Excerpt: “TSGAC believes that any efforts to reorganize, streamline, or create efficiencies require Tribal
Consultation under the HHS Tribal Consultation Policy, most recently revised in 2010. The Department’s Tribal Consultation Policy states that “Before any action is taken that will significantly affect Indian Tribes it is the HHS policy that…consultation with Indian Tribes will occur.” The policy further states that actions that may “have substantial direct effects on one or more Indian Tribes” or impact “on the relationship between the Federal Government and Indian Tribes” require Tribal Consultation. Therefore, we believe that Tribal Consultation on this initiative is necessary.”
