Becerra, Sec. of H&HS v. San Carlos Apache Tribe (23-250)

argument 23-250

Becerra, Sec. of H&HS v. San Carlos Apache Tribe

Supreme Court of the United States 1h 26m 9 speakers 8 chapters transcribed 8 days ago official recording ↗
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What does the Indian Self‑Determination Act require regarding contracts with tribes?

John G. Roberts 0:00
We'll hear argument first this morning in case twenty three two hundred and fifty, Becerra versus the Upachi uh uh tribe. Uh Ms Flynn.
Patricia Guerrero 0:09
Mr Chief Justice, and may it please the court. The Indian Self Determination Act requires the Indian Health Service to enter into contracts with tribes to transfer federal health programs that IHS previously carried out for the tribe's benefit. ISDA's basic design is simple. IHS takes the appropriated funds it would have otherwise spent on the federal program and transfers those funds to the tribe in exchange for the tribe's promise to use them to provide the same level of services. And ISDA obligates IHS to add to that core secretarial amount contract support costs to plug specific gaps the secretarial amount does not cover. What the tribes are arguing here is that ISDA also obligates IHS to subsidize the tribe's expenditures of funds that they don't receive from IHS under the contract, but rather collect from third parties as supplemental revenue.
Patricia Guerrero 1:01
Statutory text and context refute that theory, which would upend how the statute has been administered for thirty five years. Is this provisions addressing contract support costs say nothing about third party revenue a tribe may earn? ISDA deals with that separate income stream in other provisions, including one instructing that such income shall be treated as supplemental funding to that in the contract. The tribe's argument that Congress actually intended for such income to determine what IHS pays under the contract would work a sea change in ISDA's scheme by potentially tripling the federal government's contract support cost obligation and eventually transforming what the statute designated. as mere support costs into the primary component of contract funding.
Patricia Guerrero 1:44
But there is an even more straightforward reason why the tribes theory here is wrong. It violates Congress's express command that IHS only reimburse costs that are directly attributable to the tribes is the contract. That prohibition applies notwithstanding any other provision of law. and would independently bar the agency from paying the costs at issue here, even if they might otherwise qualify. I welcome the court's questions.
Clarence Thomas 2:08
Uh are there limitations on how the tribe can use the outside income?
Patricia Guerrero 2:14
Uh there are
Clarence Thomas 2:15
additional income.
Patricia Guerrero 2:16
There are two statutory conditions that are applicable to how tribes can use these this uh third party reimbursement income. Those are in fifty three twenty five M one. That's a And
Clarence Thomas 2:26
what's that limitation?
Patricia Guerrero 2:28
So there it says they have to use it to further the general purposes of the contract.
Clarence Thomas 2:32
So if that's the case, I guess their argument is then it is a part of the contract.
Patricia Guerrero 2:38
Uh they have an argument that because all of ISDA twenty uh Title I is incorporated uh via cross reference in the authority section of the model contract, that that provision M one is incorporated. But that provision also has to be read consistent with a provision of the Indian Healthcare Improvement Act, that's sixteen forty one D two. And that governs the same reimbursement income and says tribes just have to use it, quote, for any health care related purpose or otherwise to further the purposes of that law, which include things like as varied as including the presence of uh tribal members in healthcare professions. So it is a very open ended limitation that is not limited to just providing additional contract services.
John G. Roberts 3:21
So under under your approach um uh a a tribe is worse off uh if the the more they undertake uh uh i in the in the direction of self determination. Right.
Patricia Guerrero 3:35
In
John G. Roberts 3:35
terms in terms of funding, they are undertaking more uh uh health care responsibilities and getting a smaller percentage of the money back from the government.
Patricia Guerrero 3:47
I would respectfully disagree with that, Your Honor. I believe uh you're referencing the the mathematical hypo that the tribes have offered in their brief saying that there's what they call a self determination penalty because for the same amount of third party reimbursement income, HHS brings in the tribe uh won't be able to provide the same level of services, but that assumes that HHS when it's or IHS when it's running its own program and the tribes are earning the same amount of third party income.

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