Letter to IHS in re: Indian Health Service Draft Quality Framework Comment

Submitted via: consultation@ihs.gov

October 3, 2016

Ms. Rebecca Spitzgo
Indian Health Service
Attention: IHS Draft Quality Framework
5600 Fishers Lane
Mail Stop: 08E86
Rockville, Maryland 20857

RE: Indian Health Service Draft Quality Framework Comment

Dear Ms, Spitzgo:

On behalf of National Council of Urban Indian Health (NCUIH), I write to submit comments in response to Principal Deputy Director Mary Smith Dear Urban Indian Organization Leader Letter dated July 20, 2016 releasing the draft IHS Quality Framework and initiating Tribal and Urban consultation. NCUIH fully supports the increasing the quality of care in the Indian Health system and would like to provide recommendations regarding the framework.

The National Council of Urban Indian Health was founded 18 years ago to represent the interests of Urban Indian Health Programs (UIHPs) before Congress and Federal agencies, and to influence policies impacting the health conditions experienced by urban American Indians and Alaska Natives (AI/AN).The National Council of Urban Indian Health is a 501(c)(3), membership-based organization devoted to support the development of quality, accessible, and culturally sensitive health care programs for AI/AN living in urban communities. NCUIH fulfills its mission by serving as a resource center providing advocacy, education, training, and leadership for urban Indian health care providers. NCUIH strives for healthy American Indians and Alaska Natives living in urban settings, which comprise over 70% of the AI/AN population, supported by quality, accessible health care centers and governed by leaders in the Indian community. NCUIH represents urban Indian Health Programs receiving grants under Title V of IHCIA and the American Indian and Alaska Natives they serve.

NCUIH praises the initiatives IHS has taken to improve the quality of healthcare AI/AN receive. Quality care is also a core value of Urban Indian Health Programs (UIHPs). We recommend that the IHS incorporate UIHPs in any initiatives or funding that furthers the mission of quality care. We ask that IHS incorporate cultural competency initiatives and accountability for cultural competency in its framework, as culture is integral to Indian Country. Also, while we appreciate the repository of policies and procedures, we ask that IHS place them online for all of the I/T/U system to easily access. Finally, while there is a recommendation to review the policy annually, this should only be done with Tribal consultation and Urban confer sessions.


NCUIH hopes that IHS, in the spirit of its partnership and shared interest in improving AI/AN access to its resources and services, will work with NCUIH and UIHPs to advance access to quality health care for all of Indian Country. We thank you for this opportunity to provide our comments and recommendations and look forward to further engagement with IHS on this framework. Please contact Francys Crevier, Policy Analyst and Congressional Relations Liaison at FCrevier@ncuih.org, if there are any additional questions or comments on the issues addressed in these comments.


Ashley Tuomi President
National Council of Urban Indian Health