Comments

During the year, USET SPF leadership attends consultations, listening sessions, commission meetings, and various committees to advocate legislation on various issues, subjects, and initiatives.  USET SPF also will comment on notices of proposed rulemaking, legislation, or court cases.  Click on the links below for specific comments you would like to view from USET SPF.

Topic
Title
HEALTH USET SPF Comments to Center for Medicare and Medicaid Services Virginia Work Requirements 1115 Demonstration Waiver 1.4.2019
SUMMARY:In our comments we oppose mandatory Medicaid work and community engagement requirements that do not provide an exemption for American Indians and Alaska Natives (AI/ANs), and express our concern that the Demonstration Application does not clearly exempt AI/ANs from new premiums and cost-sharing as required by the Social Security Act. We further stated changes or improvements to the Medicaid program must move forward in a manner that respects Tribal sovereignty and upholds federal treaty and trust responsibilities. Conditioning access to Medicaid on state imposed work requirements is a violation of the federal trust obligation. We continue to oppose, in the strongest possible terms, any action taken by the federal government that fails to recognize this sacred duty, including the approval of the Extension Application, or any 1115 waiver, that does not contain an exemption for AI/AN from work requirements. We urge CMS to retract its deeply flawed legal interpretation and work with Tribal Nations to preserve AI/AN access to Medicaid. We also urge CMS to ensure that existing statutory AI/AN protections from premiums and cost-sharing are reflected in the waiver.