On February 26, 2016, the Centers for Medicare and Medicaid Services (CMS) released State Health Official (SHO) letter #16-002 updating its policy regarding circumstances in which 100 percent federal funding is available for services to American Indian/Alaskan Native (AI/AN) “received through” facilities of the Indian Health Service (IHS), including Tribal health organizations. SB 74 required the department to fully implement the new federal policy.

The SHO letter requires care coordination agreements (CCAs) between tribal and non-tribal providers to claim the enhanced federal match for services provided to an AI/AN Medicaid enrollee by a non-tribal provider. The department has been working with the Tribal Health Organizations (THOs) to facilitate initiation of CCAs with non-tribal organizations since February 2016. The SHO letter further requires the validation that a referral was made for each episode of care, and that an exchange of electronic health records occurred for each episode
of care. As of August 2018 there are a total of 1,450 CCAs in place between 18 THOs and 137 non-tribal providers. Note that some, but
not all, of the THOs have signed an agreement with each of the 137 non-tribal providers.

The department’s Tribal Section tracks the 1,450 CCAs, and must verify that a valid referral and exchange of health records occurred for each episode of care before the state can claim 100 percent federal funding. The number of referrals requested and verified by the department since the new policy was implemented through the end of FY 2018 was 25,078. The number for which sufficient documentation was available to validate the referral was 5,594, or 22.3 percent of requested referrals. In addition, the department must also track the transportation arrangements made by the Alaska Native Tribal Health Consortium, Yukon Kuskokwim Health Corporation, and Tanana Chiefs Conference for AI/AN recipients, which account for approximately 1,000 – 1,200 travel arrangements per week.