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CHAP TAG Submits Formal Recommendations to IHS

drawing of a room with groups of people

Image: During the Tribal caucus, this visual representation of the caucus's discussion was created and presented to Director Tso. The image depicts the main topics of discussion and how they fit into the greater conversation that led to the recommendations the CHAP TAG presented to IHS.

On March 26 & 27, 2024, the Community Health Aide Program Tribal Advisory Group (CHAP TAG) met to discuss updates on the implementation of the national CHAP to the contiguous 48 states. The CHAP TAG’s role is to provide input and feedback to the Indian Health Service (IHS) on the program’s design and implementation to serve Tribal communities.

What is the CHAP?

Currently, CHAP is a multidisciplinary system of mid-level behavioral, community, and dental health professionals working alongside licensed providers to offer patients increased access to quality care in rural Alaska communities. In 2016, IHS consulted with Tribes on expanding the program, and in 2018, formed the CHAP TAG to provide subject matter expertise, program information, innovative solutions, and advice to the IHS to establish a National CHAP.

CHAP TAG Shares Recommendations to Director Tso

Tribal representatives and IHS officials agreed to adjust the TAG Meeting Agenda to allow Tribal representatives to caucus for the first day and a portion of the second day of the meeting to develop a set of recommendations for CHAP nationalization.

In communicating their recommendations to the IHS, Tribal representatives made it clear from the outset that Tribes drive CHAP – as they best understand their communities’ needs, and they can offer solutions that are derived from the ground up. Tribal leaders linked IHS’s role to the inherent trust responsibility the federal government owes Tribes. Further defined, this responsibility, as it relates to CHAP, should be grounded in the intent, on the part of IHS, to remove barriers to CHAP expansion. Tribal representatives asked IHS to vigorously support expansion by advocating to Congress for adequate appropriations from Congress for CHAP. It was shared with IHS that it can best advocate for adequate appropriations by including the National Tribal Budget Formulation Workgroup’s CHAP Expansion funding request in the President’s budget recommendation. Further, IHS can support CHAP expansion by having an Advisory Committee modeled on the Tribal Self Governance Advisory Committee and protecting CHAP from dilution from outside entities by setting requirements for scope of practice and training and supervision requirements.

Tribal representatives articulated eight recommendations that they offered IHS Director Tso during the second day of the CHAP TAG. They are:

  1. Establish IHS as CHAP Trustee.
  2. Rewrite Circular 20-06 to support Tribal Self Governance and Self Determination.
  3. IHS to develop and maintain baseline scope, training, and supervision.
  4. Untether Portland Area CHAP certification board from the Alaksa CHAP certification board.
  5. Recognition of Billings Area CHAP certification board.
  6. Inclusion of CHAP in Annual Funding Agreements at Tribes’ request.
  7. Implementation of CHAP for Direct Services Tribes (2027).
  8. CHAP providers available to all Indian health programs (2027).

Dir. Tso was receptive to the recommendations and the timeline the TAG proposed. Considering the TAG’s recommendations, Dir. Tso requested that the TAG and IHS author a joint letter that memorializes the recommendations and describes the timeline for their implementation. Also, the letter would be something that Tribes could take to their State Medicaid offices as a means of showing that CHAP has the support of the highest parts of IHS.

Further discussion between Tribal leaders and Dir. Tso focused on how to better optimize the program for the contiguous 48 states and how to ensure Tribes are the ones driving CHAP. Both Tribal leaders and Dir. Tso understood the need for consultation to occur during CHAP expansion, though the timeframes for those discussions did not include set dates.

Next Steps

The CHAP TAG proposed an aggressive timeline for the implementation of its recommendations. However, considering that IHS leadership could quickly change because of the election this November, Dir. Tso understood the urgency the timeline creates. The TAG proposed the following timeline:

  1. As soon as possible – Share TSGAC Protocol with IHS CHAP staff and for IHS leadership to work with IHS CHAP staff on similar Protocols/Charter for CHAP TAG.
  2. April 25 – Present to CHAP TAG revised Circular 20-06 and discuss.
  3. April-June (2024) – Tribal subject matter experts and IHS staff to work on minimum scope, education and supervision requirements.
  4. May 23 – IHS CHAP staff with IHS Director to shepherd revised CHAP policy through internal process with a goal of a consultation draft to be shared with CHAP TAG on May 23.
  5. June 1 – Tribal Consultation begins.
  6. June 25-26 (2024) – Present minimum scope, education and supervision requirements for all disciplines of CHAP and CHAP TAG and CHAP TAG Charter/Protocol.
  7. Work with IHS CHAP staff on revisions to 20-06.
  8. August/September – Director Tso advocates for approval of CHAP policy during agency-wide review to final approval.

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