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U.S. Department of Health and Human Services
Community Health Aide Program Expansion

Frequently Asked Questions

A: Reimbursement through CMS is fully dependent upon CMS’ approval of provider services. CMS will make their own determination as to what can or cannot be reimbursed based upon the eligibility criteria they establish. IHS does not determine reimbursement eligibility for CMS.

IHCIA Requirements and CHAP Authority

A:

  1. Provide training for health aides
  2. Develop a training curriculum
  3. Establish and maintain a certification board to certify health aides
  4. Develop and maintain a system that identifies continuing education needs of health aides
  5. Develop and maintain a system that supervises health aides
  6. Develop and maintain a system that reviews and evaluates health aides

A:

  • Provide training for health aides
  • IHS must establish the policy that creates the program
  • For specific aides within the program, state authorization is required (e.g., Dental Health Aide Therapists)

A:

  • In the expansion efforts, resources to Alaska CHAP (both funding and human capital) may not be reduced
  • Cannot authorize the use of Dental Health Aide Therapists in states that do not authorize their use in state law

Funding Support

A: CHAP requires a separate federal appropriation within the IHS budget. At this time, Congress has not funded CHAP expansion activities. However, states and tribal nations can provide resources once the CHAP is certified. Note: CHAP programs may still bill under the supervising dentist for services provided by DHAT until a State Plan Amendment (SPA) is in place.

A:The program requires dedicated Federal appropriations. At this time, CHAP activities at IHS remain underfunded. While Circular 24-16 has been completed and provides the core policy framework for CHAP, IHS is continuing to develop the operational infrastructure needed to support implementation—this includes certification processes, technical assistance tools, and readiness planning guidance.

Program Readiness and Tribal Actions

A:

  • Obtaining approval for State Plan Amendment (SPA) language for CHAP
  • Educating communities and clinic staff on how CHAP works
  • Outreach to community members to recruit future CHA providers
  • Identifying tribal leaders to serve on Area Certification Boards
  • Working with local tribal colleges and institutions on curriculum development or equivalency programs
  • Conducting site visits to established CHAP programs
  • Assessing community readiness and planning support strategies

A: There are differences between CHAP and CHR roles:

PROGRAM FOCUS AND OBJECTIVES
CHAP Focus: Direct clinical care, including diagnostics, treatment, and preventive services
CHAP Objectives: Improve access to care by training local community members as health aides delivering primary care
CHR Focus: Health promotion, education, outreach, social support, chronic disease prevention
CHR Objectives: Improve health outcomes by addressing social drivers of health and connecting individuals to care
TRAINING AND CERTIFICATION
CHAP Training: Extensive clinical instruction (anatomy, physiology, procedures, emergency care)
CHAP Certification: Required through exams, practical assessments, and continuing education
CHR Training: Core competency training in outreach, education, navigation, and support
CHR Certification: Often IHS or state-delivered; formal medical certification is not always required
ROLES AND RESPONSIBILITIES
CHAP Roles: Physical exams, treatment, emergency care
CHAP Responsibilities: Direct care and recordkeeping
CHR Roles: Health education, patient advocacy, connecting individuals to care
CHR Responsibilities: Organizing sessions, screenings, and liaison activities
OPERATIONAL ENVIRONMENT
CHAP Environment: Clinical settings or home-based care
CHAP Tools: Medical equipment and diagnostics
CHR Environment: Community settings, schools, homes
CHR Tools: Educational and health monitoring materials
IMPACT AND COMMUNITY ENGAGEMENT
CHAP Impact: Improves individual clinical outcomes
CHAP Engagement: Through direct care interactions
CHR Impact: Broad public health improvements through education
CHR Engagement: Outreach, events, and community groups
CHALLENGES AND OPPORTUNITIES
CHAP Challenges: Remote settings, limited resources, and sustainability
CHAP Opportunities: Pathway to clinical healthcare careers
CHR Challenges: Remote settings, limited resources, and sustainability
CHR Opportunities: Roles in public health, education, and community empowerment

A: The CHAP and CHR Programs are distinct:

Legislative Authority:

Funding:

  • CHAP (Alaska): Hospital & Health Clinics line item
  • CHR: Dedicated CHR line item

Scope of Work:

  • CHAs:Mid-level providers delivering basic clinical care under the supervision of a licensed provider.
  • CHRs: Health education, prevention, and outreach (not clinical treatment)

IHCIA Requirements and CHAP Authority

A:

  • Title I ISDEAA: Redesign with IHS approval and rebudget
  • Title V ISDEAA: Redesign and rebudget

A: It depends. Refer to:

  • Title I: 25 C.F.R. 900, Subpart M – FTCA Coverage Provisions
  • Title V: 25 C.F.R. § 137.220

Urban and State Participation

A: No. IHCIA specifies that CHAP expansion applies to tribes and tribal organizations. Urban Indian Organizations are not included under the expansion authority.

Funding Support

A: States must authorize Dental Health Aide Therapists (DHATs) through legislation before they can operate under CHAP.

A:

Alaska
Arizona
Colorado
Connecticut
Idaho
Maine
Michigan
Minnesota
Montana
Nevada
New Mexico
Oregon
Vermont
Washington
Wisconsin

Program Readiness and Tribal Actions

A: No. Under IHCIA, CHAP providers may not be used to fill dentist vacancies in Federal programs. They are intended to supplement—not replace—licensed dental professionals.

A: A SPA allows a state to formally include CHAP provider types (e.g., CHAs, BHAs, DHATs) as eligible under Medicaid. Without an SPA, these providers cannot be reimbursed for services through Medicaid.