Tag Archive for: Comments

NCUIH Submits Comments to IHS on Health Information Technology Modernization

/0 Comments/in /by

On April 8, 2022 the National Council of Urban Indian Health (NCUIH) submitted written comments to the Indian Health Service (IHS) on Health Information Technology (HIT) Modernization. The comments were submitted in response to the IHS’s Dear Tribal Leader and Dear Urban Indian Organization letter dated February 22, 2022.  In its comments, NCUIH thanked the IHS for its commitment to a collaborative HIT modernization process while urging the IHS to advance the HIT Modernization Project to select the best HIT solutions for the for the Indian Health Service/Tribal/Urban Indian Organization (I/T/U) system at the best possible speed.   NCUIH also requested that IHS provide resources, both both human and financial, to continuously evaluate, support, and evolve I/T/U HIT systems as new technology and processes become available; ensure that the RPMS replacement system meets the technical needs of the whole I/T/U system, including UIOs; and requested that IHS continue to be transparent in this long-term, financially significant project, while also prov ensure consistent engagement with all I/T/U providers of all facility types to establish and maintain transparency with UIOs and responsiveness to concerns across the I/T/U system.

The Need for HIT Modernization

HIT “is a broad concept that encompasses an array of technologies to store, share, and analyze health information.” This includes, but is not limited to, “the use of computer hardware and software to privately and securely store, retrieve, and share patient health and medical information.”  HIT Modernization for the I/T/U system is long overdue. Although HIT is necessary to provided critical services and benefits to AI/AN patients, the IHS has historically faced challenges in managing clinical patient and administrative data through the Resource Management System (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.”

In addition,

NCUIH’s Requests to the IHS

NCUIH made the following specific comments, requests, and recommendations in response to your February 22, 2022, correspondence and March 10, 2022, Tribal Consultation and Urban Confer:

  • IHS must provide resources, both human and financial, to continuously evaluate, support, and evolve I/T/U HIT systems as new technology and processes become available
    • NCUIH requests that IHS provide sufficient funding for off-the-shelf costs of HIT modernization, including maintenance and IT support costs
    • NCUIH advises IHS that it must account for additional delays and costs in its support for I/T/U HIT modernization
    • NCUIH recommends that IHS dedicate a full-time staff person to support UIOs in the Office of IT (OIT) to improve training, support, and personnel in replacing the current RPMS, implementing new systems, and continuing support for UIOs utilizing any other commercial off-the-shelf (COTS) systems
    • NCUIH urges IHS to work with Congress to address budgetary constraints and fiscal law restrictions blocking reimbursement of HIT modernization costs to Tribes and UIOs
  • IHS must ensure that the RPMS replacement system meets the technical needs of the whole I/T/U system, including UIOs
    • NCUIH recommends that the RPMS replacement system provides full support for data exchange and interoperability both within and external to the I/T/U system
    • NCUIH advises IHS that the RPMS replacement system must support data reporting required for regulatory compliance
    • NCUIH requests that the RPMS replacement system provide a user-friendly experience that decreases the burden on I/T/U staff to access, make updates, and work in the new EHR system
  • IHS must ensure consistent engagement with all I/T/U providers of all facility types to establish and maintain transparency with UIOs and responsiveness to concerns across the I/T/U system

NCUIH will continue to closely follow IHS’s progress and policies with HIT Modernization and looks forward to participating in the additional Tribal Consultation and Urban Confer session later in the year.

NCUIH Submits Comments to VA on Tribal Representation Expansion Project

/0 Comments/in /by

On March 30, 2022, the National Council of Urban Indian Health (NCUIH) submitted written comments to the Department of Veteran Affairs (VA) on the Tribal Representation Expansion Project (T.REP). The comments were submitted in response to VA’s notice of Tribal consultation and request for comment. In the comments, NCUIH requested that VA include urban Indian organizations (UIOs) in T. REP or establish a similar program for UIOs.  In addition, NCUIH recommended that VA consult with UIOs to gain a better understanding of the needs of American Indian/Alaska Native (AI/AN) veterans living in urban areas.

The Tribal Representation Expansion Project

VA’s T.REP represents VA’s most recent effort to ensure that AI/AN veterans and their families have access to appropriate representation in the preparation, presentation, and prosecution of their VA benefit claims. The aim of this program is to “ensure that Native American Veterans have access to responsible, qualified representation in the preparation, presentation, and prosecution of their benefit claims before VA.”  VA hopes to build on its work from 2017, when it revised its regulations to permit Tribal veterans’ service offices affiliated be recognized by VA as Tribal organizations in a manner similar to State organizations.

In addition to seeking information regarding the availability of representation for veterans’ claims in Tribal communities, VA is also planning to provide further options for representation.  According to VA, they plan to collaborate with Tribal governments to identify “an individual who is affiliated with their government, is of good character and reputation, and, who, after proper training on VA benefits, would be fit to be authorized by the VA General Counsel to represent on VA benefit claims.”  If a tribal government identifies such a person “[t]he General Counsel then plans to use his discretionary authority, pursuant to 38 CFR 14.630, to specially authorize such individuals to prepare, present, and prosecute VA benefit claims before VA.”

About AI/AN Veterans

AI/ANs have a proud legacy of service in the armed forces of the United States.  This includes at least 12,000 AI/AN men who served the United States in World War One, who suffered a casualty rate five times that of other American forces before this country granted universal citizenship to American Indians; 42,000 AI/ANs who served in the Vietnam War, representing 25% of the total AI/AN population at the time; and at least 33,538 AI/ANs who have served following September 11, 2001.

There are at least 140,000 living AI/AN veterans nationwide.  NCUIH estimates that 67% percent of the veteran population identifying as AI/AN alone lives in metropolitan areas.  UIOs currently serve six of the ten urban counties with the largest veteran AI/AN alone populations, including Maricopa County, Arizona; Los Angeles County, California; San Diego County, California; Bernalillo County, New Mexico; Oklahoma County, Oklahoma; and Tulsa County, Oklahoma.  AI/AN veterans regularly prefer to see UIOs over other health care providers thanks to the provision of culturally competent care (including traditional healing services), community and familial relationships, shorter wait times, and shorter distance to travel.

Unfortunately, despite a distinguished record of service, VA’s statistics show that AI/AN veterans were more likely to be unemployed, were more likely to lack health insurance, and were more likely to have a service-connected disability when compared to veterans of other races.  In addition, in Fiscal Year 2017, AI/AN veterans used Veterans Benefits Administration (VBA) benefits or services at a lower percentage than veterans of other races.  It is important to note that AI/AN veterans living in urban areas face many of the same barriers to accessing competent representation in VA claims that AI/AN veterans face on reservations.  For example, AI/AN veterans living in urban areas face significant barriers to accessing representation on VA benefit claims based on their location, they deal with the same language barriers that AI/AN veterans living in rural areas face, and they must overcome cultural barriers to representation as well.

NCUIH’s Role

NCUIH has consistently advocated for UIO inclusion with VA-led initiatives and played a critical role in getting legislation passed in 2020 which established the VA Advisory Committee on Tribal and Indian Affairs and in the subsequent nomination and selection of NCUIH President-Elect Sonya Tetnowski as a UIO representative on the Committee.  Given the large portion of the AI/AN veteran population living in urban areas and UIOs’ ability to reach AI/AN veterans, inclusion of UIOs in T.REP would help VA accomplish its goal of “ensur[ing] that Native American Veterans and their families have access to responsible, qualified representation in the preparation, presentation, and prosecution of their benefit claims before VA.”  Accordingly, NCUIH made the following specific comments, requests, and recommendations to VA in response to the notice:

  • NCUIH recommends that VA expand T. REP to provide accreditation opportunities for staff at UIOs.
    • In the alternative, NCUIH requests that VA establish a similar accreditation program for staff at UIOs.
  • NCUIH requests that VA consult with UIOs to better understand the needs of AI/AN veterans living in urban areas.
    • NCUIH recommends that VA establish an Urban Confer policy to set the necessary policies and procedures for direct and clear communication with UIOs.

NCUIH appreciates the VA for its commitment to ensuring that AI/AN veterans “have access to responsible, qualified representation in the preparation, presentation, and prosecution of their benefit claims before VA.” NCUIH will continue to monitor this program and engage with VA to support greater provision of benefits to AI/AN veterans living in urban areas.

DOJ Consultation Meeting on the Public Safety and Criminal Justice Needs of Native Americans

/0 Comments/in /by

On January 14, 2022, the U.S. Department of Justice (DOJ) Office of Tribal Justice (OTJ) issued a Dear Tribal Leader letter inviting Tribal leaders to a two-day government-to-government consultation on March 16 and 17, 2022. The purpose of this two-day consultation is to discuss “DOJ’s efforts to address the unacceptably high rate of violent crime in Native communities, including the rates of missing or murdered indigenous persons.” Deputy Attorney General Lisa Monaco directed this consultation in her November 15, 2021  memorandum establishing the DOJ’s Steering Committee to address the crisis of missing and murdered indigenous persons (MMIP). The OTJ is also welcoming written comments via email to OTJ@usdoj.gov until April 15, 2022. The meetings will be held from 3:00 p.m. – 4:30 p.m. EST on both days.

On November 15, 2021, during the White House Tribal Nations Summit, President Biden signed Executive Order 14053 (E.O.) “Improving Public Safety and Criminal Justice for Native Americans and Addressing the Crisis of Missing or Murdered Indigenous People,” which directed the Administration to work together with Tribes to “build safe and healthy Tribal communities and to support comprehensive law enforcement, prevention, intervention, and support services.”  The E.O. also recognizes that because “approximately 70 percent of American Indian and Alaska Natives live in urban areas and part of this epidemic of violence is against Native American people in urban areas, we must continue that work on Tribal lands but also build on existing strategies to identify solutions directed toward the particular needs of urban Native Americans.”  To that end, in her November 15, 2021 memorandum, Deputy Attorney General Monaco directed DOJ’s Steering Committee to seek and consider the views of stakeholders including Urban Indian Organizations.