Tag Archive for: Comments

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.

NCUIH Submits Comments to the Indian Health Service on the Creation of an Urban Indian Interagency Workgroup

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On September 12, 2022, the National Council of Urban Indian Health (NCUIH) submitted comments and recommendations to the Indian Health Service (IHS) regarding the formation of an Urban Interagency Workgroup with other federal agencies. The agency held an Urban Confer on July 13, in response to a letter sent to President Biden and Vice President Harris from several Senators, requesting the formation of such a workgroup. NCUIH supports the development of an Interagency Workgroup and believes that this would be a key step to increasing support and resources to American Indians/Alaska Natives (AI/ANs) living in urban areas.

NCUIH Recommendations to IHS

NCUIH noted in the comments that Tribes have a unique government-to-government relationship with the federal government and it is essential that any group does not disrupt this. Furthermore, NCUIH supports the federal government in its attempts to better uphold the trust responsibility it has to AI/ANs living in urban areas, which requires more complete involvement of urban Indian organizations (UIOs). However, this does not mean that resources and funding should come at the expense of Tribes. Rather, the government should broaden and deepen the services it provides to all AI/ANs while additionally further meeting the trust responsibility to urban-dwelling AI/ANs.

NCUIH provided the following recommendations to IHS in response to the Urban Confer:

  • Respect Tribal Sovereignty and the government-to-government relationship in the formation of an Interagency Workgroup.
  • Create a committee within the White House Council on Native American Affairs (WHCNAA) focused on how federal agencies can better serve AI/ANs living in urban areas.
    • The White House Council on Native American Affairs (WHCNAA) was established to improve outcomes for AI/AN communities through a stronger relationship between the federal government and Native people.
    • Developing an Interagency Oversight Committee on Urban Indian Affairs within WHCNAA would allow cross-collaboration across all agencies and ensure that all other WHCNAA committees are accurately incorporating urban Indian communities into their work.
  • IHS should provide technical assistance to federal agencies to develop Urban Confer policies.
    • Urban Confer policies or UIO-specific consultations do not supplant or otherwise alter Tribal Consultations and the government-to-government relationship between Tribes and federal agencies. IHS should provide support and assistance to federal agencies as they begin the development of such policies.

Background

The formation of an Urban Indian Interagency Work Group to identify the needs and develop strategies to better serve urban AI/AN populations has been a priority for NCUIH. On February 3, 2022, Senator Van Hollen, along with Senators Alex Padilla (D-CA), Catherine Cortez Masto (D-NV), Tina Smith (D-MN), Dianne Feinstein (D-CA), Elizabeth Warren (D-MA), Ed Markey (D-MA), Mark Kelly (D-AZ), Amy Klobuchar (D-MN), Patty Murray (D-WA), Tammy Baldwin (D-WI), Jacky Rosen (D-NV), Jeff Merkley (D-OR), and Jon Tester (D-MT) sent a letter to the Biden Administration requesting the establishment of this workgroup. NCUIH worked closely with Senator Padilla on this letter and supports the effort to bring better representation for the needs of AI/ANs who do not reside on Tribal land.

The Senate Appropriations Subcommittee directed IHS to continue to explore the formation of this interagency working group in its Fiscal Year 2023 Interior Appropriations bill, noting that “in addition to the Indian Health Service, the working group should consist of the U.S. Department of Health and Human Services, U.S. Department of Housing and Urban Development, U.S. Department of Agriculture, U.S. Department of Justice, U.S. Department of Education, U.S. Department of Veteran Affairs, U.S. Department of Labor, the Small Business Administration, the Economic Development Agency, FEMA, the U.S. Conference of Mayors, and others as identified by UIOs.”

The Work Group would help identify federal funding strategies to better address the needs of urban AI/ANs, advance the development of a wellness-centered framework to inform health services, strengthen support for practice-based traditional healing approaches, improve Urban Confer policies at Health and Human Services and associated agencies, and ensure that Urban Indian Organizations can regularly meet with federal agencies to address relevant topics of concern.

NCUIH will continue to monitor for any further development on the formation of an Urban Interagency Workgroup. NCUIH will also continue to engage with IHS, the White House, and Congress on moving this proposal forward.

NCUIH Submits Comment on Consistent Application of the Indian Child Welfare Act

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On September 7, the National Council of Urban Indian Health(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 the Indian Child Welfare Act (ICWA) and protect children, families, and Tribes.

In the submitted comments, NCUIH made the following specific comments, requests, and recommendations to ACF and BIA in response to the July 8, 2022 correspondence:

  • Ensure that urban child welfare and judicial systems are aware of and able to implement ICWA appropriately
    • According to the National Indian Child Welfare Association (NICWA), American Indian/Alaska Native(AI/AN) children continue to be overrepresented in the state foster care system at a rate 7 times higher than their non-Native peers. Because more than 70% of AI/AN people live in urban settings, this overrepresentation undoubtedly includes AI/AN children living in urban areas.
    • To properly implement ICWA, state courts must determine whether a child is an “Indian Child” for the purposes of ICWA as a threshold determination in the proceedings. There are states with experience in the application of ICWA and making applicability determinations. However, some state courts and child protective agencies may not be aware of this requirement or may make incorrect assumptions about a child’s “Indian child” status based on physical appearance or distance from their Tribe. This process needs to be standardized across all states to ensure the safety of these children
    • An AI/AN child’s physical location should not affect whether they receive ICWA’s protections. Specifically, NCUIH requests that ACF and BIA provide technical assistance on ICWA to state social service and child welfare agencies and courts located in urban areas.
  • Actively inform urban child welfare and judicial systems about urban Indian organizations (UIOs) as a potential resource for ICWA proceedings
    • NCUIH recommended that, as part of their efforts to strengthen and implement ICWA, ACF and BIA actively inform state child welfare and judicial systems located in urban areas about UIOs as a potential ICWA resource.
    • While UIOs are healthcare organizations, they often provide culturally competent services that state child welfare services and courts can refer parents to in accordance with ICWA’s “active efforts” requirements. For example, various UIOs provide the following services: family support services, parenting classes and groups, gender-based violence programs, and breastfeeding support.
    • Because UIOs are AI/AN organizations, they may be able to provide useful contacts or other information when a state child welfare agency throughout the child welfare process, including during the initial “Indian child” determination phase.
    • The UIO connection may be particularly useful in areas, such as Chicago, where there is an active UIO but no federally recognized Tribes nearby, and urban systems may not know where to start with the ICWA process.

Background

Congress enacted ICWA in 1978 to re-establish tribal authority over the adoption of Native American children (25 U.S.C. § 1903.) The goal of the Act was to strengthen and preserve Native American family structure and culture. Studies conducted in advance of ICWA’s drafting showed that between 25% and 35% of all Native children were being removed from their home by state child welfare and private adoption agencies. Of those, 85% were placed with non-Native families, even when fit and willing relatives were available. ICWA was established as a safeguard that requires:

  1. Recognition of Tribal jurisdiction over decisions for their Indian children;
  2. Establishment of minimum Federal standards for the removal of Indian children from their families;
  3. Establishment of preferences for placement of Indian children with extended family or other Tribal families; and
  4. Institution of protections to ensure that birth parents’ voluntary relinquishments of their children are truly voluntary.

According to NICWA, ICWA “[l]essens the trauma of removal by promoting placement with family and community . . . [p]romotes the best interest of Indian children by keeping them connected to their culture, extended family, and community, which are proven protective factors . . . [and] [p]romotes placement stability by ensuring that voluntary adoptions are truly voluntary.”

Next Steps

NCUIH will continue to advocate for  the appropriate application of ICWA to all welfare proceedings involving AI/AN children, regardless of whether the child is located in an urban or rural community.

 

 

USDA Publishes 2022 Tribal Resource Guide

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On August 16, 2022, the United States Department of Agriculture (USDA) released the 2022 edition of the USDA Resource Guide for American Indians and Alaska Natives (Resource Guide). The Resource Guide provides information regarding USDA resources and services available to tribal governments, citizens, and organizations. The Resource Guide covers four categories of USDA programs: 1) agriculture, food sovereignty, and traditional foods; 2) Indian Country economic development; 3) conservation and forestry; and 4) research, extension, and outreach. Additionally, the USDA released the Native Youth Resource Guide (Youth Guide). The Youth Guide summarizes USDA scholarship opportunities, internship programs, cultural summer camps for Native youth, afterschool activities, and resources for employment in the federal government.

Background

The USDA is a federal executive department responsible for food, agriculture, natural resources, rural development, nutrition, and related issues within the United States. The USDA plays an important role in the development of tribal nations and self-governance.  Funding from the USDA helps grow new tribal agricultural ventures, promote traditional food ways, and benefit Indigenous health through foods tailored to American Indian/Alaska Native dietary needs. As a federal agency, the USDA helps advance the federal trust responsibility to Native American communities.

The newly published Resource Guides seek to provide transparency to tribal nations. “These guides can introduce our tribal nation partners to the many USDA funding opportunities and resources that can benefit them and their communities,” remarked Secretary of Agriculture, Tom Vilsack. NCUIH recommends tribal nations use the Resource Guides to help facilitate growth within Indian Country.

NCUIH Comments on the IHS Urban Indian Infrastructure Study

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On August 23, 2022, the National Council of Urban Indian Health (NCUIH) submitted comments regarding additional funding for the Urban Indian Infrastructure Study (Infrastructure Study) provided by the Consolidated Appropriations Act, 2022. The additional fiscal year (FY22) funding for the Infrastructure Study is approximately $800,696. NCUIH supports the appropriation of the additional funding and it recommended that IHS disseminate the findings of the FY21 Infrastructure Study, already in progress, to UIOs prior to making any decisions regarding the use of the additional funding. NCUIH also requested that the Office of Urban Indian Health Programs (OUIHP) create a timeline of when the Infrastructure Study will be released to UIOs, the contracting process necessary to use additional funding, and the deadline for obligation of the additional funding. Lastly, NCUIH requested that IHS host an additional Urban Confer after the release of updates about the scope and results of the FY21 Infrastructure Study.

Background

In 2021, Congress allocated $1 million in funds for IHS to conduct an Urban Indian Infrastructure study through the Consolidated Appropriations Act, 2021. The purpose of the Infrastructure Study is to further understand the most critical deficiencies facing UIOs. IHS contracted with The Innova Group, a healthcare consultancy entity, to conduct the Infrastructure Study.

On March 15, 2022, Congress provided $800,969 in additional funding to IHS for the Infrastructure Study through the Consolidated Appropriations Act, 2022. As of September 2022, the results from the Infrastructure Study have not been released by IHS and The Innova Group. On June 16, 2022, IHS requested input regarding the additional funding from 2022 and how these funds can be utilized by IHS. On June 23, 2022, UIO Leaders and NCUIH attended an Urban Confer where IHS explained that the Infrastructure Study will be completed by December 31, 2022, with results to be released in January 2023.

NCUIH’s Recommendations to IHS

NCUIH made the following recommendations regarding the Infrastructure Study:

  • Provide UIOs with the findings from the first Infrastructure Study prior to making any decisions regarding use of the additional funds
    • It is crucial that UIOs are aware of the scope, results, and usefulness of the Infrastructure Study before they make any recommendations regarding the use of the further funding.
    • Given the timeline presented during the Urban Confer, there should be an 8-month window in which UIOs and IHS will be able to review the Infrastructure Study results following their release in January 2023 and decide as to the best use of the additional funding
  • OUIHP should provide a timeline of the Planning Process to UIOs
    • NCUIH requested a timeline be released to UIOs delineating when the initial Infrastructure Study will be released, the contracting process necessary to use the additional funding, and the deadline for the obligation of the additional funding.
    • The requested timeline will provide clarity to UIOs. With a clearer picture in mind, the planning process and use of the additional FY22 funds for the Infrastructure Study becomes more cooperative between UIOs and IHS.
  • IHS should host an additional Urban Confer after releasing the results of the Infrastructure Study.
    • NCUIH notes that informed feedback from UIOs creates a scenario where the additional funding can be best used to support the needs of UIOs.

NCUIH continues to advocate for transparency in the process of the Infrastructure Study and greater support to address the critical infrastructure needs at UIOs. NCUIH will continue to keep UIOs informed as more information is made available from IHS.

 

 

NCUIH Submits Comments to the Department of Veterans Affairs on a New Medical Residency Pilot Program

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On July 5, NCUIH submitted comments to the U.S. Department of Veterans Affairs (VA) on the Pilot Program on Graduate Medical Education and Residency (PPGMER). Congress authorized this program under Section 403 of the VA Mission Act of 2018, which sought to provide high-quality, culturally sensitive healthcare options by expanding veterans’ access to medical care and enabling veterans to seek quality healthcare outside of VA facilities. Placement of residents in UIOs through this program is essential to building a highly trained, culturally competent medical workforce to provide equitable access to high-quality healthcare for the estimated 67% of AI/AN veterans living in urban areas.

Recommendations

NCUIH provided the following recommendations for implementation of the PPGMER that supports AI/AN veterans:

  • Add UIOs as covered facilities consistent with legislative intent and flexibility provided under Section 403 of the Mission Act.

Listing UIOs as covered facilities will help VA ensure that it carries out Congress’ intent to expand veterans’ access to medical care and enable veterans to seek quality health care outside of VA. NCUIH estimates that 67 percent of the veteran population identifying as AI/AN alone lives in metropolitan areas. UIOs are particularly well placed to help VA meet the needs of AI/AN veterans living in urban areas.  UIOs fill the gap to ensure all AI/AN veterans have access to critical healthcare options, particularly amid a global pandemic that has disproportionately impacted AI/AN communities.

  • Consider a consortium for residence focusing on the Indian Health Service, Tribal, and Urban (I/T/U) system.

NCUIH recommends extending eligibility criteria for covered facilities to consortia of IHS, Tribal, and UIO (I/T/U) healthcare facilities under Section 403(a)(2)(F) of the Mission Act. The VA, IHS, and Tribal partners have achieved significant success through joint workgroups on increasing care coordination, health care services, and reimbursement for training and cultural competency for eligible Veterans. While those partnerships are successful, many AI/AN veterans are still not being served as noted in a 2020 VA Report, which found that 7.4 percent of AI/AN veterans lack health insurance compared to 2.9 percent of non-AI/AN veterans. Residency consortia represent a unique opportunity to train physicians on the intricacies of the Indian healthcare system and the provision of culturally sensitive health services across the I/T/U system.

  • Establish two additional consideration factors for placement of residents that consider the provision of culturally sensitive healthcare and ongoing staffing shortages in facilities that provide healthcare to underserved veteran demographics, including AI/ANs.

UIOs fill an essential gap by providing culturally sensitive and community-focused care options to AI/AN veterans with shorter wait and travel times. Even in cities that have greater numbers of providers serving AI/AN veterans, there is no guarantee that these providers will be culturally competent. Despite their essential role in the healthcare of AI/AN veterans across the nation, UIOs have long faced understaffing issues that reduce the number of patients each facility can serve.  UIOs have frequently expressed their inability to retain or hire staff due to their inability to pay competitive salaries. Medical residents at UIOs have the potential to dramatically increase healthcare options for AI/AN veterans and their families.

  • Utilize the VA Tribal Advisory Committee in the review process for regulations that support the VA PPGMER prior to publication.

The Advisory Committee provides guidance on all matters related to tribes, tribal organizations and AI/AN veterans. Inclusion of the Committee in regulatory review processes for the PPGMER would demonstrate the VA’s commitment to the United States’ national policy “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.”

We will continue to monitor ongoing implementation of the VA PPGMER and provide updates on how the program impacts urban Indian communities.

Link to resource.

NCUIH Submits Comments to the Administration, the Department of Health and Human Services, and the US Department of Agriculture on the National Strategy for Hunger, Nutrition, and Health

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On July 15, 2022, the National Council of Urban Indian Health (NCUIH) submitted comments and recommendations to the Administration, the Department of Health and Human Services (HHS), and the US Department of Agriculture (USDA) on hunger, nutrition, and health. This comment was in response to correspondence from the Administration, HHS, and USDA dated May 27, 2022, which sought input on the development and implementation of the national strategy on hunger, nutrition, and health. NCUIH recommended that the Administration, HHS, and USDA support UIO programs to promote food security, nutrition, and exercise, include urban AI/AN populations in future research efforts and government projects, and establish consistent Urban Confers regarding nutrition, hunger, and health.

Background

AI/AN people face high levels of food insecurity and diseases related to lack of access to healthy foods, including diabetes and heart disease. Furthermore, AI/AN people who live in urban settings are especially likely to experience food insecurity. According to a 2017 report published in the Journal of Hunger & Environmental Nutrition, “[u]rban AI/ANs were more likely to experience food insecurity than rural AI/ANs.” The high rates of food insecurity in urban AI/AN communities are likely a result of “AI/ANs living on reservations… [having] access to tribally provided food and health care resource services that may not be accessible to AI/ANs living in urban areas.”[1]

NCUIH’s Actions

As a result of the high rates of food insecurity in urban AI/AN communities, and in effort to highlight the programs already in place at UIOs that address hunger, nutrition, and physical exercise, NCUIH made the following recommendations to the Administration, HHS and USDA:

  • NCUIH recommended that the Administration, HHS, and USDA support UIO programs to promote food security, nutrition, and exercise.
    • Many UIOs operate programs to improve food security and nutrition, such as: food banks, meal services, community gardens, cultural cooking and nutrition classes, community workout groups, facilities, and events, and counseling and classes about diabetes prevention and care. Through their offerings, UIOs incorporate cultural knowledge and traditional practices, address other social needs, and strengthen community bonds.
    • Recognizing that UIOs face chronic underfunding which limits them from expanding their offerings, NCUIH urged the Administration, HHS, and USDA to support the maintenance and expansion of UIO programs related to hunger and nutrition.
  • NCUIH requested that the Administration, HHS, and USDA support further research efforts and include urban AI/AN populations in future framing documents and government projects.
    • The inclusion of data about urban AI/AN populations in future research projects about food security and nutrition will contribute to a more comprehensive and reflective understanding of AI/AN experiences and needs.
    • Any and all efforts to include UIOs and urban populations in government research projects should be complementary to the inclusion of Tribal governments and should not supplant or otherwise alter Tribal representation. Research efforts should also respect tribal sovereignty.
  • NCUIH requested that HHS and USDA establish consistent Urban Confers with UIOs regarding nutrition, hunger, and health.
      • Urban Confers are not only integral to addressing the care needs of urban AI/AN persons and fulfilling the government’s trust responsibility, but also sound public policy.
    • Meeting regularly with UIO through Urban Confers will help HHS and the USDA ensure that AI/ANs in urban areas are able to voice their needs and priorities to both agencies.
    • Urban Confer policies or inclusion of UIOs in UIO-specific consultations do not supplant or otherwise alter Tribal Consultation and the government-to-government relationship between Tribes and federal agencies.


NCUIH will continue to closely follow the Administration’s development and implementation of the national strategy on hunger, nutrition, and health. NCUIH will also continue to advocate for the resources needed to reduce health disparities for AI/ANs, regardless of where they live.

[1] Id. at 5-6. See also Castor M.L., Smyser M.S., Taualii M.M., et al., A nationwide population-based study identifying health disparities between American Indians/Alaska Natives and the general populations living in select urban counties. 96 Am. J. Public Health. 1478-84 (2006).

NCUIH Submits Comments to IHS on Resource and Patient Management System Replacement and Health Information Technology Modernization Focus Groups

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On June 3, 2022, the National Council of Urban Indian Health (NCUIH) submitted comments and recommendations to the Indian Health Service (IHS) about Health Information Technology (HIT) Modernization Governance regarding the replacement of the Resource and Patient Management System (RPMS). These comments responded to the joint Tribal Consultation and Urban Confer on May 3, 2022 and request for comments. NCUIH thanked the IHS for hosting the joint Tribal Consultation and Urban Confer and for planning two additional Tribal Consultation and Urban Confer sessions in 2022 to address HIT Modernization. Furthermore, NCUIH recommended that IHS ensure HIT Modernization focus groups are representative of the entire IHS/Tribal/Urban Indian Organization (I/T/U) system, identify specific statutes and/or regulations that prevent convening the focus groups before IHS purchases the new Resource and Patient Management System (RPMS), and prioritize interoperability in the RPMS replacement system.

Background

HIT Modernization for the I/T/U system is long overdue. Although HIT is necessary to provide critical services and benefits to American Indians/Alaska Natives (AI/AN) patients, IHS has historically faced challenges in managing clinical patient and administrative data through the RPMS. Initially developed specifically for the IHS, years of underfunding and a resulting failure to keep pace with technological innovation have left the RPMS impractical by current HIT standards. RPMS has been in use for nearly 40 years and has developed significant issues and deficiencies during this time, especially in recent years as HIT systems have rapidly advanced in sophistication and usefulness. As the Department of Health and Human Services (HHS) Office of the Chief Technology Officer (OCTO) and IHS found in the 2019 Legacy Assessment, systemic challenges with RPMS “across all of the IHS ecosystem currently prevent providers, facilities and the organization from leveraging technology effectively.” Because HIT is so critical to modern provision of healthcare services, this in turn makes it difficult for AI/AN healthcare providers to provide continuous, consistent care to the already marginalized AI/AN community. Accordingly, NCUIH appreciates that IHS has chosen to fully replace RPMS. Appropriate implementation of HIT Modernization will be a long-term project requiring consistent communication and collaboration between IHS and the entire I/T/U system.

NCUIH’s Requests to HHS

Accordingly, NCUIH makes the following specific comments, requests, and recommendations to IHS:

  • IHS must ensure that HIT Modernization focus groups are representative of the entire I/T/U system.
    • Inclusion of urban Indian organizations (UIOs) in the HIT Modernization process is consistent with, and required by, the federal government’s trust responsibility and the Indian Health Care Improvement Act (IHCIA). Furthermore, it is sound public policy. The UIO experience with RPMS and their needs from the modernization process must be accounted for, because they will inherently differ from the rest of the I/T/U system.
    • NCUIH urges the IHS IT office to proactively reach out to individual UIOs and NCUIH for recommendations on persons willing and able to serve as UIO representatives on the HIT Modernization focus groups. IHS Headquarters should also use Area Offices to reach out to UIOs, as they will have pre-existing local relationships with relevant UIO IT staff.
    • NCUIH offers its assistance if needed to facilitate communication with UIOs relating to the HIT Modernization focus groups or HIT modernization.
  • NCIUH requests that IHS identify the specific provisions of the Federal Acquisition Regulation, as well as any other relevant statutes and/or regulations, which it believes prevent convening the HIT Modernization focus groups at this time.
    • Based on the May 3 Tribal Consultation and Urban Confer, NCUIH understands that IHS identified legal concerns with convening focus groups prior to purchasing a RPMS replacement system and is seeking to minimize the risk of bid protests.
    • NCIUH asks that IHS identify relevant statutes and/or regulations which it believes prevent convening the focus groups at this time, so that Tribes, UIOs, and relevant national organizations may understand IHS’ concerns and provide pertinent feedback.
    • In addition, NCUIH requests an explanation from IHS on how it will utilize the focus groups if a RPMS replacement system is purchased prior to their convening.
  • IHS must prioritize interoperability in the RPMS replacement system.
    • Advancing interoperability is a key component of the 2020-2025 Federal Health IT Strategic Plan and is critical for creating a longitudinal health record that can be used to provide and improve care to AI/ANs.
    • NCUIH and UIOs are concerned that purchasing a RPMS replacement system without utilizing the interoperability focus group runs the risk of recreating RPMS’ existing interoperability problems.
    • If IHS insists on purchasing a RPMS replacement system prior to convening the interoperability focus group, it must use all data gathering tools at its disposal, including surveying I/T/U providers, hosting further Tribal Consultations and Urban Confers, internal technical analysis, and more, to ensure that the RPMS replacement system will prove to be a comprehensive solution for all I/T/U facilities.

NCUIH looks forward to the upcoming listening sessions and is confident that UIOs will be valuable subject matter experts in the HIT Modernization focus groups.