The State of IHS Tribal Drinking Water Data
Tribal Drinking Water Data Landscape–Indian Health Service
The Indian Health Service (IHS) is the other federal entity that maintains drinking water data relevant to Tribal communities. Its data systems are designed to support the Sanitation Facilities Construction (SFC) program and are accessible to IHS employees and Tribal staff, and, at aggregate levels, to some authorized federal staff at collaborating agencies. The primary data system, Sanitation Tracking and Reporting System (STARS), is widely considered the best data source to characterize drinking and waste water access in American Indian and Alaska Native communities. Unlike EPA’s SDWIS dataset, STARS tracks household-level access and includes data for Indian homes both on and off Tribal lands, provided the homes meet SFC program eligibility criteria (IHS funds sanitation facilities projects to serve homes only, as opposed to other buildings such as schools or Tribal offices).
IHS: STARS
STARS is used to identify and prioritize projects that address sanitation deficiencies—defined by IHS as “needs arising from existing water, sewer, or solid waste facilities (or the lack thereof) that create or may result in exposure to environmental conditions that negatively impact public health.”
Where EPA’s service area boundaries dataset has been a revelation to non-Tribal communities, Tribal communities have household-level sanitation data and a household-level project planning tool in STARS, albeit with gaps and significant opportunities for improvement.
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The first is the Home Inventory Tracking System (HITS), which contains home-specific sanitation deficiency information. HITs data is collected for “Indian homes,” which can be on or off reservations, but according to IHS officials, the agency typically does not collect information about Indian homes located in large urban areas. IHS officials work directly with individual Tribes to identify homes that need to be included in the tracking system, in order to ensure the inclusion of all Indian homes that may have a sanitation deficiency and are eligible to receive SFC program assistance. “Through this process, IHS has entered information about hundreds of thousands of eligible Indian homes in HITS and developed thousands of projects in the SDS.”
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The second is “the Sanitation Deficiency System (SDS), which contains proposed drinking water and wastewater infrastructure projects to address identified sanitation deficiencies.” The two systems are connected–every project identified in SDS connects to all individual homes identified in HITS that will benefit from the project and “the HITS data supporting an SDS project must be accurate and must be reviewed on a regular basis.” The information in HITS is used to estimate costs and describe the communities that will benefit from the projects with a Community Deficiency Profile (CDP) to track the status of infrastructure deficiencies for individual Tribal communities. IHS then uses these project descriptions to prioritize and fund projects. More on project prioritization through SDS can be found in the 2019 IHS SDS Guide.
STARS data collection
To collect sanitation deficiency data, “area [IHS] staff work with tribes each year to (1) identify Indian homes eligible for and in need of IHS drinking water or wastewater infrastructure assistance to include in IHS’s home-specific tracking system, HITS; and (2) develop projects aimed at correcting any identified sanitation deficiencies in these homes to include in the SDS.” SDS project descriptions include “information about the sanitation deficiency level that each project will address, the project’s estimated cost, and the number of Indian homes that the project will serve.” Information on the data quality control process for data in STARS can be found in this EPA Data Quality Record.
Discussion of Tribal Drinking Water in IHS STARS Data
TLDR:
IHS data is highly accurate and granular (when Tribes collaborate on data collection) but can be limited by the strict SFC program eligibility requirements, and still likely underestimates the number of deficiencies. Its scope and geographies are different from EPA’s drinking water data geographies. STARS is not public, but can be accessed by Tribes and agency staff, though it is not accessible as a data analysis tool. Data analysis is made public on an aggregate level only, in the context of IHS’ annual report to Congress. IHS STARs is a useful tool for Tribal project planning, it is a useful tool for IHS in project planning and budgeting, and it is a useful tool to external agencies seeking to support Tribal sanitation projects. Links to EPA datasets could improve the validity of IHS datasets. There may be opportunities to expand the use of IHS STARS data through the development of data analysis tools that make use of this extensive and highly accurate data to support Tribally-driven data analysis and decisionmaking.
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STARS is private and confidential, accessible to Tribal governments through a password-protected website. This privacy of the system is best practice, particularly because drinking water data is owned and should be governed by Tribes. EPA staff have read-only access to portions of the system for the purpose of establishing funding priorities with EPA dollars. IHS shares other aggregated, read-only data with other agencies who support Tribal sanitation infrastructure.
A 2011 evaluation found that IHS and EPA have opportunities to better communicate, and that project selection in SDS is not always aligned with EPA priorities for the Clean Water Indian Set-Aside (CWISA) Grant Program and the Drinking Water Infrastructure Grant Tribal Set-Aside (DWIG-TSA) programs. The evaluation also identified the potential for improved data linkages between SDWIS and STARS. Some data elements were missing that would allow the data to be linked between datasets, including PWSIDs(the water system identifier in SDWIS) and Sanitation Deficiency System (SDS) and Project Data System (PDS) numbers from STARs.
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IHS produces Congressionally-required Annual Reports to Congress on Sanitation Deficiency Levels in Indian Homes and Communities using STARS data. While STARS captures the costs for all infrastructure affected by a sanitation deficiency project, eligible and ineligible, only the SFC program-eligible costs are reported in IHS’ Annual Report to Congress. However, IHS does still sometimes publish additional information and also supports Tribes in identifying funds from other federal agencies that may be able to cover ineligible costs. The 2021 Water and Tribes report lays out the complex SFCP eligibility requirements, and recommendations for improving access to SFCP for Tribal Communities. Here are a few examples of who might be ineligible for SFCP and missing from assessments of need:
New homes funded by Housing and Urban Development (HUD), which are not eligible for IHS funded construction of sanitation facilities;
American Indian/Alaska Native homes located in a non-Indian community, and non-American Indian/Alaska Native homes located in an Indian community;
Base community infrastructure, like schools, Tribal buildings, teachers’ homes, and post offices, which IHS requires be funded with matched funds, and will not be funded with SFCP funds.
Future residents–IHS does not adequately accommodate growth projections or plans, which has implications for Tribal citizens who wish to move to their homelands but are unable to because of a lack of housing, caused in part by lack of clean water.
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As one would imagine, collecting sanitation deficiency data for every SFC-eligible home and maintaining the accuracy of that data is very time consuming and requires quite a bit of IHS and Tribal staff capacity.
In conversations with individuals who have used STARS, we learned that STARS data is not always accurate or validated, and fields may be missing. This privacy of the system is best practice, particularly because drinking water data is owned and should be governed by Tribes. Historical evaluations of EPA and IHS data systems have recommended improving data to define lack of access to safe drinking water and safe wastewater disposal. Some Tribal drinking water managers we talked to described how helpful IHS STARS is–particularly in terms of the SDS project planning capabilities. However, they also mentioned that capacity and funding limitations at IHS, combined with project scoring criteria can sometimes result in projects that are further from ready, but still important in terms of planning, out of the system.
IHS guidance relates that the most reliable method for identifying new or reviewing existing sanitation deficiencies is through a sanitary survey or field visit completed by IHS staff in collaboration with Tribal staff. IHS staff must assess the most valid data sources for understanding local population demographics–per IHS guidance: “When identifying sanitation deficiencies, the population demographics and number of eligible homes vs. ineligible users within the community must be accurately known. Judgment should be exercised in using census data, as the Census Bureau may underreport the Indian population and number of homes in some locations. Local data sources (e.g. tribal housing authorities and planning departments) may provide more accurate population and homeownership data.”
HITS likely underestimates the number of eligible Indian homes that may have existing infrastructure needs. not all Tribal homes eligible for IHS water infrastructure assistance may be in HITS. In some cases, Tribes elected not to provide information to IHS because of cultural or other concerns. Checkerboarding has also created challenges, and in Oklahoma, IHS officials “estimated that 100,000 homes eligible for IHS assistance may not be in the database due to challenges identifying eligible homes within communities that have a mix of Tribal and non-Tribal residents and that are not on reservations.” Similarly, in Portland, Oregon, IHS officials have noted that many eligible Indian Homes are likely excluded from HITS “because of difficulties identifying Tribal homes in dispersed areas removed from Tribal community facilities.” Moreover, data system assessments have found that PWSIDs are not always accurately recorded in the SDS.
Explore the data yourself
IHS captures the data necessary for implementing the Sanitation Facilities Construction program in the Sanitation Tracking and Reporting System (STARS), which captures sanitation deficiencies in Indian homes. Check out our report to learn more!