Letter to IHS in re: Comments on Office of Urban Indian Health Strategic Plan

Submitted via: urbanconfer@ihs.gov

December 4, 2016

Principal Deputy Director Mary Smith
Indian Health Service
Attention: IHS Draft Quality Framework
5600 Fishers Lane
Mail Stop: 08E86
Rockville, Maryland 20857

RE: Comments on Office of Urban Indian Health Strategic Plan

Dear Principal Deputy Director Smith:

On behalf of National Council of Urban Indian Health (NCUIH), this letter is in response to your Dear Urban Indian Organization Leader Letter dated November 23, 2016, requesting an Urban Confer and comments on a draft OUIHP strategy plan.

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 American Indians and Alaska Natives (AI/AN) living in urban settings. 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 genuinely appreciates OUIHP establishing a strategic plan and prioritizing American Indians and Alaska Natives that live in urban settings. We have observed that IHS is listening: previous conversations with NCUIH on how to better serve UIOs have been incorporated into this plan, with recommendations such as FMAP, working with other agencies to serve UIOs and providing technical assistance for VA reimbursements, to list a few. We appreciate your work to ensure that our people are cared for, and we offer you these comments in the same spirit. We have also attached a redline edit of the strategic plan for your convenience.

I. Confer

While we understand that IHS is under a Congressional deadline of December 18, 2016 to finalize this strategic plan, IHS had a year to conduct this strategic plan and did not start for more than six months. Releasing this plan on November 23 for comment with a quick turn-around of December 5, which is less than two weeks and over a holiday break, does not allow for a true assessment and analysis of the proposed plan. NCUIH humbly requests that future issues that greatly impact UIOs allow for multiple confer sessions and a more reasonable amount of time, no less than 30 days. This will allow for a greater dialogue and a full analysis of any opportunities or setbacks presented.

II. Transparency in Progress

NCUIH believes that in order for IHS to improve their relationship with Tribes and Tribal members, IHS should be open and transparent about all confer sessions, administration changes, etc. A few examples would be addressing UIHPs/UIOs regarding the eligibility change in the cooperative agreement, administration changes in the OUIHP director, etc. Having confer sessions before the change in the cooperative agreement, or immediately after the vacancy of the OUIHP director would allow for greater transparency and a better working relationship, as we are all interested stakeholders that are directly affected by these changes.

We recommend hosting a confer session after the comments have been submitted and implemented into the plan with time to further review the changes and make any final comments before the December 18th deadline.

III. Urban Indian v. American Indian

While the term “Urban Indian” has a definition in various Indian Health Service laws and policies, it generally an unhelpful term that makes people feel as though an “Urban Indian” is somehow different than an “American Indian,” when in fact, it is just an American Indian that lives or even just receives health services in an urban setting.
Moving towards a transition of language may improve advocacy outcomes, and should be considered.


NCUIH believes that the OUIHP strategy plan is an excellent starting point in representing and fulfilling the needs of UIOs. We also hope you provide further clarification and support regarding NIAAA programs, their status and timeline. We hope that you include the above recommendations and redline edits. We look forward to working with you to ensure this plan exceeds expectations. 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
National Council of Urban Indian Health