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Medicaid Services “Received Through” an Indian Health Service/Tribal Facility: A Request for Comment

The Centers for Medicare & Medicaid Services (CMS) is updating its policy regarding the circumstances in which 100 percent federal funding would be available for services furnished to Medicaid-eligible American Indian and Alaska Native (AI/AN) individuals through facilities of the Indian Health Service (IHS) or Tribes.

On October 27, 2015, CMS issued a Request for Comment that described the policy options being considered and sought feedback from states, Tribes, and other stakeholders. Below are the comments received through the deadline of November 17, 2015.


Urban Indian Center San Francisco, CA

Urban Indian Center in Albuquerque, NM

South Dakota Health Care Solutions

Urban Indian Center in Great Falls, MT

Oneida Nation, New York

Urban Indian Center Tulsa, OK

Urban Indian Center San Diego, CA

Urban Indian Center Denver, CO

AI/AN Beneficiary letters that utilize Urban Indian Center in Denver, CO

Individual letter from Jim Crouch, MPH

Native Directions – Urban Indian Center, Manteca, CA




Maniilaq Association (tribal) (AK)

Great Plains Tribal Health Board


Tribal Self Governance Advisory Committee (TSGAC)

SE Michigan Urban

University of California, San Francisco (stakeholder)

Sisseton-Wahpeton Oyate of the Lake Traverse Reservation (tribal)

American Academy of Pediatrics (stakeholder)

Center on Budget and Policy Priorities (stakeholder)


SD Urban

Sacramento Urban

Salt Lake City Urban

Wichita Urban



Los Angeles Urban

National Congress of American Indians

Oglala Sioux Tribe (SD) (tribal)

Cook Inlet Tribal Council, Inc

Helena Indian Alliance – Helena MT Urban

National Association of Medicaid Directors

Sac and Fox Nation (OK) (Tribal)

Cheyenne River Sioux Tribe (SD) (tribal)

Molina Healthcare Inc. (stakeholder)

Milwaukee Urban

Rosebud Sioux Tribe (SD)



Pueblo de Cochiti (tribal)

Chickasaw Nation (tribal)


Nebraska Urban Indian Health Coalition, Inc., - Omaha Urban

Fond du Lac Band of Lake Superior Chippewa (WI) (tribal)


America’s Health Insurance Plans (stakeholder)

Georgetown University McCourt School of Public Policy



United South and Eastern Tribes (USET) (Tribal)

Native Americans for Community Action

Native Americans for Community Action

Indian Health Center of Santa Clara Valley

New Mexico


Navajo Nation

Fresno Urban

Inter Tribal Association of Arizona (ITAA)

National Council of Urban Indian Health (NCUIH)

Chugachmiut (AK) (Tribal)

Ketchikan Indian Community (AK) (Tribal)

Southcentral Foundation (AK) (Tribal)

Alaska Native Tribal Health Consortium (ANTHC)

Alaska State Hospital and Nursing Home Association (stakeholder)


Alaska Native Health Board (ANHB)

Native Health (Urban)

Kenaitze Indian Tribe

Native American Rehabilitation Assoc. of the North West

United Indian Health Services, Inc.

Menominee Indian Tribe of Wisconsin

Cheyenne & Arapaho Tribes

In addition to receiving individual letters, CMS received several emails providing feedback on our proposed policy change. In order to make these emails publicly available, we have inputted the contents of the received emails into a chart. Comments submitted by email.