Tribes can make their voices heard and submit comments on IHS’s (Indian Health Service’s) implementation of Becerra v San Carlos Apache. The decision states IHS must pay tribes Contract Support Costs on expenditures tribes make on health care expenses – which will mean additional funding of up to $1 billion annually for Indian Country. However, IHS has introduced two avenues to potentially reduce this new funding – for CSCs on services to non-beneficiaries, and offsets for duplication of CSC payments in 3rd party revenues.
IHS will hold a consultation on Oct. 9th from 1 – 5 p.m. Eastern Time and written comments will be accepted through October 11th. Details of the consultation meetings were sent in a Dear Tribal Leader letter last month. Registration is required to attend. The Tribal CSC Advisory Group (Co-Chaired by President Martin Harvier of the Salt River Pima-Maricopa Indian Community) has provided tribal leaders with suggested talking points in response to IHS’s consultation questions.
NAFOA encourages tribes and tribal health entities to submit a comment letter to IHS Director Tso, at consultation@ihs.gov. by the Oct. 11 deadline, opposing IHS’s positions on the areas that, if implemented by IHS, would greatly reduce the funding Tribes are entitled to. IHS has requested commenters use the subject line: CSC Methodology for Program Income.
Per the IHS Dear Tribal Leader letter: “If you have any questions on the Tribal Consultation on CSC for Program Income, or the Agency’s approach to implementation, please contact Johnnita Tsabetsaye, Director, Contract Support Costs, Office of Direct Service and Contracting Tribes, IHS, by email at johnnita.tsabetsaye@ihs.gov.”
For any other questions or concerns, please contact Nicholas Lovesee, Director of Policy, at nicholas@nafoa.org
