The information on S. 2460 requested in your letter of March 31, 1978 follows:

Question No. 1:

Please specify by what mechanisms the Tribe could obtain a single grant for its BIA & IHS programs using only one application procedure, one accounting procedure and one evaluation report without violating the IHS accountability?

Answer No. 1:

To our knowledge, the only authority which could be used to enable
a tribe to obtain joint funding for both its Indian Health Service
and Bureau of Indian Affairs programs is the Joint Funding Simpli-
fication Act of 1974, P.L. 93-510. This act permits a wide range
of administrative arrangements aimed at enabling an applicant for
Federal assistance to better utilize and coordinate resources from a
number of programs. The Act permits such things as: uniform
provisions for financial administration, and timing of Federal pay-
ments; establishment of joint management funds for a project; single
agency administration and project supervision of a multi-agency
funded project; and the creation of joint or common application
review and processing.

The Indian tribes are covered by P.L. 93-510. The Indian Health
Service, however, has had very little experience with P.L. 93-510.
I understand that several tribes in Oklahoma are considering applying
for a joint funding grant to cover programs funded by the Indian

Health Service and the Bureau of Indian Affairs. In addition, the Salt River Tribe has been utilizing joint funding procedures for several years now--initially under OMB Circular Alll and now under P.L. 93-510. The Indian Health Service has had little direct involvement, but there is an alcoholism component to the joint funding project and this component is one of the projects being transferred from the Alcohol, Drug Abuse, and Mental Health Administration to the Indian Health Service. The Administration for Native Americans has had considerable input into the project. It is my understanding that the Department of Health, Education, and Welfare is the lead agency in the Salt River Project which is under the overall purview of the Indian committee of the Western Federal Regional Council. Though limited, there does appear to be some experience to draw upon.

Question No. 2:

Since both BIA and IHS must change its 638 regulations due to
P.L. 95-224, do you intend to work with the BIA to achieve identical
procedures and substantially the same regulations?

a.

b.

If the answer to 2 is yes, what problems might you
encounter from HEW regulations?

If the answer to 2 is no, specify practical or legal
reasons why you should not have identical procedures
and substantially the same regulations?

Answer No. 2:

The Federal Grant and Cooperative Agreement Act of 1977, P.L. 95-224, authorizes the Director of the Office of Management and Budget to issue interpretative guidelines for the implementation of this act. There are no provisions in the act itself that would require the P.L. 93-638 regulations to be revised. Until the Office of Management and Budget guidelines are issued, we cannot determine which, if any, Departmental regulations might have to be revised or to what extent they might have to be revised. Should any P.L. 93-638 regulations require substantive revision, we will strive to have both the regulations and the procedures match those of the Bureau of Indian Affairs to the greatest extent possible.

Question No. 3:

In your testimony on page 5, you mention that the problems accompanying the early stages in the implementation and administration of P.L. 93-638 have to a great extent been alleviated. Please identify the problems you are referring to, and which have been alleviated?

Answer No. 3:

The problems referred to in my opening statement involves those normal to the beginning of a new program effort. These involved such things as publishing the regulations, training staff, establishing grant and contract capability, providing information to the Indian people on the new law and defining the health delivery systems involved. In addition to establishing the machinery with which to implement the Act, there were many legal questions that had to be addressed by the HEW Office of General Counsel of HEW and this process too is proceeding smoothly.

Question No. 4:

On page 2, you speak of "Tribal specific health plans." How do such plans compare with the comprehensive Tribal plan and needs assessment as set forth in S. 2460?

Answer No. 4:

Section 701 of the Indian Health Care Improvement Act, P.L. 94-437 requires the Secretary of Health, Education and Welfare to report to Congress concerning any additional authorizations for fiscal years 1981 through 1984. In order to obtain that data necessary for this report, and as part of the implementation plan for P.L. 94-437, it was decided to offer each tribe the opportunity to develop tribal specific health plans (TSAD) It should be noted that this system includes urban specific health plans since the report required by section 701 must cover all programs authorized under P.L. 94-437.

The format for developing Tribal Specific Health Plans for FY1981 1984 includes the: (1) scope of the Plan, (2) descriptive data on the service area, (3) demographic and health data, (4) total health needs for the tribe, (5) health resources currently available, (6) unmet needs, and (7) approach and plan for overcoming the unmet health needs. The plans developed under S. 2460 may cover "any, some, or all "programs covered by S. 2460. It would therefore, be possible for an S. 2460 plan to be wider or narrower in scope than a TSHP. The S. 2460 plan could cover up to 10 years while the TSHP would intially cover only 4 years. The S. 2460 plan covers function performed by the tribe or for the tribe under the consolidated grant. The TSHP deals with the total health needs and all health resources available to meet these needs. The S. 2460 plan would be an intricate part of a grant request. TSHP is not a request for specific funding, but rather part of a system to both assess total health needs and to develop justification for budget authorizations and appropriations to meet unmet needs.

Question No. 5:

Please describe the mechanisms with which you are monitoring the delivery of a new training and technical assistance funds appropriated under the authority of P.L. 93-638 to the Tribes.

Answer No. 5:

IHS monitors the delivery of training and technical assistance funds provided under P.L. 93-638 through the (TRAIS) information system. The system has been programmed to accept quarterly reports from the Area and Program Offices, and produces a consolidated report for three types of technical assistance, five types of suppliers from whom such technical assistance is acquired, six specific IHS activities which generate and provide the technical assistance, and the costs obligated for each category during the current reporting period.

This system provides management personnel in the Headquarters an overview of what is required and provided, as well as an awareness of funds being expended and residual funding balances for future technical assistance requirements. A copy of the mandatory quarterly report is enclosed for your information. (Enclosure No. 1)

Question No. 6:

Are any P.L. 93-638 training and technical assistance monies now being used directly or indirectly for IHS salaries, travel support, employee conferences, or other overhead expenditures?

Answer No. 6:

Such funds are used to meet tribal requests for technical assistance and training and to improve IHS administration of programs that are under tribal management. These monies may provide additional IHS P.L. 93-638 capabilities for training and technical assistance operations by IHS staff.

Question No. 7:

What training and technical assistance monies under 'Category B' were allocated to the Navajo Area Office in FY78? Were they to be used in conjunction with the Navajo Tribe's health contracts? What specific activities were these funds used for? Why did the Navajo Tribe's health programs not receive any Category C funds for FY78? Which other health contracts received no Category C funds in FY78? How much Category D and E funds were allocated to the Navajo Area Office for FY78 Navajo Tribal Health contracts? What specific activities were these funds used for?

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Answer No. 7:

A.

B.

C.

D.

E.

F.

What training and technical assistance monies under Category B
were allocated to the Navajo Area Office in FY78?

In FY78, $123,000 was allocated to the Navajo Area. As of the
end of the 3rd quarter, $118,352 was unobligated and $4,647.50
has been obligated for special activities.

Were they to be used in conjunction with the Navajo Tribe's
health contracts?

Yes, the specific use of these funds are listed in the next
question.

What specific activities were these funds used for?

They are used for the items discussed in Question #6 on the
Navajo Reservation these funds were used: (1) to develop IHS
staff capabilities to meet Navajo tribal requests for technical
assistance and training, (2) to improve IHS administration of
programs that are under Navajo tribal management, (3) to provide
technical assistance (including training) to the Navajo tribe
in their preparation for program management, and (4) to provide
additional P.L. 93-638 support for program operation by IHS
staff not otherwise available.

Why did the Navajo Tribe's health programs not receive any
Category C funds for FY78.

Category C, Indirect Administrative Cost, funds were only
distributed to Areas and Programs that had unmet needs for these
type of funds and to those Area and Programs who could not fund
their unmet indirect administrative cost needs out of existing
funds. The Navajo Area was able to fund all Indirect Administrative
Costs out of its existing funds which eliminated the need to
obligate Category C funds to the Navajo Area in FY78.

Which other health contracts received no Category C funds in FY78?

The list of such contracts is displayed in Enclosure No. 2.
(See Enclosure #2).

How much Category D and E funds were allocated to the Navajo
Area Office of FY78 Navajo tribal health contracts?

In FY78 $104,000 ($93,000 and $10,900 mandatories) of Category D
funds, Personnel Support, were allocated to the Navajo Area.
There were $117,000 of Category E, Non-reoccuring, funds allocated.