Emergency Justification memo

DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service
Indian Health Service
Rockville, MD 20857

TO:

Office of Management and Budget

FROM:

Director
Office of Information Technology

SUBJECT:

Justification Memo for Tribal EHR Data Call Information Collection

ISSUE
The purpose of this memorandum is provide a justification and request approval of the Indian
Health Service (IHS) information collection titled, “Tribal EHR Data Call.”
JUSTIFICATION
This information collection is a requirement from Congress. Congress instructed IHS to report
on the number of Tribes using commercial EHR solutions, and their associated costs. Congress
did not specify its intent or purpose for asking for this information.
According to the Consolidated Appropriations Act, 2021, signed into law on December 27, 2020,
“The Committees direct the [Indian Health] Service to report back within 120 days of enactment
of this Act with a list of Tribes that currently maintain their own non-RPMS electronic health
record systems along with cost estimates required for those Tribes to implement, maintain, and
make any necessary upgrades to these systems. Further directions and limitations on
expenditures are provided in the bill.”
This information requested is after the 120 day of enactment. This collection is essential.
Normally, the IHS does not collect or maintain this information about Tribal investment into
non-RPMS EHR systems, and IHS must issue a data call to the Tribes to gather the information.
The Agency cannot reasonably comply with the normal clearance procedures under this Part
because the use of normal clearance procedures is reasonably likely to cause a statutory deadline
to be missed.
RECOMMENDATION
I recommend you approve this request so that we can begin to collection the information.

Mitchell
Thornbrugh -S
Mitchell Thornbrugh

Digitally signed by Mitchell
Thornbrugh -S
Date: 2021.05.05 14:21:06
-04'00'