Dear USET/USET SPF Family,
On June 17, 2022, the Indian Health Service (IHS) issued a Dear Tribal Leader Letter initiating Tribal consultation on how to evaluate health care facilities construction demonstration project proposals. As part of the Patient Protection and Affordable Care Act, the Indian Health Care Improvement Act (IHCIA) contains new provisions on health care facility construction demonstration projects. This authority affords an opportunity for the IHS to test alternative models of care through unique funding arrangements with Tribal Nations and organizations.
The IHCIA at Title 25 USC §1637(a)(1), “Indian Health Care Delivery Demonstration Projects,” encourages the IHS to establish demonstration projects to test alternative means of delivering health care or to use alternative or innovative methods or models of delivering health care services.
The following information was provided in the DTLL to facilitate conversation in the upcoming consultation:
1. The Fiscal Year (FY) 2023 President’s Budget proposes $10 million for mid-sized ambulatory demonstration projects. How should the IHS define mid-sized?
2. The IHCIA provides a number of terms to evaluate demonstration projects. The IHS is proposing the following definitions of these terms. Please comment on how the IHS proposes to define these terms or suggest how the terms should be defined. To review the language of the demonstration project authority in the IHCIA follow this link:
- Alternative or Innovative Methods (Title 25 USC §1637(a)(1)(B)). The IHS proposes defining this to mean alternative or innovative methods or models of delivering health care services; and/or delivering health care in a location other than a health facility, for example, storefront, community center, or partnering with another health care provider in an IHS facility.
- Alternative Means (Title 25 USC §1637(a)(1)(A)). The IHS proposes defining this to mean using an authority that has not been developed by the IHS, for example, Dialysis, Long-Term Care, Inpatient Mental Health, or Special Referral Centers.
- Significant number of Indians (Title 25 USC §1637(c)(2)(A)(ii)). How many users should the IHS consider to be a “significant number of Indians?”
- Improve access (Title 25 USC §1637(c)(3)(A)). The IHS proposes defining this to mean providing a 25 percent increase in the number of IHS-eligible users, or a 10 percent increase in workload.
- Increased efficiency (Title 25 USC §1637(c)(2)(A)(i)). How would Tribal Nations and organizations define “objective measurements?
3. Demonstration projects could potentially include both service delivery projects and construction projects. Should the IHS limit solicitations to construction projects?
4. Should the IHS limit demonstration projects solely to the five new authorities: Dialysis; Long-Term Care clinical; Long-Term Care non-clinical; Inpatient Mental Health; and Special Referral Centers, or should the IHS consider any “alternative or innovative” project?
5. What relationship should the facilities have with potential partners (such as state, local, Tribal, and private health care agencies)?
Details regarding the date and time of a virtual consultation are soon to come.
IHS will be accepting written comments on this consultation until Friday, August 5, 2022. Comments should be submitted to consultation@ihs.gov, with SUBJECT LINE: Demonstration Authority Tribal Consultation.
For more information, please contact Liz Malerba, USET SPF Director of Policy and Legislative Affairs, at lmalerba@usetinc.org.
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