The Tribal Biotechnology & Health Consortium’s full sovereign submission on the CY 2026 Medicare Physician Fee Schedule has been posted publicly on Regulations.gov, the federal government’s official rulemaking record platform, under Comment ID CMS-2025-0304-13291.

The publication places the full tribal sovereign argument — invoking Executive Order 13175, the Indian Health Care Improvement Act, the federal trust responsibility, and the Buy Indian Act — in the permanent public record, accessible to scholars, other tribal nations, and the federal historical archive.

The Consortium files all formal sovereign comments through public-record channels by design. Tribal engagement with federal agencies has often been conducted privately — a practice that can leave the tribal sovereign voice invisible to future generations. The Consortium has chosen the opposite: full visibility, full transparency, full public record.

“Our descendants should be able to read what we said to the federal government on behalf of our nations. Our colleagues in other tribal nations should be able to read it and use it. The federal government should know that what we say to them is what we say to history. There’s no closed-door version of the tribal sovereign position. The position is the position.”

— John Michael Cataldi, CEO, Clear Health Pass Holdings

What this means for tribal health and tribal nations

A tribal attorney drafting a sovereign comment for the next rulemaking cycle can search Regulations.gov and find the Consortium’s full sovereign argument — the statutory citations, the policy framing, the clinical grounding — and build on it without starting from zero. That’s the practical value of the Consortium’s transparency, and it’s available to every tribal nation that comes after.

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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