Encourage tribal self-governance in PPC formation and implementation, in line with PL 93-638, ISDEAA
SAMHSA’s implementation of ‘Prevention Prepared Communities (PPC)’ appears to be a step in the right direction toward reducing the rate of suicide for American Indians and Alaska Natives (AI/AN). Involving “individuals, families, schools, workplaces, and communities” is an appropriate method of increasing awareness and aiding prevention. Our concern is not with the program’s stated objectives, but the method upon which “effective” practices are constructed. If the PPC program relies solely upon “data driven” or “evidence-based” methods, this could preclude newer, more innovative possibilities that, although in their formative stages, have shown great potential.
The first strategic initiative of SAMHSA acknowledges the place of suicide prevention within the larger context of substance abuse and mental illness. Our concern is with possible limitations in how these programs can be effectively applied to individually diverse communities lacking the administrative capacity to gather the amount of data necessary to achieve statistical significance.
In order to accommodate entities with limited data acquisition abilities in achieving the program priorities, we ask SAMHSA to allow meaningful input by the entities these programs intend to target. The relatively small sample size, by which many communities and villages are characterized, necessitates that measures be taken to incorporate information that goes beyond “numbers”, as measures of success or failure are not determined by a single incident. In this respect, it is imperative for SAMHSA to seek meaningful consultation in PPC formation and maintain a degree of flexibility in its eventual implementation.
Additionally, there is a growing concern among AI/AN Tribes and Tribal organizations regarding SAMHSA’s emphasis on program funding via grants. Although significant measures have been taken to lessen the complexity and administrative burden involved in the grant application process, it invariably forces potential applicants to divert resources that would otherwise be used to provide direct services. The process, inherent to grant applications, requires a specific set of technological and workforce prerequisites that are out-of-reach to many isolated, rural communities – which are often the most vulnerable and in need of assistance.
Beyond the exclusion of those whom the grants are intended to help most, the grant application process invariably puts tribal participants in competition with each other over limited resources. With regard to these practices, we request SAMHSA fully incorporate a distribution and funding system in line with PL 93-638, the Indian Self-Determination and Education Assistance Act, by providing funding through the existing Title I and Title V funding agreements that tribes and tribal organizations have with the Department of Health and Human Services. This practice would allow for the use of a proven effective and efficient Tribal Self-Governance process to further SAMHSA’s mission of substance abuse and mental illness prevention.
Evangelyn "Angel" Dotomain, MBA
Alaska Native Health Board