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

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 Comments to IHS on Health Information Technology Modernization

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.