To the editor:
The medical staff of the Tuba City Regional Health Care Corporation (TCRHCC) sees the proposed amendments as detrimental to the health of our patients. We understand that the purpose of these amendments is to improve the health care of the Navajo People, but we believe it will do just the opposite.
Proponents of this amendment assert that Navajo control of regulation, licensure and enforcement will better ensure quality and culturally relevant health care services.
This is definitely not correct. The healthcare industry in the United States is already the most regulated industry in the nation. The hospitals and clinics on Navajo are required to meet rigid federal and state regulation in order to be paid by the federal government (Medicare) the state government (Medicaid) and third party payers (private insurance, an area which is likely to become more important with the implementation of the Affordable Care Act (ACA), another federal law with a huge federal bureaucracy.) Compliance with these regulatory agencies is a big task for the most experienced of hospital administrators and medical professionals.
The proposed changes would simplify the Medicaid program by placing three different state Medicaid programs (Arizona, Utah and New Mexico) under one roof.
Although this might sound simpler in reality, it would be more difficult to negotiate payments from the federal and state agencies and would likely lead to an even lower all around Medicaid payment. Add to this the implementation of the ACA and you have a nightmare on your hands.
The Navajo Nation finds states are encroaching on the Navajo Nation's inherent sovereignty to regulate health care.
All the current regulations would still apply if payment from the federal government were to continue.
The Navajo Department of Health is authorized and established to meet the comprehensive health care and public health needs of the Navajo Nation and its population.
Public health is within the scope of a health department, but Navajo cannot realistically provide comprehensive health care. The health care system is far too vast. Public health cannot provide the education, research facilities, training, etc. required by an entire health system.
The Navajo Department of Health will provide licensure and certification of health care providers to ensure quality and relevant health care services.
If the Navajo Nation intends to manage the licensure and certification of healthcare professionals it will only succeed in adding another layer of bureaucracy to a system which is already functional in 50 states. Nor would an attempt to do this satisfy the credentialing of the Indian Health Service (IHS) and 638 facilities by the Centers for Medicare and Medicaid Services (CMS).
In addition, this will severely limit the ability to recruit health care providers. In general it takes six months to credential a physician at a hospital or clinic and about three months to credential a nurse or other professional. Adding another level of licensure would only slow this cumbersome practice further and would not add any additional safety component.
No credentialing process guarantees quality of care, which is an ongoing process at every hospital and clinic. We comply with performance improvement standards required by the federal, state and third parties that pay us for services. The Navajo Department of Health would have to meet these exact same criteria.
Making it more complicated to attract good physicians and nurses with extra requirements will not improve the ability for Navajo institutions to recruit, especially since the salaries for most of these professionals is at the 25th percentile compared to national averages.
We comply with the Navajo Preference Employment Act and promote the hiring, education, training and mentoring of Navajos interested in the health care field.
We have a department of traditional healing and promote culturally sensitive care.
We provide service in the Navajo language.
Navajo Department of Health will review agreements, develop comments and participate in negotiations.
This is not within the realm of a health department. These functions should lie within the control of the local board of directors who are best able to meet the needs of their service unit. Who better to chart the course for individual clinics and hospitals on Navajo but the people most directly affected? Only local control, not a central bureaucracy, can meet the needs of the people.
We wish to express our continued support for the oversight authority of the Health Education and Human Services Committee (HEHSC) over the Tuba City Regional Health Care Corporation as established by the Navajo Nation Council. We know the vital health care services provided to our community will be compromised by changes to that authority, we are concerned for the welfare of our patients, our hospital and our community. We should be delighted to offer testimony in support of the current oversight. We look forward to meeting with you.
Kathleen Harner, MD, MPH, FACOG
Deputy Chief of the Medical Staff, Tuba City Regional Health Care Corporation
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