Ryan White Program and IHS
The following RWCA provisions in the reauthorization affect the IHS and AI/AN population:
- AI/AN individuals are/were always eligible for RWCA services if certain requirements were met (as any other person infected/affected by HIV/AIDS would need to meet various requirements – dependent upon the State of residence).
- IHS federally operated Health Facilities will now be eligible to apply for services under Part C and Part D through the RWMA (in addition to previously authorized Urban Programs and 638 Tribal Facilities under RWCA). Thus, the changes of eligibility as a grantee for Titles III and IV affect our IHS sites, but did not affect the eligibility that was already offered to Urban and 638 facilities. Here are links to services provided under Part C and Part D: http://hab.hrsa.gov/programs/CapacityDevelopment/, http://hab.hrsa.gov/programs/PlanningGrant/, http://hab.hrsa.gov/programs/EarlyIntervention/, and http://hab.hrsa.gov/programs/women/. This, once again, enumerates eligibility, however funding for new programs will be through a competitive process.
- IHS facilities are exempt from the “Payer of Last Resort” restriction for Parts A, B and CAlthough RWCA grantees are the payer of last resort, this amendment exempts I/T/U facilities from reimbursement, regardless of referral. In the past, RWCA grantees were asked to coordinate reimbursement of such funds with the tribes and with the IHS.
- The new legislature supports access for all AI/AN under RWMA regardless of I/T/U utilization/affiliation or geographic location. (Previously, HRSA Policy 00-01 stated that AI/AN could not be turned away from RWCA services. RWCA grantees remain as Payers of Last Resort. If patients were referred from IHS, RWCA grantees could technically go back to IHS for funding (whether or not this actually happened). Now, the RWMA codifies (that IHS is exempt from the Payer of Last Resort restriction) this language into law.
- Planning council representation under Part A should include members from federally recognized Indian tribes as represented in the population.
- Language surrounding AIDS Education and Training Centers (AETCs) now specifically names “Native Americans” as person(s) to be trained. Previous language did not specify this; however we have been working with the AETC leads at HQ for quite some time and are continuing this activity by working on renewing a formal collaborative agreement.
We are working diligently with leadership from HRSA to discuss ramifications and implementation of this language and to disseminate the message of these changes to help with care of our AI/AN persons at risk and living with HIV/AIDS. Additionally, we hope to focus current and future initiatives and collaborations with HRSA around efficient models and linkages of care between our clients, I/T/U facilities, and Ryan White grantees, service providers, and services (i.e. RWCA Titles I, II (which includes the AIDS Drug Assistance Program), III, IV, etc.).
Although I/T/U sites are eligible for Titles III and IV, this does not mean I/T/U sites are automatically grantees; they must go through the application and approval process. For now, you may visit http://www.grants.gov/ for more information.
Given these new provisions, it is imperative that all AI/AN clients and facilities eligible for these provisions are made aware and assisted in removing any barriers to effective and seamless access and care. It may be advisable for each health facility to contact a RWMA grantee in your respective area/state to link this new language to an action plan and discuss potential linkages or improve existing ones.