Letter to IHS in re: Comments on Headquarters Realignment

Submitted via: consultation@ihs.gov; urbanconfer@ihs.gov

November 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 Headquarters Realignment

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 October 5, 2016, requesting Urban Confer on a draft realignment of the IHS Headquarters Office.

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 generally believes that there are many great changes in the structure that are common sense, however, we provide the following comments for improvement. We appreciate your expedited work to ensure that our people are cared for, and we offer you these comments in the same spirit.

I. Regulatory Affairs

Regulations and legislation being in the same department can often lead to more synergy and better results. We believe that the regulation duties would be more effective in the Legislative Affairs department. We also ask that activities that they review and coordinate with other agencies prior to and during the promulgation process to develop/finalize rules that advance, and do not create barriers to Indian Health operations.

II. Retain the Intergovernmental Affairs (IA) Group in the Office of the Director.

As there is a government-to-government trust relationship with Tribes as well as a fiduciary relationship with Tribal members, the Office of Intergovernmental Affairs should be in the Office of the Director to be in touch with the needs of the people and the Tribes. There is also a description missing from the functional statement as well as the office of Telemedicine, which makes it impossible to analyze its function.

III. Revenue Generation Office

It is widely known that IHS is severely underfunded. While the limited funds is mostly due to lack of congressional budgeting, it is also caused by incorrect billing and underutilization of resources. We recommend not only training to capture better billing practices, but also provide revenue enhancing resources.

IV. 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 consultations and confer sessions. Providing stakeholders with the feedback submitted to IHS and routine updates regarding changes would be vital to creating a more positive relationship.


NCUIH believes that the presentation IHS gave at the Tribal Self-Governance meeting in October was very helpful in understanding the thought process behind the changes, and recommends providing a similar presentation nationally, with opportunity for Tribes and Tribal members to comment.

We hope that you include the above recommendations and look forward to your response to the joint request for an extended comment period made on October 17, 2016. 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