The Tribal Biotechnology & Health Consortium today filed its formal sovereign comment on the proposed CY 2026 Medicare Physician Fee Schedule (CMS-1832-P), continuing a coordinated, multi-docket engagement with the Centers for Medicare & Medicaid Services.

The comment builds on the 910-page submission filed in July and adds the formal sovereign legal framing required under Executive Order 13175 and the CMS Tribal Consultation Policy. On September 13, the Consortium filed a companion comment on the Inpatient Prospective Payment System (IPPS, Part A) to ensure full alignment across the three federal rulemaking dockets that affect the Consortium’s product line. On September 16, the comment was published publicly on Regulations.gov as Comment ID CMS-2025-0304-13291.

“The tribal sovereign voice has to be present on every docket, every cycle, every time. We filed PFS, OPPS, IPPS, and companion clarifications, and we published to the public record. That’s what multi-docket federal engagement looks like when you take it seriously. We’ve built the capacity to do this every year, and we will — for as long as the federal government writes rules that affect tribally owned regulated products, which is to say, for as long as the United States exists.”

— John Michael Cataldi, CEO, Clear Health Pass Holdings

What this means for tribal health and tribal nations

Eight tribal nations onboarding into the Consortium are watching how multi-docket federal engagement works in practice. The Consortium has demonstrated, on the public record, that tribal nations can deploy that capability at the level of any major regulated sector. The playbook now exists. Other tribes shouldn’t have to invent it from scratch.

About Clear Health Pass™  

Clear Health Pass™ is a bioinformatics, bio-surveillance. Clear Health Pass™ is a minority/veteran-operated organization in partnership as tribal is a portfolio partner of The Native American Venture Fund (NAVF). Clear Health Pass Holdings, LLC, DBA Clear Health Pass™ is an appointed “Tribal Agent” for The Tribal Consortium, a federal, Section 17 Tribal Corporation, whose tribal sovereignty’s authority is derived from The Indian Reorganization Act Of 1934 (IRA), 25 U.S.C. § 477. If you would like to know more information and investment opportunities with Clear Health Pass™ you can request information via this link

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