Tag Archive for: Comments

NCUIH Calls for Improved EHR Training and Support for Urban Indian Organizations During IHS Health Information Technology Modernization Implementation

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On December 6, 2024, the National Council of Urban Indian Health (NCUIH) submitted written comments to the Indian Health Service (IHS) Director, Roselyn Tso, regarding IHS January 18, 2024, Dear Tribal Leader and Urban Indian Organization Leader letter (DTLL/DULL) and the November 7, 2024, joint Tribal Consultation and Urban Confer (TC/UC) session on Health Information Technology (HIT) Modernization Site Readiness and Training. In its comments, NCUIH recommended that IHS support Urban Indian Organizations (UIOs) pre- and post-go-live of the new electronic health record (EHR) by providing training that does not disrupt facilities’ operations and reflects real-life scenarios

Background on HIT Modernization

On November 8, 2023, TC/UC on HIT Modernization, IHS announced that it selected General Dynamics Information Technology, Inc. (GDIT) to build, configure, and maintain a new IHS EHR system utilizing Oracle Cerner technology. The new EHR, named Patients at the Heart (PATH), will replace the Resource and Patient Management System (RPMS).

For more information about HIT Modernization implementation, please click here.

NCUIH’s Requests

In its comments following the TC/UC, NCUIH submitted the following requests and recommendations to IHS:

  • Support UIOs pre- and post-go-live by providing training that does not disrupt facilities’ operations and reflects real-life scenarios
  • Ensure HIT Modernization implementation is equitable and inclusive for all facility types and sizes pre- and post-go-live
  • Continue to engage with UIOs through Urban Confer sessions to understand the site-level needs that IHS should consider when designing and deploying the PATH EHR
  • Continue to provide an updated timeline of the PATH EHR implementation

NCUIH Advocacy on HIT Modernization

NCUIH has previously submitted several comments to IHS on HIT Modernization:

NCUIH also submitted written testimony  to the House Appropriations Subcommittee on Labor, Health and Human Services, Education, and Related Agencies regarding the fiscal year (FY) 2024 funding for UIOs in which NCUIH requested increased funding for EHR Modernization. Specifically, NCUIH requested support for the IHS’ transition to a new EHR system for IHS and UIOs by supporting the President’s budget request of $913 million in FY 2024 appropriations.

NCUIH will continue to closely follow IHS’s progress and policies with HIT Modernization.

NCUIH Requests SAMHSA Engage with Urban Indian Organizations in Redesign of Tribal Behavioral Health Grant Program

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On November 27, 2024, the National Council of Urban Indian Health (NCUIH) submitted written comments to the Substance Abuse and Mental Health Service Administration’s (SAMHSA) October 2024 Dear Tribal Leader Letter on redesigning the Tribal Behavioral Health (TBH) grant program to streamline the program and enable applicants to focus on priorities that align with their needs. In its comments to SAMHSA, NCUIH requested that SAMHSA engage with Urban Indian Organizations (UIOs) by hosting an Urban Confer or UIO listening session throughout the redesign process because UIOs are eligible for the TBH grant program through the Native Connections grant.

Background on the TBH Grant Program

The purpose of this program is to prevent and reduce suicidal behavior and substance use/misuse, reduce the impact of trauma, and promote mental health among American Indian and Alaska Native youth, up to and including age 24, by building a healthy network of systems, services, and partnerships that impact youth. In fiscal year 2023 and fiscal year 2024, 4 UIOs were awardees of the TBH grant program.

NCUIH Advocates for Engagement with Native Communities in Shaping New Healthy People 2030 Objectives

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On October 31, 2024, the National Council of Urban Indian Health (NCUIH) submitted written comments in response to the Department of Health and Human Services (HHS) Office of Disease Prevention and Health Promotion (ODPHP) Announcement of Solicitation of Written Comments on Proposed Healthy People 2030 Objectives. In these comments, NCUIH urged the ODPHP to reconsider three recommendations previously proposed by NCUIH to ODPHP in written comments submitted on November 20, 2023. These recommendations are:

  • Engage with the American Indian and Alaska Native community through Tribal Consultation and Urban Confer.
  • Ensure ODPHP is engaging with the HHS Secretary’s Tribal Advisory Committee on Healthy People 2030 additional Objectives.
  • Ensure that an IHS representative is on each of the objective workgroups.

The federal trust responsibility requires that ODPHP incorporate the perspective of American Indian and Alaska Native communities in development of Healthy People 2030 objectives. NCUIH’s recommendations will help fulfill this requirement and ensure that the Healthy People 2030 objectives address the health needs and priorities of the Indian health system.

Background on Healthy People 2030

Healthy People 2030 identifies public health priorities to help individuals, organizations, and communities across the United States improve health and well-being. Healthy People 2030 is the initiative’s fifth iteration, and it builds on the knowledge gained from previous iterations, which span over four decades. On October 1, 2024, HHS published an Announcement of Solicitation of Written Comments on Proposed Healthy People 2030 Objectives. In this announcement, HHS solicited written comments from the public on the proposed addition of twelve (12) new objectives to the current set of Healthy People 2030 objectives. The twelve proposed objectives were developed by Healthy People topic area workgroups led by various agencies within the Federal Government. The new objectives are:

  1. Increase the proportion of people with chronic kidney disease and diabetes who receive glucose-lowering medications based on the most recent guidelines. This objective is new to Healthy People 2030.
  2. Increase the proportion of people with chronic kidney disease and severe albuminuria who receive glucose-lowering medications based on the most recent guidelines.
  3. Increase the proportion of medical schools that include environmental health content in a required learning experience.
  4. Increase the proportion of undergraduate nursing and graduate nurse practitioner training programs that include environmental health content in a required learning experience.
  5. Increase the proportion of physician assistant (PA) training programs that include environmental health content in a required learning experience.
  6. Increase the proportion of colleges and schools of pharmacy with Doctor of Pharmacy (PharmD) degree programs that include environmental health content in a required learning experience.
  7. Increase the proportion of colleges and schools of dentistry with Doctor of Dental Surgery (DDS) and/or Doctor of Dental Medicine (DMD) degree programs that include environmental health content in a required learning experience.
  8. Reduce deaths related to heat. This objective is currently a development objective, EH-D02.
  9. Increase the proportion of adults with communication disorders of voice, swallowing, speech, or language who have seen a health care specialist for evaluation or treatment in the past 12 months.
  10. Increase the proportion of pregnant women who receive 1 dose of the tetanus-diphtheria-acellular pertussis (Tdap) vaccine during pregnancy.
  11. Increase the proportion of adults who receive the recommended age-appropriate vaccine.
  12. Reduce the rate of hypertension in pregnancy (preexisting and pregnancy-associated hypertension) among delivery hospitalizations.

Past NCUIH Advocacy on Healthy People 2030

Prior to the comments submitted on October 31, NCUIH submitted two other written comments to HHS in order to ensure that the Healthy People 2030 objectives address the health needs and priorities of the Indian health system.

First, on October 31, 2023, NCUIH recommended that HHS Office of Minority Health’s (OMH) consider the health needs of American Indian and Alaska Native people living in urban areas when developing the Healthy People 2030 Leading Health Indicators Initiative (LHII) Notice of Funding Opportunity (NOFO) and urged OMH to facilitate partnerships between grantees and UIOs to ensure American Indians and Alaska Natives can be served by the LHII no matter where they reside.

Second, on November 20, 2023, NCUIH recommended that HHS ODPHP consider the unique needs of Native communities when advancing current objectives and developing future objectives to monitor, address, and advance Healthy People 2030’s overarching goals.

Next Steps

NCUIH will continue to monitor changes to Healthy People 2030 and engage with HHS to ensure that the initiative’s objectives address the health needs and priorities of the Indian health system.

NCUIH Urges HHS to Collaborate with Urban Indian Organizations and Tribes on Syphilis and Congenital Syphilis Education, Stigma Reduction, and Data Sharing

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On September 4, 2024, the National Council of Urban Indian Health (NCUIH) submitted written comments to the U.S. Department of Health and Human Services (HHS) Assistant Secretary for Health, Admiral Rachel L. Levine, in response to the HHS Office of the Assistant Secretary for Health (OASH) July 2, 2024, Dear Tribal Leader Letter (DTLL). In its comments, NCUIH requested that HHS and the National Syphilis and Congenital Syphilis Syndemic Federal Task Force (Task Force) partner with urban Indian organization (UIOs) to reduce stigma and increase education on syphilis and congenital syphilis and facilitate dissemination of timely data on syphilis and congenital syphilis to Tribes and UIOs.

Background

Disproportionate Impact of Syphilis on American Indian and Alaska Native Communities

The rates of primary and secondary syphilis have risen every year since 2001. Congenital syphilis rates have also risen. Racial and ethnic minorities, including American Indian and Alaska Native people, have been disproportionately affected by the surge of cases. According to the Centers for Disease Control and Prevention’s National Center for HIV, Viral Hepatitis, STD, and TB Prevention, American Indian and Alaska Native people experience the greatest relative disparity in primary and secondary syphilis cases, representing “2.8% of reported P&S syphilis cases . . . despite being 0.7% of the US population, or a burden 4.0 times what would be expected based on their proportion of the population.” American Indian and Alaska Native mothers also experienced the greatest relative disparity in congenital syphilis cases, representing “4.6% of reported congenital syphilis cases . . . despite being 0.7% of live births, or a burden 6.6 times what would be expected based on their proportion of live births.”

HHS Task Force: A Collaborative Response to Rising Syphilis Cases

HHS established the Task Force as part of the agency’s commitment to addressing these escalating cases. The Task Force is a cross-agency collaborative effort, with participants from HHS agencies and offices, including the Indian Health Service (IHS), as well as the Department of Agriculture, Department of Justice, Department of Veterans Affairs, and the White House, including both the Office of National Drug Control Policy and the Office of National AIDS Policy.

The Task Force identified 14 priority jurisdictions that account for nearly 75 percent of congenital syphilis cases and over 55 percent of primary and secondary syphilis cases nationwide to focus on targeted interventions. Additionally, these 14 priority jurisdictions represent over 65 percent of primary and secondary syphilis and over 70 percent of congenital syphilis cases among individuals that identify as American Indian and Alaska Native. 21 UIOs serve American Indian and Alaska Native patients in 8 of the 14 priority jurisdictions.

NCUIH’s Requests

In its comments, NCUIH recommended:

  • HHS and the Task Force must work with UIOs as part of their strategy to reduce the cases of syphilis and congenital syphilis in American Indian and Alaska Native communities
    • HHS and the Task Force should Host Urban Confers or UIO listening sessions and continue to seek Tribal feedback
    • HHS and the Task Force should partner with UIOs to reduce stigma and increase education on syphilis and congenital syphilis
  • HHS and the Task Force should facilitate dissemination of timely data on syphilis and congenital syphilis to Tribes and UIOs

NCUIH will continue to monitor as OASH addresses the syphilis and congenital syndemic impacting American Indian and Alaska Native people.

NCUIH Requests IHS Support All Facility Types and Integrate Social Services into the New IHS Electronic Health Record System

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On September 6, 2024, the National Council of Urban Indian Health (NCUIH) submitted written comments to the Indian Health Service (IHS) Director, Roselyn Tso, regarding the IHS’ January 18, 2024, Dear Tribal Leader and Urban Indian Organization Leader letter (DTLL/DULL) about the August 8, 2024, joint Tribal Consultation and Urban Confer (TC/UC) session on Health Information Technology (HIT) Modernization: Multi-Tenant Domain Considerations. In its comments, NCUIH requested that IHS support all facility types to address inefficiencies during the implementation process and ensure social services are integrated into IHS’ new electronic health record (EHR) system.

Background on IHS HIT Modernization

During the November 8, 2023, TC/UC on HIT Modernization, IHS announced that it selected General Dynamics Information Technology, Inc. (GDIT) to build, configure, and maintain a new IHS enterprise EHR system utilizing Oracle Cerner technology. The new EHR, named Patients at the Heart (PATH), will replace the Resource and Patient Management System (RPMS).

For more information about HIT Modernization implementation, please click here.

NCUIH’s Requests

In its comments following the TC/UC, NCUIH recommended:

  • IHS should increase the value proposition for urban Indian organizations (UIOs) to participate in the PATH EHR:
    • Integrate social services into the PATH EHR
    • Support the unique interoperability needs of UIOs
    • Ensure security of patient health information
  • IHS should address the following challenges and risks that UIOs may face when transitioning from their current EHRs to the shared PATH EHR:
    • Lack of support for all UIO facility types
    • Failure to be included in pilot site and implementation cohort selection

NCUIH Advocacy on HIT Modernization

NCUIH has previously submitted several comments to IHS on HIT Modernization:

NCUIH also submitted written testimony  to the House Appropriations Subcommittee on Labor, Health and Human Services, Education, and Related Agencies regarding the Fiscal year (FY) 2024 funding for UIOs in which NCUIH requested increased funding for EHR Modernization. Specifically, NCUIH requested support for the IHS’ transition to a new EHR system for IHS and UIOs by supporting the President’s budget request of $913 million in FY 2024 appropriations.

NCUIH will continue to closely follow IHS’s progress and policies with HIT Modernization.

NCUIH Recommends Noncompetitive Funding Model and Support for Whole Family Substance Abuse Treatment in IHS Behavioral Health Initiatives

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On July 22, 2024, the National Council of Urban Indian Health (NCUIH) submitted comments to the Indian Health Service (IHS) Director, Roselyn Tso, in response to a May 21, 2024, Dear Tribal Leader and Dear Urban Indian Organization Leader letter (DTLL/DULL) and June 20, 2024, Urban Confer on IHS Behavioral Health Initiative Funding. In its comments, NCUIH recommended that IHS consider developing a funding methodology similar to the Special Diabetes Program for Indians (SDPI) National Funding Formula, which was developed to avoid competition for funds and to reduce barriers to access in an effort to ensure equitable distribution of funds for behavioral health grant funding.

Background

President Biden’s December 6, 2023, Executive Order (EO) 14112, “Reforming Federal Funding and Support for Tribal Nations To Better Embrace Our Trust Responsibilities and Promote the Next Era of Tribal Self-Determination,” directs Federal agencies to implement reforms to federal funding and support programs to make them more accessible, flexible, and equitable. In accordance with EO 14112, the IHS Division of Behavioral Health (DBH) is evaluating Agency-wide processes for distributing appropriated funding for behavioral health initiatives. In fiscal year 2024, the IHS administers more than $59 million in behavioral health initiatives funding, including the seven grant programs that address substance abuse, domestic violence, suicide, and youth regional treatment centers aftercare.

Almost every UIO provides behavioral health, mental health, or substance use disorder care, in addition to primary care services, Traditional Healing and Medicine, and social and community services. Further, seven UIOs have intensive inpatient/residential services as part of their behavioral health services. To fund this important work, 18 UIOs utilize the seven behavioral health grant programs that IHS is seeking feedback on to support and save lives, but the need for these programs is felt at all 41 UIOs.

NCUIH’s Recommendations and Requests

In response to the May 21 DTLL/DULL and June 20 Urban Confer, NCUIH made the following recommendations and requests to IHS regarding Behavioral Health Initiative Funding:

  • Ensure noncompetitive program awards across the I/T/U system
  • Support whole family treatment
  • Support for youth residential treatment centers at UIOs
  • Ensure funding reform for these programs does not create additional reporting requirements
  • Continue to engage with UIOs

NCUIH will continue to monitor as IHS conducts the grant funding evaluation process.

Department of Veterans Affairs Announces Revised Urban Indian Organization Reimbursement Agreement Program Template, Broadens Scope of Services

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On July 11, 2024, the Department of Veterans Affairs (VA)published a Dear Facility Leader letter announcing implementation of the revised VA-Urban Indian Organization (UIO) Reimbursement Agreement Program (RAP) template (hereinafter “revised agreement”). VA states that the revised agreement contains several key improvements designed to expand the scope of reimbursements and honors the unique capabilities and traditions of American Indian and Alaska Native Health Programs, including reducing duplicative terms, expanding timely filing to 36 months, and broadening the scope of services. For example, the revised agreement explicitly includes reimbursements for durable medical equipment (DME), prosthetics/orthotics and supplies, and home health services, while no longer explicitly excluding reimbursement for residential treatment. It also now includes dental services under “Reimbursement Rates for Direct Care Services.”

Download the Template

Background

The VA Indian Health Service (IHS)/Tribal Health Program (THP)/UIO RAP provides VA reimbursement to IHS, THP, and UIO health facilities for services provided to eligible American Indian and Alaska Native Veterans. The agreements program was first initiated in 2012 for IHS and Tribal health facilities. It was expanded in 2022 to include UIOs. The RAP is part of a larger effort to improve access to care and coordination for American Indian and Alaska Native Veterans under a broader VA-IHS Memorandum of Understanding managed by Veterans Health Administration (VHA). On May 1, 2024, VA hosted an Urban Confer regarding the revised template for the VA-UIO RAP template.

NCUIH’s Actions

NCUIH submitted comments on May 15, 2024, in response to the May 1, 2024, Urban Confer. In its comments, NCUIH recommended that VA continue to engage with and provide updates to UIOs on the revised agreement through its development; improve the UIO reimbursement rates under the revised agreement; ensure changes to the scope of services include services provided at UIOs; and provide technical assistance to UIOs to support UIO participation. NCUIH also previously submitted comments to VA in February 2022, requesting VA improve VA’s urban confer process and continue to improve VA’s relationship with UIOs.

NCUIH will continue to monitor developments regarding the RAP.

NCUIH Calls for Improved Data Accuracy, Partnerships with Other Agencies, and Urban Indian Health Inclusion in IHS Strategic Plan

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On June 28, 2024, the National Council of Urban Indian Health (NCUIH) submitted written comments to the Indian Health Service (IHS) Director, Roselyn Tso, in response to IHS’ May 2, 2024, Dear Urban Indian Organization (UIO) Leader Letter (DULL) and May 30, 2024, Urban Confer regarding IHS’ Draft Strategic Plan for Fiscal Years 2024-2028 (Draft Strategic Plan). In its comments, NCUIH requested that IHS include improved data accuracy and partnerships with other key agencies and stakeholders including the Office of Management and Budget in the agency’s Draft Strategic Plan.

Background on IHS Strategic Plan

The Draft Strategic Plan will establish IHS’ direction for the next five years. It is developed based on feedback received from Headquarters Offices and the Strategic Plan Workgroup and builds on the work of Headquarters Offices to determine appropriate measures. IHS is also incorporating input and feedback from other stakeholders including UIOs. The Draft Strategic Plan includes three Strategic Goals which consist of their own Strategic Objectives, Performance Goals, and Measures.

NCUIH’s Requests

In its comments in response to the May 2, 2024, DULL and May 30, 2024, Urban Confer, NCUIH requested that IHS:

NCUIH Requests Inclusive Governance and Equitable Cohort Selection for Urban Indian Organizations in IHS’ Health Information Technology Modernization Efforts

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On March 7, 2024, and June 7, 2024, the National Council of Urban Indian Health (NCUIH) submitted written comments to the Indian Health Service (IHS) Director, Roselyn Tso, regarding the IHS’ January 18, 2024, Dear Tribal Leader and Urban Indian Organization Leader letter (DTLL/DULL) about the February 8, 2024, and May 9, 2024, Tribal Consultation and Urban Confer (TC/UC) sessions regarding Health Information Technology (HIT) Modernization. In its comments, NCUIH requested that HIT Modernization governance be inclusive of urban Indian organizations (UIOs) by ensuring Domain Groups reflect the scope of facility types, and that the cohort selection process is equitable by ensuring that cohort selection equally prioritizes all facility types.

NCUIH’s Requests

The purpose of the February 8 TC/UC session was for IHS to receive feedback from Tribes and UIOs concerning the HIT Modernization Enterprise Collaboration Group (ECG). The ECG will be a user-focused body that will inform system configuration in clinical and administrative areas.  It will review preferred, evidence-based practices and recommendations for operational aspects of the EHR implementation and deployment. IHS stated that one of the purposes of the ECG is to ensure users of the enterprise EHR drive the configuration of the system that they will use for patient care. It will also engage Tribes and UIOs and their users in enterprise EHR management. Within the ECG there will be Domain Groups which will be multi-disciplinary bodies comprised of EHR users from IHS, Tribal health centers and UIOs (I/T/U) and will be forums for clinical and business subject matter experts to make EHR design and configuration recommendations on behalf of the end users the represent.

For the presentation slides from the February 8 TC/UC session, please click here.

In its comments to this urban confer, NCUIH requested IHS:

  • Ensure all UIO facility types are represented in the ECG Domain Groups
  • Encourage consideration of interoperability by the ECG either through existing Domain Groups or a new Domain Group
  • Ensure Tribal and UIO representation on the ECG Executive Committee
  • Clarify expectations, scope, and outcomes for Domain Groups

The purpose of the May 9 TC/UC session was for IHS to receive feedback from Tribes and UIOs concerning HIT Modernization deployment and cohort planning. IHS presented on the proposed timeline for deployment implementation pathways and approach, and the steps Tribes and UIOs can take to prepare for implementation at their individual sites. IHS will begin the HIT Modernization process by first having implementation occur at IHS pilot sites and then begin implementation at cohorts using the lessons learned from pilot sites. The cohorts will be groups of facilities selected for simultaneous system implementation.

For the presentation slides from the May 9 TC/UC session, please click here.

In its comments to this urban confer, NCUIH requested IHS:

  • Clarify the cohort identification process
  • Ensure IHS accounts for challenges related to operational and financial costs
  • Develop training materials for I/T/U facilities to use as a planning base to prepare for transitioning to a new Electronic Health Record (EHR)
  • Ensure IHS address data integration and migration process for a new EHR

NCUIH Advocacy on HIT Modernization

NCUIH has previously submitted several comments to IHS on HIT Modernization:

NCUIH also submitted written testimony  to the House Appropriations Subcommittee on Labor, Health and Human Services, Education, and Related Agencies regarding the Fiscal year (FY) 2024 funding for UIOs in which NCUIH requested increased funding for EHR Modernization. Specifically, NCUIH requested support for the IHS’ transition to a new EHR system for IHS and UIOs by supporting the President’s budget request of $913 million in FY 2024 appropriations.

NCUIH will continue to closely follow IHS’s progress and policies with HIT Modernization.

Background on IHS HIT Modernization

During the November 8, 2023, Tribal Consultation and Urban Confer on HIT Modernization, IHS announced that it selected General Dynamics Information Technology, Inc. (GDIT) to build, configure, and maintain a new IHS enterprise Electronic Health Record (EHR) system utilizing Oracle Cerner technology. The new EHR will replace the Resource and Patient Management System.

For more information about HIT Modernization implementation, please click here.

NCUIH Requests Enhanced VA Support and Improved Reimbursement Rates for Urban Indian Organizations in Reimbursement Agreement Program

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On May 15, 2024, that National Council of Urban Indian Health (NCUIH) submitted comments to the Department of Veterans Affairs’ (VA), in response to a May 1, 2024, Urban Confer regarding the revised template for the urban Indian organization (UIO)-VA Reimbursement Agreement Program (RAP) (“revised agreement”). In its comments, NCUIH requested that VA support UIO participation in the Program by providing technical assistance to UIOs and improving UIO reimbursement rates under the revised agreement.

Background

The VA Indian Health Service (IHS)/Tribal Health Program (THP)/UIO RAP provides VA reimbursement to IHS, THP, and UIO health facilities for services provided to eligible American Indian and Alaska Native Veterans. The agreements program was first initiated in 2012 for IHS and Tribal health facilities. It was expanded in 2022 to include UIOs. The RAP is part of a larger effort to improve access to care and coordination for American Indian and Alaska Native Veterans under a broader VA-IHS Memorandum of Understanding managed by Veterans Health Administration (VHA).

NCUIH previously submitted comments to VA in February 2022, requesting VA improve VA’s urban confer process and continue to improve VA’s relationship with UIOs.

NCUIH’s Recommendations

In its May 15, 2024, comments, NCUIH recommended that VA:

  • Continue to engage with and provide updates to UIO on the revised agreement through its development.
  • Improve the UIO reimbursement rates under the revised agreement.
  • Ensure changes to the scope of services include services provided at UIOs.
  • Provide technical assistance to UIOs to support UIO participation.

NCUIH will continue to monitor the development of the revised UIO-VA RAP template.