mmpc - National Indian Health Board

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NORTHWEST PORTLAND AREA INDIAN HEALTH BOARD Burns-Paiute Tribe Chehalis Tribe Coeur d' Alene Tribe Colville Tribe Coos, Sui slaw & Lower Umpqua Tribe Coquille Tribe Cow Creek Tribe Cowl it? Tribe Gmnd Ronde Tribe Hoh Tribe Jamestown S'Klaliam Tribe Kalispcl Tribe Klamath Tribe Kootenai Tribe Lower Elwha Tribe Lummi Tribe Makah Tribe Muekleshoot Tribe Nez Perce Tribe Nisqually Tribe Nooksack Tribe NW Band of Shoshone Tribe Port Gamble S'Klallam Tribe Puyallup Tribe QuileuteTribe Quinault Tribe Sam ish Indian Nation Sauk-Suiattlc Tribe Shoalwater Bay Tribe Shoshone-Bannock Tribe Siletz Tribe Skokomish Tribe Snoqualmie Tribe Spokane Tribe Squaxin Island Tribe Stillaguamish Tribe Suquamish Tribe Swinomish Tribe Tulalip Tribe Umatilla Tribe Upper Skagit Tribe Wann Springs Tribe Yakama Nation 2121 SW Broadway Suite 300 Portland, OR 97201 (503) 228-4185 (503)228-8182 FAX www.npaihb.org SENT VIA EMAIL: Pam.Hyde@SAMHSA.hhs.gov; blockgrants@samhsa.hhs.gov September 21,2012 Ms. Pamela S. Hyde, J.D. Administrator Substance Abuse and Mental Health Service Administration 1 Choke Cherry Rd. Rockville, MD 20857 REF: Comments - Agency Information Collection Activities: Proposed Collection; Comment Request for: Uniform Application for the Mental Health Block Grant and Substance Abuse Block Grant FY 2014-2015, Application Guidance and Instructions (OMB No. 0930-0168) Revision. Dear Ms. Hyde: The Northwest Portland Area Indian Health Board (NPAIHB) is a P.l. 93-638 Tribal organization 1 that represents forty-three federally-recognized Tribes in the states of Idaho, Oregon, and Washington. On behalf of our member Tribes, we are writing to provide comments for the Agency Information Collection Activities: Proposed Collection; Comment Request, published in the Federal Register, Vol. 77, No. 135, Friday, July 13, 2012, notices. We understand the purpose of this notice is to comment on: information from reports will have a practical utility; have accuracy of the agency's estimate of the burden of the proposed collection of information; ways to enhance the quality, utility, and clarity of the information to be collected; and ways to minimize the burden of the collection techniques or other forms of information technology. Before providing comment it is important for us to underscore our deep concern that there is no mention of Tribal governments in the entire document. We note a "casual" citation near the end of page 41434 and the reference to Native Americans on page 41435. The document overlooks the preferred reference and legislative term "American Indians and Alaska Native (AI/AN)" and we urge SAMHSA to use the preferred term in future publications. We are concerned that past comments we provided and issues discussed at the SAMHSA Tribal Advisory Committee meetings are not adequately addressed. These issues have also been raised in SAMHSA Tribal consultation sessions. J As defined in the Indian Self-Determination and Education Assistance Act. P.L. 93-638. 25 U.S.C .• Section 45O(b) a Tribal organization is a legally established governing body of any Indian tribe(s) that is controlled. sanctioned. or chartered by such Indian Tribe(s) and designated to act on their behalf.
It is unclear if this was just an oversight or a lack of understanding of the government to government requirement. The proposed application requirements will have a direct impact of the ability of SAMHSA to further its mission and services for Tribal communities. Please note the following comments from a submission dated June 6, 2011 per SAMHSA's request. Where these comment disregarded? We did not receive any feedback from the comments. These comments were directed toward the information provided in the Federal Register, Vol. 76, No. 69, Monday, April 11, 2011: In regards to States following a four-step planning process conSisting of: (1) Assessing the strengths and needs of the service system; (2) identifying the unmet service needs and critical gaps within the current system; (3) prioritize the State planning activities, and; (4) develop goals, strategies and performance indicators, there will be unintended consequences for Tribal population unless: 1. Tribes are consulted to address the strengths and needs of the population they serve. It would be impossible for a State to provide a comprehensive assessment of strengths and needs of the service system without the assistance of Tribes in their respective States. Additionally, non-Medicaid encounter data from Tribal systems is often reported directly to the Federal government, (via Indian Health Service), and is not included in State databases. Furthermore, Tribal populations often do not access State services due to historical discrimination and mistreatment, resulting in an unrealized "silent need". 2. The unmet service needs are difficult to identify. States have various methods for gathering data, as do the 565 Federally Recognized Tribes. Currently, most policy for service provision is driven from encounter data. This results in a fatal flaw - no valid method to determine unmet service needs when there is no access or limited access to behavioral health services. As noted in numerous publications, including the Report on State Responses to the FY 2011 Block Grant Addendum on Health Care Reform, there is a current shortage of behavioral health professionals. This shortage is projected to amplify with the surge caused by the implementation of the Affordable Care Act, thus the intense need to determine actual levels of need. This Proposed Project needs to clearly define how population needs will be assessed for people that do not have access to behavioral health services. There should be a specific section that elaborates on a method to not only determine this for Tribal populations but all rural populations as identified by the Health Professional Shortage Areas. If this measure is not taken there will be a gross underestimate of service needs from populations that are never "counted" until they self-terminate or suffer catastrophic consequences. 3. States must be required to consult with Tribal representatives (specifically elected Tribal leaders or individuals formally appointed to represent their Tribal government) for any prioritization of State planning activities. Tribal populations will continue to be
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MEDICARE, MEDICAID, & HEALTH REFORM
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GENERAL INFORMATION TABLE OF CONTEN
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Last Updated: November 12, 2012 2.
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Ref. # 2. Task/Issue Person(s) CMS
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Ref. # II. POLICY Task/Issue Person
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Ref. # Task/Issue Person(s) 9. Stra
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IV. OUTREACH AND EDUCATION MMPC: SU
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Ref. # Task/Issue Person(s) 25. Med
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MMPC October 9, 2012 Teleconference
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To do List: -Myra will have draft b
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Internal Revenue Service Meeting No
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with a “interim/acting”. Can al
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8/7/12 DRAFT COMPANION TO ADDENDUM
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Indian Self-Determination and Educa
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Under federal law, There are privac
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1. Purpose of Addendum; Supersessio
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(1) ISDEAA, 25 USC §450 et seq.; (
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13. Medical Quality Assurance Requi
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edits on documents are due back fro
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d. CCIIO Philosophy - CCIIO is taki
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- I/T/U provider receives their all
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i. CMS rep. commented that an analy
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IHS TRIBAL SELF-GOVERNANCE ADVISORY
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Letter: Dr. Robert Petzel, Under Se
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October 17, 2012 Dr. Robert Petzel,
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A BILL To correct inconsistencies i
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California Rural Indian Health Boar
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As people have changes in employmen
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Indian eligibility determinations,
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v.7, 2012‐09‐23a ACA, (2) the s
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Indian tribe means any Indian tribe
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v.7, 2012‐09‐23a In issuing thi
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(1) to ensure the highest possible
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v.7, 2012‐09‐23a Delays in acc
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v.7, 2012‐09‐23a 1997. The prov
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v.7, 2012‐09‐23a 48 Enacted thr
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Prepared by James Crouch MPH Chair,
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Summary T he Indian Health Service
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Summary providers that were either
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Introduction Reliable determination
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Analysis Groups IHS AIAN Methods Th
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Methods group for the statistical m
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Enrollees with no Payments Methods
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Methods Table 5. Mean Medicaid and
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Page 127 and 128: defined in Sections 8 and 9 of this
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Page 133 and 134: provide Indian Tribes with a region
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premium tax credit assistance and c
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Access to this benefit is criticall
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community providers for purposes of
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November 12, 2012 Centers for Medic
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_________ American Indian or Alaska
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November 9, 2012 Page 2 We are comm
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Tribal Consultation for Health Insu
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Background Analysis of Tribal Consu
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Analysis of Tribal Consultation Pol
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D. FFE Data Analysis of Tribal Cons
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John O'Brien Director, Healthcare &
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