Letter to to express concern over the Indian Health Service’s recent reinterpretation of the duplication provision found in the Indian Self-Determination and Education Assistance Act (ISDA), 25 U.S.C. § 450 et seq. The agency’s new position that duplication is based
on categories of funding, rather than the actual dollars provided in the Secretarial amount, drastically
lowers the amounts owed to Tribes and Tribal organizations and is not supported by the statute or
IHS’s own Manual