Tag Archive for: DULL

IHS Outlines Strategic Goals including Rapid Disbursement of Funds, for FY 2024 Advance Appropriations Implementation

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On July 19, 2023, the Indian Health Service (IHS) sent a Dear Tribal Leader and Urban Indian Organization Leader letter providing an update on the status of implementing the Fiscal Year (FY) 2024 advance appropriations provided to the IHS. To ensure the successful implementation of advance appropriations, the IHS has identified three strategic goals. Goal 1 aims to distribute FY 2024 advance appropriations for IHS, Tribal, and Urban Indian health programs as close as possible on or after October 1, 2023. Goal 2 aims to ensure regular engagement with Tribal Leaders, Urban Indian Organization (UIO) Leaders, and Congress so that all relevant stakeholders have a clear understanding of the Agency’s progress. Goal 3 aims to demonstrate the impact of advance appropriations to demonstrate the positive impacts.

IHS Strategic Goals for Advance Appropriations

The IHS’s first goal in implementing advance appropriations is to distribute the funds as soon as possible after October 1, 2023. To date, to achieve this goal, the IHS has taken the following steps:

  • Updating existing budget execution systems and internal timelines to allow funds to be distributed as quickly as possible. The IHS has confirmed that all financial systems will support the rapid distribution of funds.
  • Ensuring apportionments, which authorize the expenditure of funds, are prepared and approved timely by the IHS for submission to the Department of Health and Human Services (HHS) and Office of Management and Budget (OMB);
  • Partnering with all IHS Headquarters and Area Office staff involved in payments to Tribal Organizations and UIOs to ensure an effective process; and
  • Upon the enactment of a full year bill, the IHS will distribute any additional funds enacted by Congress as soon as possible after the passage of the bill.

The IHS’s second goal in implementing advance appropriations is to ensure regular outreach and engagement with Tribal Leaders, UIO Leaders, and Congress, so that all relevant stakeholders have a clear understanding of the Agency’s progress. To achieve this goal, the IHS is:

  • Making useful information about advance appropriations implementation available on the IHS Web site; 􀁸 Briefing Tribal Leaders and Urban Indian Organization Leaders on implementation progress during scheduled meetings and/or engagements. Conducting listening sessions, or Tribal Consultation and Urban Confer; and
  • Providing updates to Congress on the IHS’s progress toward implementation.

The IHS’s third goal in implementing advance appropriations is to demonstrate the positive impacts of advance appropriations, including:

  • Partnering with health programs operated by the IHS, Tribes, and UIOs to identify metrics for success, including success stories. The IHS is developing a plan to engage IHS, Tribal, and Urban Indian health programs on an ongoing basis to seek your input on how advance appropriations have improved your ability to provide high-quality health care services.
  • The IHS will complete an evaluation to assess the implementation, impact, and customer service satisfaction regarding the execution of advance appropriations.

Background on IHS Advance Appropriations

In FY 2023, the IHS received the first ever advance appropriation for the FY 2024 Budget. The FY 2023 Consolidated Appropriations Act (Public Law 117-328) included a total of $5.1 billion in FY 2024 advance appropriations for the Indian Health Service, which includes funding at the same level as FY 2023 enacted for nearly all IHS programs. The full year funding level will be available for these programs on Oct. 1, 2023, regardless of whether Congress enacts a continuing resolution or full year bill. Advance appropriations provide long overdue funding stability and predictability for the IHS.

NCUIH Advocacy

After tireless advocacy from the National Council of Urban Indian Health (NCUIH) and across Indian Country, advance appropriations for IHS was included in the FY 2023 final spending bill to provide stable funding for FY 2024. The current advanced appropriation expires in FY 2025, and NCUIH is continuing its advocacy to secure funding for IHS for future years. NCUIH endorsed the bipartisan, bicameral Indian Program Advance Appropriations Act (H.R.4832/S.2424) which was reintroduced by Sen. Lujan (D-NM), Sen. Mullin (R-OK), Rep. McCollum (D-MN-04), and Rep. Cole (R-OK-04) on July 24, 2023. This bill would authorize advance appropriations for several accounts under the Bureau of Indian Affairs and Bureau of Indian Education within the Department of Interior and IHS within the Department of Health and Human Services.

For FY 2024, NCUIH has been advocating that advance appropriations be maintained for IHS until mandatory funding is achieved. On March 9, 2023, NCUIH CEO Francys Crevier (Algonquin), testified before and submitted public witness written testimony to the House Appropriations Subcommittee on Interior, Environment, and Related Agencies regarding FY 2024 funding and requested that advance appropriations for IHS be maintained. NCUIH also worked closely with Representatives Gallego and Grijalva on leading a Congressional letter to the House Committee on Appropriations for FY 2024, urging to maintain advance appropriations for IHS until such time that authorizers move IHS to mandatory spending. On April 4, 2023, a group of 12 Senators sent a letter to the Senate Interior Appropriations Committee with the same requests. Due to this advocacy, advance appropriations for IHS was maintained for FY 2025 in both the House and Senate Interior Appropriations proposed FY 2024 spending bills.

Next Steps

NCUIH continues to engage with IHS to ensure the successful implementation of advance appropriations for the whole IHS, Tribal organization, and UIO system. NCUIH encourages IHS to host an Urban Confer before October 1, 2023, to ensure UIOs are briefed on the implementation process and are prepared for fund distribution.

Health Information Technology Modernization Update: IHS requests statements of Interest from Tribes and Urban Indian Organizations

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On June 29, 2023, Indian Health Service (IHS) Director Roselyn Tso released a Dear Tribal Leader Letter and Dear Urban Indian Organization Leader Letter giving an update on the IHS Health Information Technology (HIT) Modernization by sharing an opportunity for interested Tribal and Urban Indian Organization (UIOs) sites. Specifically, Tribal and UIO sites can become directly involved in the collaborative planning for the new IHS enterprise electronic health record (EHR) solution. IHS is requesting sites that may wish to participate with the IHS on shared enterprise solution planning efforts to complete and submit the Statement of Interest form. This non-binding Statement of Interest will help the IHS understand which sites are interested in becoming part of the IHS enterprise EHR solution partnership. It asks for limited details about those organizations, such as facility size, current EHR utilization, and point(s) of contact. Interested UIOs are encouraged to complete and submit Statements of Interest by e-mail to modernization@ihs.gov and cc Policy@ncuih.org.

There is no deadline for submitting the form. The IHS IT Modernization Program Management Office will reach out to organizations that provide the Statement of Interest to learn more about their facilities, services, and staffing that may need to be supported by the new EHR system. There will also be opportunities for subject matter experts from your organizations to provide individual input in their areas of expertise regarding the configurations and workflows that the new system should provide.

If you have questions, please contact Mr. Mitchell Thornbrugh, Chief Information Officer, IHS, by telephone at (240) 620-3117, or by e-mail at mitchell.thornbrugh@ihs.gov.

Background

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 IHS, Tribal organization, and urban Indian organization (I/T/U) system is long overdue. Although HIT is necessary to provide critical services and benefits to American Indian and Alaska Native 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.”

The National Council of Urban Indian Health (NCUIH) is aware that technological tools cut across all UIO operational areas—from clinical and medical technology and telemedicine to accounting, payment system processes, marketing, and outreach. Since its foundation, NCUIH has fostered and participated in national initiatives involving technology as a medium to improve both the sustainability of the UIOs as well as the well-being of the population they serve. Likewise, NCUIH strives to ensure the technology available to collect the most accurate data from its programs.

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.

IHS Clarifies Additional $800,696 in Funding Allocated in the Consolidated Appropriations Act, 2022 Not Intended for UIO Infrastructure Study Activities

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On February 13, 2023, the Indian Health Service (IHS) sent a  Dear Urban Indian Organization Leader letter (DULL) clarifying use of funds requirements from the Fiscal Year (FY) 2022 Urban Indian Organization (UIO) Infrastructure Study as a follow-up to the virtual Urban Confer convened by the IHS on June 23, 2022. In the letter, IHS emphasized that “…the joint explanatory statement accompanying the Consolidated Appropriations Act, 2022 (CAA, 2022) does not mean Congress intends to allocate additional funding for UIO Infrastructure Activities. Instead, Congress intends to ensure that the additional funding provided remains in the Direct Operations accounts of IHS management use.” IHS notes that this aligns with UIO Confer recommendations to avoid using the funding for any additional UIO Infrastructure Study activities.

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 aims to better understand the most critical deficiencies facing UIOs. On March 15, 2022, Congress provided $800,666 in additional funding to IHS for the Infrastructure Study through the CAA, 2022. On June 16, 2022, IHS requested input from UIO leaders regarding the additional funding from the CAA, 2022 on 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 scheduled for release in January 2023. Results have not been released as of February 2023.

NCUIH’s Recommendations to IHS

On August 23, 2022, NCUIH submitted comments to IHS in response to the June 16, 2022 DULL regarding the use of funding available for the Urban Indian Infrastructure Study.  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 was an 8-month window in which UIOs and IHS will be able to review the Infrastructure Study results following their scheduled 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 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 Comments to IHS on Health Information Technology Modernization

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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.