DC

RE: Comment regarding Section 5006(a) of ARRA PLEASE SEE COMMENT LETTER ATTACHED/Delivered Electronically Dear Administrator Berwick: On behalf of the National Indian Health Board (NIHB) and the Centers for Medicare and Medicaid Tribal Technical Advisory Group (TTAG), we write in response to the definition of Indian contained in the Final Rule regarding Premiums and Cost Sharing. Established in 1972, The National Indian Health Board advocates on behalf of all Tribal Governments, American Indians and Alaska Natives in their efforts to provide quality health care for ALL Indian People. The NIHB serves as conduit to open opportunities for the advancement of American Indian and Alaska Native health care with other national and international organizations, foundations corporations and others in its quest to build support for, and advance, Indian care issues. Although generally leery of Interim Final Rules, in this instance, we agree with the assessment of the Centers for Medicare & Medicaid Services (“CMS”) that further delay in enacting rules regarding implementation of protections against premiums and cost sharing for Indians and Alaska Natives would have been harmful. In addition, CMS has provided opportunities for Tribal Leaders, directly and through the Tribal Technical Advisory Group to CMS, to be involved in the development of the rules. We also appreciate this additional comment period. We strongly support the definition of “Indian” adopted in the new paragraph (b) added to Section 447.50. The inclusiveness of the rule assures both that all individuals who are considered “Indian” or “Alaska Native” will enjoy the protection of the rule and that determining who an Indian is will be administratively simple. We recommend this definition be applied when other protections against costs and access to benefits intended for Indians are being implemented. The relationship of Indian people and tribes with their States varies widely, but even in t