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Public Health Authority and TECs

In 2010, Congress enacted the Patient Protection and Affordable Care Act (ACA), which permanently reauthorized the Indian Health Care Improvement Act (IHCIA). Originally passed in 1976 and subsequently amended, IHCIA declares that “it is the policy of this Nation, in fulfillment of its special responsibilities and legal obligation to the American Indian people, to assure the highest possible health status for Indians and Urban Indians and to provide all resources necessary to effect that policy.” IHCIA established the legal and programmatic structure for providing health services to American Indian and Alaska Native populations (AI/AN).

Under the IHCIA, the TECs have 7 Core Functions:

Collect data relating to, and monitor progress made toward meeting, each of the health status objectives of IHS, the Indian Tribes, Tribal organizations, and Urban Indian organizations in the Service Area.
Evaluate existing delivery systems, data systems, and other systems that impact the improvement of Indian health.
Assist Indian Tribes, Tribal organizations, and Urban Indian organizations in identifying highest-priority health status objectives and the services needed to achieve those objectives, based on epidemiological data.
Make recommendations for the targeting of services needed by the populations served.
Make recommendations to improve health care delivery systems for Indians and Urban Indians.
Provide requested technical assistance to Indian Tribes, Tribal organizations, and Urban Indian organizations in the development of local health service priorities and incidence and prevalence rates of disease and other illness in the community.
Provide disease surveillance and assist Indian Tribes, Tribal organizations, and Urban Indian communities to promote public health.

Public Health Authority and Health-related Data Access

The reauthorization of IHCIA in 2010 formally acknowledged the Tribal Epidemiology Centers (TECs) as public health authorities for purposes of the Health Insurance Portability and Accountability Act (HIPAA) and extended general authorization for TECs to access data held by the U.S. Department of Health and Human Services (HHS). While access to AI/AN public health data is essential for the successful performance of fundamental public health functions of the TECs, administrative requirements and additional legal constraints can present barriers to timely and comprehensive data access.

Following Tribal Consultation in 2011, IHS released a Dear Tribal Leader Letter in May of 2012, facilitating TEC access to select IHS data and also delivering a Data Sharing Agreement (DSA) template to guide data sharing negotiations. This DSA provides access by TECs to limited and largely de-identified data from the IHS Epidemiology Data Mart (EDM). The EDM is a data repository of IHS patient registration and encounter data managed by DEDP.

By 2019, nine of the TEC programs signed DSAs with IHS and completed numerous surveillance and analytic projects using the EDM addressing priority health topics such as:

  • Oral health.
  • Maternal and child health indicators.
  • Allergy, asthma, and respiratory disease.
  • Behavioral health.
  • Traumatic brain injury.
  • Validation of communicable disease surveillance.
  • Modeling risk factors associated with hospitalization among diabetics.
  • Disability in children.
  • Opioid use disorder.
  • Opioid overdose.
  • Injury.

In 2019, IHS launched an expanded data-sharing pilot project with Northwest Portland Area Indian Health Board (NPAIHB) Northwest Tribal Epidemiology Center (NWTEC). This pilot effort permits the use of IHS patient identifiers by NWTEC to correct for racial misclassification in the public health reporting of states within the IHS Portland Area. This effort will allow the NWTEC to compare a list of people who have received health services at IHS, Tribal, and Urban Indian health programs in the Portland Area with outside information sources, such as state cancer registries and death records, to check for racial misclassification. NWTEC will then use the corrected information for various analysis and reporting efforts, including to provide more accurate health data to Northwest Tribes. This increase in information sharing with our TEC partners acknowledges and further strengthens the statutory public health functions of the TEC.

This and other data sharing activities with TEC partners directly support the IHS Strategic Plan, Goal 3, Objective 3.3, Strategy 9: “Assure system of data sharing to solidify partnerships with Tribal and urban Epidemiology Centers and other Tribal programs and Urban Indian Organizations.”