Tag Archive for: Comments

NCUIH Provides Recommendations to Federal Government Regarding Important Native Behavioral Health and Substance Use Disorder Program

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On January 30, 2024, the National Council of Urban Indian Health (NCUIH) submitted written comments to the Substance Abuse and Mental Health Services Administration (SAMHSA) Office of Tribal Affairs in response to SAMHSA’s July 2023 framing paper and October 2023 urban Indian organization (UIO) listening session concerning the development of the funding formula for the Behavioral Health and Substance Use Disorder Resources for Native Americans (BHSUDRNA) Program. NCUIH’s comments make seven key recommendations to SAMSHA when developing the funding methodology for the BHSUDRNA program.

Background

NCUIH, UIOs, Tribes, and Tribal Organizations worked closely with Congress to create a new Behavioral Health program modeled in part after the Special Diabetes Program for Indians (SDPI) to expand access to behavioral health funding for Native communities. Congress authorized this program via the Consolidated Appropriations Act, 2023 (CAA 2023).  The purpose of the Program is to provide services for the prevention of, treatment of, and recovery from mental health and substance use disorders among American Indians, Alaska Natives, and Native Hawaiians. The BHSUDRNA Program will be operated by SAMHSA in consultation with the Indian Health Service. Eligible entities include Urban Indian organizations.

NCUIH’s Recommendations

In its comments, NCUIH recommended that SAMHSA:

  • Ensure noncompetitive Program awards across the IHS/Tribal Organization/UIO (I/T/U) system.
  • Account for administrative duties in the funding formula.
  • Respect Traditional Healing and Indigenous Knowledge in the funding formula.
  • Ensure program measures do not impose additional burdensome reporting requirements.
  • Ensure that all information related to program application is widely available.
  • Seek additional expert feedback from Tribal Advisory Committees and Federal Agencies
  • Continue to engage with and incorporate UIO feedback in the development of the Program.

While Congress authorized $80 million in appropriations for this Program in each of Fiscal Years (FY) 2023-2027, Congress has not yet appropriated the necessary funding for the Program since its authorization. As part of its comments, NCUIH called on the Biden Administration to request that Congress fully fund the Program at the authorized levels.

NCUIH will continue to monitor the development of the funding formula for the BHSUDRNA Program and continue to advocate for Congress to fully fund the Program.

IHS Responds to NCUIH’s Request to Provide Clarity on the Health IT Modernization Implementation During Virtual Summit

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On December 13, 2023, the Indian Health Service (IHS) held the Health Information Technology (HIT) Modernization Virtual Summit. IHS gave Tribal and urban Indian organization (UIO) leaders an update on the HIT Modernization Program and provided a forum to engage with IHS on the Program. The purpose of the Summit was to raise awareness of the new enterprise Electronic Health Record (EHR) solution and to give Tribal and UIO leaders an opportunity to engage in a conversation with IHS on the HIT Modernization Program. In providing updates on the HIT Modernization implementation process, IHS also responded to comments that the National Council of Urban Indian Health recently submitted to the agency regarding HIT Modernization on December 8.

For more information on the Summit, please click here.

NCUIH Requested IHS Provide Clarity on the HIT Modernization Implementation

On December 8, 2023, NCUIH submitted comments and requests to IHS Director, Roselyn Tso, in response to a Tribal Consultation and Urban Confer and request for input on the HIT Modernization Program. In its comments, NCUIH urged IHS to maintain transparency in the HIT Modernization process to ensure that UIOs stay informed on the progress of the complex, multi-year rollout for the new EHR.

In its comments, NCUIH requested that IHS:

  • Clarify the HIT Modernization implementation process. This includes providing clarity on the vendor’s scope of work, the data migration process, and the ways in which IHS will support all facility types.
  • Provide an update to the timeline for HIT Modernization implementation. Specifically, NCUIH seeks clarity on the multi-year rollout cohort identification process.
  • Provide frequent and regular updates to the IHS HIT Modernization webpage.
  • Communicate the status of the Enterprise Collaboration Group (ECG).
IHS Responds to NCUIH’s Request Regarding Focus Groups and the Enterprise Collaboration Group

In NCUIH’s recently submitted comments to IHS regarding HIT Modernization, NCUIH requested clarification on the differences between the Focus Group and the ECG. During the Summit, IHS provided more information on the entities’ role in the HIT Modernization process.

Focus Groups are for every facility regardless of which EHR they are choosing to utilize. The ECG will be comprised of subject matter experts from IHS as well as Tribes and UIOs who provided statements of interest. It will be a chartered entity with many committees that will facilitate structured conversations to help manage the system. The ECG is for entities that will use the new system.

Other Takeaways from the HIT Modernization Program Updates

Timeline

The contract with GDIT is a 10-year indefinite delivery, indefinite quantity (IDIQ) contract. Initial go-live(s) expected to occur late Fiscal Year 2025. IHS requested Tribes and UIO maintain their current HIT system and keep data up to date to support EHR replacement if desired.

Substance Use Disorder Treatment and the New EHR

The EHR will support substance abuse/alcohol abuse treatment centers. IHS stated that it is working to understand how to share patient information with a health information exchange (HIE) partner in compliance with 42 CFR Part 2 (Confidentiality of Substance Use Disorder Patient Records). Because there are limits on how patient information can be shared, IHS is discussing how to share the information effectively under the rules and doing so in the HIE environment.

Background on 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 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 Action

NCUIH has submitted several written 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 Urges Office of Management and Budget to Fully Fund IHS and Fund Critical Indian Health Programs

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On September 29, 2023, the National Council of Urban Indian health (NCUIH) submitted comments to the Office of Management and Budget (OMB) Director, Shalanda Young, regarding the formulation of the President’s Fiscal Year (FY) 2025 Budget. In its comments, NCUIH made seven key recommendations to fully fund and support health services for urban Indian organizations (UIOs) and urban American Indian and Alaska Native (AI/AN) people.

Background

OMB serves as a clearinghouse for budget formulation by developing overarching presidential priorities, coordinating across agencies, and publishing the annual President’s Budget. For more information on OMB, please click here.

NCUIH’s Recommendations

In its comments, NCUIH recommended that the President’s FY2025 budget:

  • Fully fund the Indian Health Service (IHS) and the Urban Indian Health Line Item , as recommended by the Tribal Budget Formulation Workgroup. Full funding for IHS in the President’s FY 2025 Budget will address the following UIO priorities:
    • Infrastructure and facility needs
    • Food security
    • Traditional Healing
    • Health information technology and electronic health record modernization
  • Safeguard IHS and UIO funding by transitioning the IHS budget from discretionary funding to mandatory funding and exempting IHS funding from sequestration.
  • Propose setting the Federal Medical Assistance Percentage (FMAP) at 100% for Medicaid services provided at UIOs.
  • Request inclusion of $80 million for the Native Behavioral Health Resource Program (NBHRP).
  • Propose permanent reauthorization of the Special Diabetes Program for Indians (SDPI) at $250 million, if not reauthorized in the FY 2024 budget.
  • Request a legislative fix permitting the U.S. Public Health Service Commissioned Corps Officers to be detailed to UIOs

NCUIH will continue to monitor the FY 2025 budget formulation process and report developments across federal agencies and in Congress.

NCUIH Advocates for HHS Office of Minority Health to Address AI/AN Needs in Healthy People 2030 Leading Health Indicators Initiative

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On October 31, 2023, the National Council of Urban Indian Health (NCUIH) submitted written comments in response to the Department of Health and Human Services (HHS) Office of Minority Health’s (OMH) September 13, 2023, letter regarding the development of a Notice of Funding Opportunity (NOFO) entitled Healthy People 2030 Leading Health Indicators Initiative (LHII). In its comments, NCUIH urges OMH to consider the health needs of American Indian and Alaska Native people living in urban areas when developing the NOFO, in accordance with Congress’ directive in the Indian Health Care Improvement Act “to raise the health status of Indians and urban Indians to at least the levels set forth in the goals contained within the Healthy People 2010 initiative or successor objectives,” like Healthy People 2030. NCUIH highlighted particular leading health indicators (LHIs) which impact American Indians and Alaska Natives living in urban areas, such as maternal deaths, food insecurity, diabetes, behavioral health, substance use disorders, and drug overdose deaths, and also 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.

Background

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, the initiative’s fifth iteration, builds on knowledge gained over the first four decades. The Healthy People 2030 LHII is intended to identify innovative adaptations of evidence based/evidence informed practices that improve health outcomes related to Healthy People 2030 LHIs among racial, ethnic, tribal and other disadvantaged communities.

LHIs are a small subset of high-priority Healthy People 2030 objectives selected to drive action toward improving health and well-being. Most LHIs address important factors that impact major causes of death and disease in the United States, and they help organizations, communities, and states across the nation focus their resources and efforts to improve the health and well-being of all people. Healthy People 2030 includes 23 LHIs that are organized by life stage: Infants, Children and Adolescents, Adults and Older Adults, and All Ages.

Projects funded under the LHII will implement public health improvement models intended to improve health for one to two Healthy People 2030 LHIs in geographic areas targeted by the recipients. OMH also expects the initiative will result in enhanced capacity of public health, community, and government entities to address and reduce health disparities in geographic areas targeted by the recipients.

Next Steps

NCUIH will continue to monitor the development of the Healthy People 2030 Leading Health Indicators Initiative and advocate on the inclusion of issues of importance to American Indians and Alaska Natives living in urban areas and the UIOs that serve them.

NCUIH Submits Comments to CMS with Recommendations on Native American Access to Medicaid Services

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On July 3, 2023, the National Council of Urban Indian Health (NCUIH) submitted written comments and recommendations to the Centers for Medicare and Medicaid Services (CMS) Administrator, Chiquita Brooks-LaSure, in response to the May 2, 2023, request for comment on the CMS proposed rule regarding ensuring access to Medicaid services (CMS–2442–P).  NCUIH urged CMS to specifically consider how the proposed sections will advance the Nation’s efforts to fulfill its trust responsibility to provide services to maintain and improve the health of American Indians and Alaska Natives (AI/ANs).

NCUIH recommended that CMS take the following actions:

In its comments, NCUIH recommended that CMS ensure AI/AN representation on each state Medicaid Advisory Committee (MAC) and Beneficiary Advisory Group (BAG), ensure the rule does not impose additional burdensome reporting requirements on providers, engage with the Tribal Technical Advisory Committee (TTAG) to consider regulations or guidance to enforce the state consultation and confer requirements, and support 100% Federal Medical Assistance Percentage (FMAP) for Medicaid services provided at urban Indian organizations (UIOs) to ensure AI/AN Medicaid beneficiaries receive appropriate, quality culturally competent care. By extending this funding mechanism to cover all Medicaid services provided at UIOs, CMS can make substantial progress in reducing the existing barriers to healthcare access faced by urban Native populations.

Background on the Proposed Rule Ensuring Access to Medicaid Services (CMS–2442–P):

The proposed rule, Ensuring Access to Medicaid Services, includes both proposed changes to current requirements and newly proposed requirements that would advance CMS’s efforts to improve access to care, quality, and health outcomes, and better promote health equity for Medicaid beneficiaries across fee-for-service (FFS) and managed care delivery systems, including for home and community-based services provided through those delivery systems. These proposed requirements are intended to increase transparency and accountability, standardize data and monitoring, and create opportunities for states to promote active beneficiary engagement in their Medicaid programs.

Background on Medicaid and AI/ANs:

AI/AN people depend upon Medicaid to receive their healthcare coverage and services. In 2020, over 1.8 million AI/ANs were enrolled in Medicaid. According to a NCUIH analysis of American Community Survey (ACS) data, in 2019 Medicaid covered 1.3 million urban AI/ANs, including 30% of urban AI/AN adults under the age of 65. Medicaid and CHIP are important programs for addressing the significant disparities in insurance coverage which exist for AI/AN people.  For example, according to the Urban Institute, AI/AN children were uninsured at a rate of 8.9% in 2019, the highest rate for any ethnic group in the country.  AI/AN parents were uninsured at a rate of 18.7% in 2019, the second highest rate in the country. The Urban Institute reported that in 2019, AI/AN children remained more than twice as likely as white children to be uninsured and AI/AN were more than 2.5 times more likely to be uninsured than with white parents.

Medicaid is also an important source of funding for to support the operation of the Indian Health system, including UIOs who help serve the approximately 70% of AI/AN people who live in urban areas.  Medicaid remains the largest secondary source of funding for UIO clinics. In 2020, 33% of the total population served at UIOs were Medicaid beneficiaries, and 35% of the AI/AN population served at UIOs were Medicaid beneficiaries. As the Kaiser Family Foundation noted in 2017, “Medicaid funds are not subject to annual appropriation limits . . . since Medicaid claims are processed throughout the year, facilities receive Medicaid funding on an ongoing basis for covered services provided to AIANs.”  Because the Medicaid program receives Mandatory appropriations, Medicaid revenue is particularly essential for Indian health providers when IHS funding is reduced or interrupted by budgetary disagreements.

Supreme Court Held Oral Argument on Case Challenging the Indian Child Welfare Act

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On November 9, 2022, the Supreme Court of the United States held oral argument in Haaland v. Brackeen, a case challenging the constitutionality of the Indian Child Welfare Act of 1978 (ICWA). The questions presented to the Court in Brackeen are: (1) Whether various provisions of ICWA violate the anticommandeering doctrine of the Tenth Amendment; (2) Whether the individual plaintiffs have Article III standing to challenge ICWA’s placement preferences for “other Indian families,” and for “Indian foster home[s];” (3) Whether the default placement preferences for Indian homes in adoption or foster care cases are rationally related to legitimate governmental interests and therefore consistent with equal protection. The Supreme Court’s decision in Brackeen will have far-reaching implications on all areas of Federal Indian Law and policy and the National Council of Urban Indian Health (NCUIH) continues to advocate for the protection of ICWA to safeguard American Indian/Alaska Native (AI/AN) children and families.

Summary of Oral Argument

Oral argument for Brackeen lasted over three hours and focused heavily on the scope of Congress’s constitutional authority to legislate on behalf of AI/ANs, the equal protection limitations on that power, and whether the requirements imposed on states by the ICWA, particularly the “active efforts” requirement, violates the anticommandeering doctrine. Oral argument began with the parties challenging ICWA, referred to as “plaintiffs.” Solicitor General Judd Stone argued on behalf of the state of Texas, and Matthew McGill, a partner at Gibson, Dunn & Crutcher, argued on behalf of the potential adoptive families. The plaintiffs’ arguments centered on the assertion that ICWA deprives Indian children and non-Indian prospective parents of the “best interest of the child” standard in child welfare proceedings in violation of the Equal Protection Clause. The parties defending ICWA, referred to as “defendants,” argued second. Deputy Solicitor General Edwin Kneeler argued on behalf of the federal defendants and Ian H. Gershengorn, a partner at Jenner & Block, LLC , argued on behalf of the intervening Tribes (the Cherokee Nation, Oneida Nation, Quinault Nation, and Morongo Band of Mission Indians).  The defendant’ arguments centered on the fact that Congress has broad power to legislate in Tribal affairs, and this power is limited only by other constitutional provisions or by the test set by Supreme Court precedent in Morton v. Mancari, 417 U.S. 535 (1974), which requires congressional action to be rationally related to the fulfillment of Congress’ unique obligations to Indians.

Background on Haaland v. Brackeen

Congress enacted the ICWA in 1978 to re-establish Tribal authority over the adoption of AI/AN children. ICWA is a procedural safeguard to “protect the best interests of Indian children and to promote the stability and security of Indian Tribes and families.” 25 U.S.C. § 1902. In Brackeen, Texas, Indiana, Louisiana, and individual plaintiffs (plaintiffs) sued the federal government in the U.S. District Court for the Northern District of Texas, arguing that ICWA and its implanting regulations are unconstitutional because they violate the equal protection and substantive due processes provisions of the Fifth Amendment and violate the anticommandeering doctrine of the Tenth Amendment.  The plaintiffs also argued that ICWA and the implementing regulations violate the nondelegation doctrine and the APA. The District Court ruled in favor of the plaintiffs, finding that the ICWA violates the Constitution’s guarantee of equal protection because it applies to all children eligible for membership in a Tribe, not just enrolled tribal members, and therefore operates as a race-based statute.  The District Court further held that ICWA violates the Tenth Amendment’s prohibition on the federal government issuing direct orders to states and unconstitutionally delegates Congress’s power by giving Tribes the authority to change adoption placement preferences and make states abide by them. On appeal, the Fifth Circuit reversed the District Court’s opinion in most respects. In a fractured ruling, the Fifth Circuit sitting en banc upheld portions of the District Court’s opinion and reversed other portions.

In early September 2021, the United States government, tribal defendants, as well as state and private plaintiffs filed petitions asking the United States Supreme Court to review the Fifth Circuit’s decision. The U.S. Supreme Court agreed to review the Fifth Circuit’s decision in Brackeen v. Haaland on February 28, 2022, and held oral argument on November 9, 2022.

NCUIH Advocacy

On August 19, 2022, NCUIH and five urban Indian organizations (UIOs) (Nebraska Urban Indian Health Coalition, Inc., Sacramento Native American Health Center, Fresno American Indian Health Project, All Nations Health Center, and Oklahoma City Indian Clinic) signed on to the National Indigenous Women’s Resource Center’s (NIWRC) amicus brief to the Supreme Court in support of the constitutionality of ICWA in the  Haaland v. Brackeen case. NCUIH worked directly with NIWRC to engage with UIOs to ensure that the submitted brief was inclusive of urban AI/ANs. On September 7, NCUIH submitted written comments to the Bureau of Indian Affairs (BIA) and the Administration for Children and Families (ACF) on the BIA and ACF’s efforts to promote the consistent application of ICWA) and protect children, families, and Tribes.

NCUIH previously provided an in-depth analysis on the impact of ICWA and will continue to monitor ongoing developments.

Next Steps

The Supreme Court will hand down a decision by the end of the 2022 term on July 1, 2023. Due to the complex nature of the case, a decision is not expected until the Spring. The Supreme Court’s decision in Brackeen will have far-reaching implications on all areas of Federal Indian Law and policy. The recognition that the AI/AN classification is political classification rather than racial is a critical underpinning of not just ICWA, but many laws that relate to housing, healthcare, education, and employment. This political classification goes back to the 19th Century and has been upheld by Courts at multiple levels. Acknowledging the importance of tribal citizenship, AI/ANs are classified by this citizenship, not by their race.  If overturned, the repeal of ICWA would not only upend a law in place for more than 40 years but undercut the heart of tribal sovereignty and the federal government’s trust responsibility to Native communities.

NCUIH Submits Comments to IHS Regarding the Office of Urban Indian Health Programs Strategic Plan and Implementation Plan

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On December 15, 2022, the National Council of Urban Indian Health (NCUIH) submitted comments to the Indian Health Service (IHS) regarding additional input and recommendations for revisions to the third draft of the IHS Office of Urban Indian Health Programs (OUIHP) Strategic Plan and the Implementation Plan. The Strategic Plan and the Implementation Plan will be significant in guiding the provision of high-quality and culturally competent health care in fulfillment of the United States’ trust obligation to American Indian/Alaska Native (AI/AN) people. These comments were submitted in response to a November 17, 2022 Dear Urban Leader letter seeking input and recommendations for the final draft of the 2023-2027 IHS OUIHP Strategic Plan and Implementation Plan.

Background

In 2017, IHS developed an OUIHP Strategic Plan 2017-2021, pursuant to the Consolidated Appropriations Act, which described what the Agency hoped to achieve over the next 5 years. IHS is currently finalizing a new OUIHP Strategic Plan for 2023-2027 based on evaluations of the prior Strategic Plan along with participation and feedback received from urban Indian organization (UIO) leaders, IHS staff, and other stakeholders. According to the OUIHP, the new Plan will include goals, objectives, strategies, and performance measures, based on input from UIO Leaders, partners, and external stakeholders.

NCUIH’s Role

NCUIH has submitted three separate comments and recommendations to IHS regarding the Plan. These comments were based on NCUIH’s consultations with UIOs, the IHS Urban Confer held on December 15, 2022, and NCUIH’s subject matter expertise. NCUIH reiterated that input from UIOs is vital for IHS and its operating divisions to effectively gather comprehensive feedback, share critical information, and build mutual trust.

Recommendations

As OUIHP works to finalize the Strategic Plan for 2023-2027, NCUIH made numerous recommendations to strengthen the OUIHP strategic plan.  Among these recommendations were keeping strategic pillars from the prior draft regarding facilitating communication with federal partners on UIO issues and to provide technical assistance to UIOs transitioning from an outreach and referral program to an ambulatory clinic. Further, NCUIH recommended revisions on a strategic pillar to retain strategies regarding receiving 100% Federal Medical Assistance Percentage (FMAP) for UIOs.

NCUIH thanks the OUIHP for the hard work in developing this comprehensive third draft and for conferring with UIOs on additional recommendations. NCUIH also appreciates the opportunity to provide additional comments and recommendations on the OUIHP Strategic Plan Draft 3.  NCUIH strongly believes that the Strategic Plan and the Implementation Plan are important vehicles to articulate leadership priorities, provide direction for program management functions, engage external partners and entities, and measure OUIHP’s progress toward meeting the goals and objectives of IHS. NCUIH looks forward to the final version of the 2023-2027 Strategic Plan and to working with OUIHP to ensure both the Strategic Plan and Implementation Plan are successful.

NCUIH Submits Comments to the Department of Veterans Affairs and IHS on VHA-IHS Memorandum of Understanding Operational Plan

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On November 30, 2022, NCUIH submitted comments to the U.S. Department of Veterans Affairs (VA) and the Indian Health Service (IHS) regarding the Veterans Health Administration (VHA) and IHS first-ever Draft Annual Operational Plan for fiscal year (FY) 2022 for the VHA-IHS Memorandum of Understanding (MOU). The MOU establishes a framework for coordination and partnership between VHA and IHS to leverage and share resources and investments in support of each organization’s mutual goals. NCUIH believes that the Draft Annual Operational Plan (Operational Plan) can be a significant step forward in implementing the IHS-VHA MOU and ensuring high quality health care for all American Indian/Alaska Native (AI/AN) veterans and continues to work closely with our colleagues at VA and IHS to ensure that Native veterans receive access to the care they earned through their military service, no matter where they live.

Background

AI/AN veterans have served in the United States military in every armed conflict in the Nation’s history and have traditionally served at a higher rate than any other population in the United States. In return for their service, the United States promised all veterans, including Native veterans, “exceptional health care that improves their health and well-being.” However, of the estimated 86.2 percent of AI/AN veterans that live in urban areas, they generally have higher unemployment, lower education attainment, lower income, higher VA-service connected disability, and generally live in poorer housing conditions than non-Native veterans also living in urban areas.

Recommendations

In its comments, NCUIH stressed the importance of the Operational Plan being a vehicle to articulate leadership priorities, provide direction for program management and distribution of resources, engage internal and external partners, and measure the overall progress toward meeting the MOU’s goals and objectives. NCUIH’s comments emphasized the importance of having OUIHP representation and leadership throughout the plan. As subject matter experts in the health needs of Natives living in urban areas, having representatives who are familiar with UIOs will ensure the needs of urban Native veterans are incorporated into the plan’s actions. Additionally, to improve the collaboration between the VA and IHS, and to ensure that care for AI/AN veterans is not disrupted, NCUIH recommended that the Operational Plan has a strategy in place to achieve seamless referrals between the VA and the I/T/U system. NCUIH further stressed the importance of regular consultation with Tribal Governments, Urban Confers with UIOs, and meetings with the HHS Secretary’s Tribal Advisory Committee on Tribal and Indian Affairs.  Moreover, because VA data currently indicates that Native veterans use Veterans Benefits Administration benefits or services at lower percentages than other veterans, NCUIH recommended that the Operational Plan add an additional objective be added to increase AI/AN veteran use of VA benefits and services.

NCUIH’s work with the VA

NCUIH continues to work on behalf of Native veterans living in urban areas to ensure that they have access to the high-quality, culturally competent care the country owes to them for their military service and as a result of the trust responsibility.

For more information on NCUIH’s efforts please visit:

 

 

 

 

 

 

 

 

NCUIH Submits Comments to HRSA to Improve Access to Pediatric Health Care in Urban Native Communities

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On August 31, 2022, the National Council of Urban Indian Health (NCUIH) submitted comments to the Health Resources and Services Administration (HRSA) on the Pediatric Mental Health Care Access (PMCHA) Program. In a July 27 Dear Tribal Leader Letter, HRSA explicitly sought feedback from Urban Indian Organizations (UIOs) about how to increase access to and improve pediatric behavioral health care through telehealth and the PMCHA program’s development and implementation. NCUIH’s comments address the essential role of access to pediatric mental health care for American Indian/Alaska Native (AI/AN) communities across the country, including AI/AN communities in urban areas.

Background

According to the Indian Health Service (IHS), Native youth living off-reservation share similar health problems to their AI/AN peers nationwide, which are exacerbated by lack of access to family and traditional cultural environments. Notably, the AI/AN youth suicide rate is 2.5 times that of the national average.

UIOs are actively engaged in overcoming, addressing, and preventing mental and behavioral health issues in urban AI/AN youth. Virtually every UIO offers mental and behavioral health services, which became critically important during the height of the pandemic for families to continue accessing needed health care services to keep their doors open in the wake of reduced in-person visits. Since then, UIOs have continued to provide telehealth services to their patients, especially for mental and behavioral health programs.

Recommendations

NCUIH provided the following recommendations to HRSA regarding pediatric mental health care and telehealth services:

  • Facilitate UIO Participation in the PMHCA Program
    NCUIH urged HRSA to facilitate UIO participation in the PMHCA program. Although UIOs are a critical source of health care for urban AI/AN communities, they are often left underfunded and under resourced because federal grant programs unintentionally exclude UIOs. Accordingly, NCUIH suggested that whenever HRSA is asked to provide technical assistance on the PMHCA program to Congress, it advises Congress of this exclusion and a legislative fix to expand eligibility to UIOs. Any expansion of eligibility should be accompanied by a similar expansion in funding for the PMHCA program to ensure that there is no decrease in funding available for Tribes or Tribal organizations.
  • Continue to Engage with UIOs and Develop an Urban Confer Policy
    NCUIH recommended that HRSA continues to foster its relationship with UIOs through consistent and timely communication to UIOs. We further encouraged HRSA to cultivate meaningful partnerships between other federal agencies and stakeholders to notify UIOs when they are eligible for certain programs. Finally, NCUIH urged HRSA to develop an Urban Confer Policy, which would ensure HRSA’s services are more responsive to the needs and desires of urban AI/AN communities.

We will continue to monitor ongoing implementation of HRSA’s pediatric behavioral and mental health care programs that serve Indian Country.

NCUIH Submits Recommendations to HHS to include Support for Urban Native Communities in its Initiative to Strengthen Primary Health Care

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On August 1, 2022, the National Council of Urban Indian Health (NCUIH) submitted written comments to the Department of Health and Human Services (HHS) Office of the Assistant Secretary for Health (OASH) in response to its request for information (RFI) regarding the HHS Initiative to Strengthen Primary Care. NCUIH supports HHS’ efforts to promote health equity and reduce barriers to care for underserved populations, including American Indians/Alaska Natives (AI/ANs). AI/ANs, including those in urban areas, face significant health disparities attributable in part to a lack of access to high-quality, culturally competent care. NCUIH strongly supports the purpose and scope of the Initiative in establishing a federal foundation that supports advancement towards the stated “goal state” of the practice of primary health care.

NCUIH made the following specific recommendations to HHS OASH:
  • Support UIO models for health care delivery already in place at UIOs:
    • NCUIH recommended that HHS address the need for continued and expanded support for UIOs.
    • UIOs are a fundamental and inseverable component of the IHS, Tribal Health Program, and UIO (I/T/U) system. UIOs “are an important support to Native families and individuals seeking to maintain their values and ties with each other and with their culture,” which exist to provide “a wide range of culturally sensitive programs to a diverse clientele.”
  • Address barriers to the delivery of care at UIOs like insufficient funding and resources:
    • Presently, the ability of UIOs to expand upon their current offerings is severely limited by the chronic underfunding of the Indian health system generally, and UIOs in particular. In 2018, the average health care spending was $11,172 per person nationally, yet UIOs only received $672 per AI/AN patient.
    • NCUIH requested that HHS engage with other federal agencies and Congress to advocate for advance appropriations for the IHS. In addition to a lack of funding, UIOs also face significant barriers to providing primary care to AI/ANs in urban areas due to uncertainty over the consistency and timing of federal funding.
    • NCUIH requested that HHS consider supporting UIO recruitment efforts and increasing funding for staff at UIO facilities. UIOs have long faced understaffing issues that reduce the number of patients they can serve and the quality of service at each facility.
  • Establish an Urban Confer Policy
    • NCUIH recommended that HHS establish an Urban Confer policy to seek UIO input to guide HHS actions to strengthen primary health care. An Urban Confer is an established mechanism for dialogue between federal agencies and UIOs. Urban Confers are responses to decades of deliberate federal efforts (i.e., forced assimilation, termination, relocation) that resulted in 70 percent of AI/AN people living outside of Tribal jurisdictions, thus making Urban Confers integral to addressing the care needs of most AI/AN persons.
    • The development of an HHS Urban Confer policy will help coordinate and integrate care between UIOs and HHS, including the relevant agencies and Departments within HHS that have a trust responsibility to provide care to AI/ANs no matter where they live.
    • An urban confer policy will also help HHS fulfill the United States’ national policy, set forth by Congress, “to ensure maximum Indian participation in the direction of health care services so as to render the persons administering such services and the services themselves more responsive to the needs and desires of Indian communities.”
Background on the HHS Initiative to Strengthen Primary Care

Access to high-quality primary health care has been shown to improve health equity and health outcomes, however, the United States’ primary health care foundation is weakening and in need of support: primary health care is under-resourced; the workforce is shrinking; workforce well-being is in peril; and many practices face reimbursement challenges that may result in financial instability. In response to this, OASH launched the Initiative in September 2021 to develop a federal foundation for the provision of primary health care for all that supports improved health outcomes and advanced health equity.  The goals of the Initiative are to:

The first task of the Initiative is to develop an initial HHS plan for strengthening primary health care that will delineate specific actions that HHS agencies and offices may take to achieve the aims, within the current legislation and funding environment. The plan will also include actions that establish an infrastructure in HHS to continue its focus on strengthening primary health, develop subsequent HHS plans that build on the initial plan, and monitor progress and impact. The purpose of OASH’s June 15 RFI was to provide OASH with diverse perspectives, experiences, and knowledge that may inform the development of the initial plan for HHS, as well as future steps for the Initiative.

NCUIH remains committed to advocating for the health rights of urban AI/ANs and continues to respond to requests for information when applicable.