mmpc - National Indian Health Board
mmpc - National Indian Health Board
mmpc - National Indian Health Board
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IHS TRIBAL SELF-GOVERNANCE ADVISORY COMMITTEE<br />
c/o Self-Governance Communication and Education<br />
5060 Pacific Highway, Suite 101, Ferndale, WA 98248<br />
Telephone (360) 380-1820 ~ Facsimile (360) 380-1981 ~ Website: www.tribalselfgov.org<br />
October 5, 2012<br />
Sent Via Fax Dr. Petzel: (202) 273-5787<br />
Sent Via Email Dr. Roubideaux: Rene.Joseph@ihs.gov<br />
Originals Sent Via USPS<br />
Dr. Robert A. Petzel, M.D. Dr. Yvette Roubideaux, M.D., M.P.H., Director<br />
Under Secretary for <strong>Health</strong> <strong>Indian</strong> <strong>Health</strong> Service<br />
Department of Veterans Affairs Department of <strong>Health</strong> and Human Services<br />
810 Vermont Avenue, NW Room 448, The Reyes Building<br />
Room 800 801 Thompson Avenue<br />
Washington, DC 20420 Rockville, MD 20852<br />
RE: Negotiation of Participating Tribal <strong>Health</strong> Program Agreements with Local<br />
VA Facilities: Need for Inclusion of Agreed Upon Payment Methodologies<br />
Dear Dr. Petzel & Dr. Roubideaux:<br />
On behalf of the Tribal Self-Governance Advisory Committee (TSGAC), we are writing to<br />
provide comments on one component of the latest set of materials released by the Department<br />
of Veterans Affairs (VA) regarding implementation of section 405(c) of the <strong>Indian</strong> <strong>Health</strong> Care<br />
Improvement Act (IHCIA). We appreciate the opportunity last week during the <strong>National</strong> <strong>Indian</strong><br />
<strong>Health</strong> <strong>Board</strong> Annual Consumer Conference in Denver, Colorado to discuss with the VA, as well<br />
as with the <strong>Indian</strong> <strong>Health</strong> Service (IHS), securing reimbursement for health care services<br />
provided to eligible veterans by the IHS, Tribes and Tribal Organizations. The sessions were<br />
helpful to the Tribal participants, and we are encouraged that the VA is moving forward with<br />
establishing agreements with Tribal health programs without restricting participation to a small<br />
number of Tribal organizations under a demonstration project. We remain concerned, though,<br />
that the <strong>National</strong> Reimbursement Agreement between the VA and IHS has not been finalized<br />
and executed.<br />
The TSGAC has previously provided comments on various aspects of implementation of IHCIA<br />
section 405(c) since the provision was enacted in March of 2010. (TSGAC letters to VA/IHS<br />
dated April 4, April 18, and May 25, 2012.) We believe the successful implementation of section<br />
405(c) will serve to: (1) improve access to health care services for our veterans by expanding<br />
access and reimbursement at IHS and Tribal facilities; and (2) strengthen and improve the care<br />
received by veterans through improved coordination of their care across VA, IHS and Tribal<br />
facilities. We wish to acknowledge the apparent inclusion by the VA (as indicated in the VA’s<br />
August 24, 2012 Dear Tribal Leader letter) of a number of items TSGAC had previously<br />
recommended, particularly the exclusion of copayments for Tribally-provided services and the<br />
inclusion of behavioral health care and long-term care services as reimbursable services.<br />
In an earlier VA document titled “VA-IHS Draft Agreement – Reimbursement for Direct <strong>Health</strong><br />
Care Services: Summary” (Summary of Reimbursement Agreement dated March 2, 2012), it<br />
stated that a number of items had been successfully negotiated between the VA and the IHS,
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