding disruptions on Urban Indian Organizations (UIOs) funded by the Indian Health Service (IHS). The final report, released on February 11, 2025, builds upon the preliminary findings from February 3, 2025, offering a more comprehensive view of the challenges facing UIOs.

Background

Urban Indian Organizations were established in response to severe health, education, employment, and housing problems caused by federal forced relocation policies. Congress formally incorporated UIOs into the Indian Health System in 1976 with the passage of the Indian Health Care Improvement Act (IHCIA). Today, 41 UIOs operate over 85 facilities in 38 urban areas, serving patients from more than 500 federally recognized Tribes. These organizations provide crucial primary care, behavioral health, traditional medicine, and social services to American Indians and Alaska Natives living in urban areas.

Key Changes from February 3 to February 11 Report

Survey Participation

The final report reflects increased participation from UIOs. While the preliminary report on February 3 included responses from thirteen (13) of the forty-one (41) UIOs, the February 11 report incorporates data from twenty (20) UIOs.

Workforce Instability

The data on potential staff reductions has been refined:

  • February 3 report: 23.1% of UIOs definitely will need to furlough or lay off staff.
  • February 11 report: 25% of UIOs definitely will need to furlough or lay off staff.

Additionally, the percentage of UIOs indicating potential for staff reductions increased:

  • February 3 report: 38.5% indicate potential for staff reductions.
  • February 11 report: 45% indicate potential for staff reductions.

These changes suggest a slightly more severe outlook for workforce stability among UIOs.

Consistent Findings

Several key findings remain consistent between the two reports:

  1. Operational Sustainability: Over half of UIOs would not be able to sustain operations beyond six months without federal funding.
  2. Service Discontinuation: Over half of UIOs anticipate discontinuing critical services if federal funding disruptions persist. The potentially affected services remain the same, including primary care, behavioral health services, substance abuse treatment, community wellness initiatives, health programs, and cultural and youth programming.
  3. Immediate Impact: Some UIOs can only sustain operations for 30 days or less without federal funds.

Implications and Call to Action

The final report reinforces the critical nature of federal funding for UIOs and the potential far-reaching consequences of funding disruptions on urban American Indian and Alaska Native populations. The increased survey participation provides a more comprehensive picture of the challenges facing UIOs, while the slight increase in potential workforce instability underscores the urgency of addressing these funding concerns.

As we release this updated information based on the final NCUIH report, we continue to urge policymakers, healthcare leaders, and advocates to recognize the vital role of UIOs in the Indian health system and take immediate action to ensure their continued operation and funding stability. The health and well-being of urban Native communities depend on the uninterrupted services provided by these organizations.

Additional Information

February 3, 2025 – REPORT: Urban Indian Health at Risk – Federal Funding Disruptions Threaten Critical Services

February 4, 2025 – Action Alert: Contact Congress to Protect Indian Health System Funding

Tribal Leaders Recommend Increased Urban Indian Health Funding in Fiscal Year 2027 Area Reports

On January 22-23, 2025, the Indian Health Service (IHS) held their Area Report Presentations Webinar for Fiscal Year (FY) 2027 where Tribal leaders from all 12 IHS Areas and leaders from Native organizations, including the National Council of Urban Indian Health (NCUIH), presented on their budget requests. Tribal leaders spoke about the need to increase urban Indian health funding. For example, Oneida Division Director, Debra Danforth, said that Urban Indian Organizations (UIOs) need critical funding increases to serve large American Indian and Alaska Native populations in urban settings in the Bemidji Area.

Some common themes among Area reports were the need for funding for mental health, purchased/referred care, dental services, and alcohol/substance abuse.

NCUIH always supports the National Tribal Budget Formulation Workgroup’s recommendation for the IHS budget and is grateful for Tribal leaders’ support for increased funding in the Urban Health line item.

Area Report Highlights

Several Areas featured the work of UIOs in their presentations and advocated for increased allocation of funding and resources for urban Indian health.

The Bemidji Area stressed the need for an increase in funding to support authorized programs for UIOs. They recommended an increase of $303 million for the Urban Health line item above the fiscal year (FY) 2023 enacted of $90.4 million base.

The Billings Area listed Urban Health as priority 9 and recommended an increase of $2.6 billion increase above the FY 2023 enacted base.

The California Area recommended a $1.6 billion increase above the FY 2023 enacted base and kept Urban Health at priority 11.

The Navajo Area recommended a $3 billion increase above the FY 2023 enacted base.

The Oklahoma City Area kept Urban Health at priority 4 and included 100% Federal Medical Assistance Percentages (FMAP) at UIOs as hot issue 12. They recommended a $559 million increase above the FY 2023 enacted base.

The Phoenix Area kept Urban Health at priority 6 and recommended a $874 million increase above the FY 23 enacted base.

The Portland Area kept Urban Health at priority 5 and recommended a $1.1 billion increase above the FY 23 enacted base.

The Tucson Area included 100% FMAP for Medicaid services provided at UIOs as hot topic 7 and recommended a $1.6 billion increase above the FY 23 enacted base.

NCUIH Presents Priorities at Areas Presentations Webinar

Alexandra Payan, NCUIH’s Interim Director of Federal Relations, presented the top priorities for urban Indian health for FY 2027 during the Area Report Webinar. NCUIH supports full funding for the IHS, Tribal, and UIOs (I/T/U) system.  NCUIH endorses a budget in which IHS, Tribal Facilities, and UIOs are all fully funded to improve health outcomes for all Native people no matter where they live.

  1. Full funding for IHS and the Urban Indian line item
    1. This funding is necessary to address health priorities for Native in urban areas, including:
      1. Ensuring Urban Indian Health funding keeps pace with population growth.
      2. Providing funding for UIO facilities and infrastructure.
      3. Expanding service offerings to Native patients in urban areas.
  2. Establishing Permanent 100% FMAP for services provided to Medicaid beneficiaries at UIOs
  3. Recruitment and Retention of Workforce
  4. Special Diabetes Program for Indians (SDPI) reauthorization
  5. Increased funding and resources for Traditional Healing services, food and housing insecurity

Background on Area Budget Formulation

As part of the trust responsibility to provide health care to all American Indian and Alaska Native people, Tribal leaders present their funding needs each year to the Secretary of the U.S. Department of Health and Human Services and the Director of the Office of Management and Budget. The recommendations are formed through the Tribal Budget Formulation Workgroup and serve as a framework for the Administration in setting budget amounts for their annual requests to Congress. This process ensures the federal government has the resources to provide health care to all American Indian and Alaska Native people in fulfillment of the trust responsibility.

Next Steps

On February 11-12, 2024, IHS will host the FY 2027 National Tribal Budget Formulation Work Session. This is a 2-day annual meeting where the two Tribal representatives from each Area come together to review and consolidate all the Areas’ budget recommendations into a comprehensive set of national health priorities and budget recommendations. Work session activities include:

  • Tribal Caucus occurs where the Tribal workgroup co-chairs are selected
  • Tribal representatives from each Area give a brief Area report presentation to the group
  • Discussion on determining priorities and budget recommendations
    • Discussions are made by consensus from workgroup members. Only the two Tribal representatives that are part of the workgroup are allowed to partake in voting.
  • The workgroup will meet with the IHS Director and other IHS leadership to discuss health priorities and budget recommendations.
  • At least one tribal representative from each Area along with technical team members will coordinate to complete follow-up work on the budget recommendation and testimony that will be presented.

NCUIH Recommends CDC Continue to Engage with UIOs on Tribal Maternal Health

On January 10, 2025, the National Council of Urban Indian Health (NCUIH) submitted written comments to the Centers for Disease Control and Prevention (CDC) following a December 4, 2024, listening session on maternal health and tribal maternal mortality review. In its comments to CDC, NCUIH recommended that CDC continue to host listening sessions on this topic. In continuing this engagement, NCUIH further recommended that CDC continue to invite Urban Indian Organizations (UIOs) to give UIOs the opportunity to share insights gained from providing services to their patient populations to support maternal health.

Background on CDC and Tribal Maternal Mortality Review

The CDC Division of Reproductive Health’s Enhancing Reviews and Surveillance to Eliminate Maternal Mortality program supports maternal mortality review committees (MMRCs) to identify and review deaths during and within a year of pregnancy, including documenting prevention opportunities. CDC works with MMRCs to improve review processes that inform recommendations for preventing future deaths.

Existing reviews include deaths during and within a year of pregnancy among American Indian and Alaska Native persons. However, there are no Tribal MMRCs. Tribal MMRCs could adapt MMRC processes to reflect community priorities and culturally appropriate approaches to maternal mortality prevention; have direct access to their data and determine the use of their data; and provide recommendations relevant to the community made by a tribally appointed committee to prevent pregnancy-related mortality.

IHS Finalizes Reorganization Office of the Director, Creates the Office of Tribal and Urban Affairs and the Division of Urban Indian Affairs

On January 8, 2025, the Indian Health Service (IHS) published a final notice in the Federal Register amending Part G of the Statement of Organization, Functions, and Delegations of Authority of the Department of Health and Human Services (HHS) to reflect the IHS reorganization. IHS wrote that “[t]he purpose of this reorganization is to revise the current approved structure for the IHS, Office of the Director, Intergovernmental Affairs functions.” Importantly, this includes the establishment of the previously proposed Office of Tribal and Urban Affairs and Division of Urban Indian Affairs. This final notice does not include a request for feedback.

Background

In an October 10, 2024, letter to Tribal leaders and Urban Indian Organization (UIO) leaders (DTLL/DULL), IHS announced a proposed reorganization of IHS Headquarters Office of the Director (hereinafter “proposed reorganization”), which would then have impacts on how offices under the Deputy Director for Intergovernmental Affairs (DDIGA) are structured. IHS stated “[t]here are five primary objectives of the proposed reorganization, which adopts a One IHS model that:

  1. 1) Strengthens [IHS’] relationship with Indian Tribes and UIOs by streamlining operations and enhancing communications;
  2. 2) Enhances the business relationships with Indian Tribes through self-determination and self-governance;
  3. 3) Amplifies the work of the Agency with all partners by cultivating intergovernmental partnerships and furthering external relationships;
  4. 4) Modernizes the way the Agency supports Tribes pursuing [Indian Self-Determination and Education Assistance Act (ISDEAA)] opportunities by supporting ISDEAA negotiation teams across the Agency working under a One ISDEAA model; and
  5. 5) Fosters education and training throughout the entire IHS system on how ISDEAA interfaces with our everyday work.”

IHS also announced a November 13, 2024, Urban Confer and November 14, 2024, Tribal Consultation on the proposed reorganization. Enclosed with the DTLL/DULL, IHS included the draft IHS Headquarters Office of the Director Organizational Chart (hereinafter “draft organizational chart”). The draft organization chart for the proposed reorganization indicated that IHS planned to eliminate the Office of Urban Indian Health Programs (OUIHP) and create the Division of Urban Indian Affairs under the Office of Tribal and Urban Affairs. During the November 13, 2024, Urban Confer IHS stated that IHS envisions the Division of Urban Indian Affairs will be led by a director-like leader.

NCUIH’s Role

On December 16, 2024, the National Council of Urban Indian Health (NCUIH) submitted written comments to the IHS Director, Roslyn Tso, regarding IHS’ October 10, 2024, DTLL/DULL and November 13, 2024, Urban Confer on IHS’ proposed. In its comments following the Urban Confer, NCUIH submitted the following requests and recommendations to IHS:

  • Maintain a dedicated focus on urban Indian health
    • Clarify the role of the IHS OUIHP Strategic Plan
    • Clarify the role of the proposed Division of Urban Indian Affairs leader
  • Protect the Urban Indian Health line item
  • Ensure meaningful engagement with UIOs through Urban Confer throughout the reorganization process by hosting additional Urban Confers
    • Extend the written comment deadline
  • Clarify a timeline and next steps for the reorganization

NCUIH will continue to closely follow the reorganization.