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Indian Health and Human Services

Improving Health and Well-Being in American Indian and Alaska Native Communities Through Compliance

Why OIG Created this Training Series

OIG's mission is to provide objective oversight to promote the economy, efficiency, effectiveness, and integrity of HHS programs, as well as the health and welfare of the people they serve, including members of the AI/AN community. OIG developed this training series to help meet the compliance needs of grantees and health care providers, including Tribes and Tribal organizations, that receive funds from HHS to serve AI/AN communities. While compliance fundamentals apply to all HHS programs, the Tribes' status as sovereign governments and as PL 638 contractors and compactors introduce legal and operational complexities. Similarly, the rules applying to Tribal recipients of HHS grants are not always identical to those of other HHS recipients.

Over the past years, OIG has had many opportunities to engage with Tribes and Tribal organizations about their needs as they relate to compliance, fraud, waste, and abuse, and quality of care. In these discussions, Tribal Leaders noted that information tailored to Tribes is helpful and requested training. With that goal in mind, this training program is specific to Tribal and Tribal organizations' needs.

How OIG Created this Training Series

OIG recognizes Tribal sovereignty and is cognizant of the government-to-government relationship between Tribes and the Federal government. Although HHS OIG cannot engage in formal consultation with Tribes with respect to oversight and fraud-related activities, we proactively and purposefully sought the input of AI/AN stakeholders in the development of the training program from inception to completion in a variety of ways.

HHS OIG has learned through our own audits and investigations a great deal about the breadth and nature of the program vulnerabilities which can interfere with the IHS's and Tribes' ability to maximize their programs' effectiveness. To learn more from those who are on the frontlines of providing benefits and services to AI/AN individuals, HHS OIG leadership and staff engaged with Tribal program officials over the several years preceding the development of this program. OIG HHS staff regularly attended Tribal meetings, conferences, and consultations sponsored by the Centers for Medicare and Medicaid Services, Administration for Children and Families, Indian Health Service (IHS), and other HHS Operating Divisions. HHS OIG leadership have made several trips to Indian Country to collect information on the needs of Tribes to inform our strategy and work planning to conduct oversight of AI/AN focused programs. OIG evaluators, auditors and attorneys have visited reservations, IHS hospitals and clinics, and Tribal health care facilities where we spoke to Tribal Leaders, community members, and hospital and clinic staff such as doctors, nurses, pharmacists, and compliance officers.

Additionally, these online trainings are an extension of our in-person trainings for grantees and health care providers who serve AI/AN communities held in South Dakota at the Crazy Horse Memorial in 2017 and in Oklahoma in 2018. At the conclusion of these trainings, we sought participant feedback which has been incorporated into this training series.

Finally, as we translated the content from in-person trainings and presentations to an online format, we formally sought user feedback on all courses from grantees and health care providers who serve AI/AN communities. As we received feedback, we amended content, wherever possible, to maximize the training's utility and value to AI/AN health and human services organizations.