Dear USET/USET SPF Family,
USET
submitted comments
to Indian Health Service Nashville Area Office yesterday in response to the
November 15, 2023, Dear
Tribal Leader Letter
from the Indian Health Service (IHS) Nashville Area Office (NAO) initiating
Tribal consultation regarding the Nashville
Area Tribal Shares Tables. These tables are a vital part of understanding the
contractable, compactable, non-divisible and residual shares at the Area and
Headquarter levels for Tribal Nations and are valuable when staffing turnovers
occur at both the federal and Tribal levels. While we understand that the
format and included components are different than the historical tribal shares
tables due to the change from the non-recurring re-calculation to recurring
calculations, we believe this is a great first step toward breaking out by budget
category.
General
Recommendations
1)
USET recommends including program formulas as a note within each table or
within a footnote for ease in cross checking amounts.
2)
USET recommends funding totals be made available within the Tables for cross
reference to compare to prior years and to verify numbers.
3)
USET recommends that base level Indian Health Care Improvement Funds (IHCIF) be
distributed to Tribal Nations as recurring, which is consistent with the intent
of congress. Can the Area provide Tribal Nations with the justification for why
the IHCIF
funds aren’t considered recurring? And if they can be made recurring, including
in these Tables for transparency.
4)
USET recommends Office of Environmental Health and Engineering (OEHE) PFSA’s be
provided within these Tables for ease in cross referencing. Per the virtual
session presentations, the OEHE PFSA’s are not reflected in this Table and are
reflected in a separate 4F Table.
5)
According to US code title 25 subsection 450F, regarding self-determination
contracts, Tribes can assume and contract or compact for all or portions
thereof a PFSA. USET strongly supports the Tribal Nation recommendations to
incorporate department level Tribal Share tables for the Tribal Nations that do
not take shares yet. This would assist Tribal Nations in understanding all
shares available for contracting and compacting at any given time.
6)
USET is aware that newly recognized Tribal Nations come with program funds,
Tribal shares and residual at all levels which is all calculated differently
from the methodology used for the rest of the Nashville Area Tribes but
eventually the New Tribe allocations evolve to the Nashville Area Methodology.
When does the New Tribes Fund transition to the Nashville Area methodology so
that New Tribal Nations find value in these Tables when considering PFSA
assumption.
Should
you have questions please feel free to reach out to Tihtiyas (Dee) Sabattus,
USET Deputy Director, at tsabattus@usetinc.org
or Onawa Miller, USET THPS Director, at omiller@usetinc.org.
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