Thursday, October 10, 2013

Commentary on the NMHIX and its (non) involvement with NM tribes

Good Evening Everyone,
I wrote this commentary paper for the Legislative Health and Human Services Committee panel on the NM Health Insurance Exchange that was suppose to take place on Oct 4th in Hobbs NM.  Unfortunately this panel was cancelled so I have decided post this commentary here instead.  When I started to write this commentary the first draft was very inclusive and was around ten pages long.  I condensed it to two for the legislature and this is the result.  I will post the ten page version when I complete it.
 
 
 
Comments for the Legislative Health and Human Services

NM Health Insurance Exchange and Native Americans

I’d like to thank the Committee chair for giving me the opportunity to provide commentary on this important issue.  My name is Erik Lujan, I am a consumer advocate for the New Mexico Indian council on Aging, and for the last four years I have been following and participating in Health care reform and PPACA Implementation here in NM. 

 For the purpose of this commentary I would point out that in NM we have the State Tribal consultation collaboration and Communication Act that is the basis for how State agencies interact with the many Tribes, Nations and Pueblos. Included in the Act are the requirement for each state agency to develop a tribal consultation policy, hire a Native American Liaison. The Act also requires that State Agencies must consult tribal leaders when the agency is making a change in funding that will affect Native American communities, and individuals. The Act also elevated the Indian Affairs Department to a cabinet level state agency. 

Additionally, within the Legislation which established the Health Insurance Exchange, Senate bill 221, passed in 2013 there were several provision that were specific to Native Americans.  The NM Health Insurance Exchange (NM HIX) is required by law, to hire a Native American Liaison to assist the Executive board in outreach education and consultation with NM Tribes, Nations, and Pueblos.  Also required by law is the establishment of a Native American Advisory Committee composed of Native Americans representing communities on and off reservations.  The NM HIX also has the option to create a Native American Service Center, which is intended to provide a call center function for Native consumers, as well as technical assistance with eligibility and tribal enrollment verification.

There has not been any formal consultation between the state and Tribes regarding the NM HIX, the last scheduled consultation was set for April of 2011, this session was cancelled and never rescheduled. Since then the NM HIX has included Native Americans in none informal workgroups and committees and taskforces:

Native American Workgroup, the office of Health Care Reform (OHCR) established a task force to begin developing policy and guidelines in anticipation of the passage of legislation creating a state based health insurance exchange. The Native American Workgroup (NAWG) was created to provide guidance and insight into how the NM HIX would interact with NM’s tribes Nations and Pueblos. The NAWG worked topic such as: Job description/role of a Native American Liaison, consultation policies, creating a Native American Service Center and its functions, Tribal exemptions in the ACA, verification of Tribal enrollment eligibility for the HIX. The NAWG was composed of Advocates, healthcare providers, IHS and leaders. At each meeting it was clearly stated that the workgroup did not constitute tribal consultation and that the state needed to formally consult with tribes on the activities of the Human Services Department Office of Health Care Reform and the HIX

Native American Listening Session, the NM HIX Native American Standing committee, in order to address NA concerns instructed Mike Nunez, the Interim CEO, of the HIX to hold a listening session in order to solicit comments on what the needs of tribes were when it came to development and implementation of the HIX. Over 70 NA representatives participated in this session and the message was loud and clear. First Consultation with Tribes needs to happen as soon as possible, second the HIX needed to hire multiple Tribal liaisons, and third the Native American Advisory committee must be convened as soon as possible.

Interim Native American Advisory Committee- following up on a suggestion that came out of the listening session an interim advisory committee made up of members of the previous Native American Work group was convened to develop a communication policy for the HIX, this effort was replaced with the hiring of a Native American Consultant.

At an emergency session of the HIX board it was announced that Poston and Associates was hired to help the board and staff to create a tribal communication collaboration policy and facilitate outreach and education with Tribes.  Also Scot Atole (Jicarilla Apache) was hired as a Native American Coordinator.  When I asked what the selection process was to hire Poston and Associates, Mike Nunez relied that there was no RFP and that selection was made by Staff of the HIX. 

Native American communication collaboration session, on October 2, 2013 another listening/communication session was held with the intent to solicit guidance on developing consultation policy, development of a Native American service Center, Marketing best practices.

Throughout the development of the NM HIX there have been many instance where Tribes have unanimously state the same issues that needed to be addressed by the HIX: Meaningful Tribal Consultation, hiring of a Tribal Liaison or multiple Liaisons, and establishing a Native American Advisory committee, all of which are mandated by the law governing the HIX.  These Three task have yet to be completed.

It has been established that the NM HIX is a Quazi Governmental non-profit organization and therefore is not subject to the State Tribal Consultation Collaboration and Communication Act. This may be the case but the Act clearly states that any time and Agency applies for or changes funding that will directly affect Tribal individual’s communities and Tribes, there agency is obligated to hold formal consultation with NM Tribes Nations and Pueblos in order to inform them of the changes.  While the NM HIX is a quazi- governmental organization the NM Human Services Department, the umbrella organization to the NM HIX, was the cabinet level state agency that applied for the original Level one establishment grant of $34 million and the secondary grant of $8 million. Since applying for and receiving the grant funding HSD has held on to that funding.  The HSD Secretary Squire should be aware of the obligation to consult with Tribes given the recent consultation sessions with the Medicaid program.

From my point of view the NM HIX has had many opportunities to address Native American issues, and has at times delayed, and not fully taken advantage of the work and resources available.   

Respectfully,

 Erik Lujan
Consumer Advocate/Policy Analyst
NMICoA Health Committee
(505) 280-2811
elujan78@gmail.com

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