Conflict of Interest: Home- and Community-Based Services

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**Please visit the new Home and Community-Based Services Conflict of Interest website for up-to-date information.**

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Background

On January 16, 2014, the Centers for Medicare and Medicaid Services (CMS) issued final regulations on home- and community-based services (HCBS) requirements (79 FR 2947). The rule supports enhanced quality in HCBS programs, outlines person-centered planning practices, and reflects CMS’s intent to ensure that people receiving services and supports under different federal authorities can fully participate in their community and can receive services in the most integrated setting of their choice. A key part of these new HCBS requirements is the assurance that case management is provided in a conflict-free manner.

The Agency of Human Services (AHS) has been progressive in pursuing a home- and community-based services (HCBS) continuum of care that offers meaningful community integration, choice, and self-direction, and strives to promote health, wellness, and improved quality of life. The following programs which support these goals are authorized through the 1115 Global Commitment to Health waiver:

1. Choices for Care Moderate, High, and Highest Needs Groups
2. Developmental Disabilities Services Program
3. Traumatic Brain Injury Program
4. Community Rehabilitation and Treatment
5. Intensive Home- and Community-Based Services (formerly Enhanced Family Treatment)

Home- and Community-Based Services Conflict of Interest Plan

As addressed in the October 22, 2021 Global Commitment Register Clarification on Home- and Community-Based Services (HCBS) Conflict of Interest, Vermont Medicaid submitted its HCBS conflict of interest plan to the Centers for Medicare and Medicaid Services (CMS). The corrective action plan was approved by CMS on March 7th, 2023: 

• CMS Approval Letter
• HCBS Conflict of Interest Corrective Action Plan
• Corrective Action Plan Summary (unofficial)

Stakeholders are encouraged to submit feedback on the Home- and Community-Based Services Conflict of Interest Plan by emailing ahs.medicaidpolicy@vermont.gov. Please say what program(s) you are commenting on.

HCBS Conflict of Interest Advisory Committee Meeting Materials:

• March 21, 2023: 
  • Meeting Recording
  • Meeting Minutes
  • Agenda
  • Advisory Committee PowerPoint Slides
  • Discussion Guide for March Advisory Committee Meeting
• February 22, 2023:
  • Meeting recording 
  • Meeting minutes
  • Agenda
  • Advisory Committee PowerPoint Slides
  • Corrective Action Plan Summary

Other HCBS Conflict of Interest Information:

• Conflict-Free Case Management Home- and Community-Based Services Summary (February 2019)
• Conflict-Free Case Management Presentation (March 2019)
  • Includes key information from the summary above and program documents below.
• Case Management Assessments by Program:

1. Choices for Care Program (Moderate, High, and Highest Needs Groups) (March 2019)
2. Developmental Services Program (March 2019)
3. Traumatic Brain Injury Program (March 2019)
4. Community Rehabilitation and Treatment Program (CRT) (March 2019)
5. Intensive Home- and Community-Based Services Program (IHCBS, formerly Enhanced Family Treatment) (March 2019)

Department of Disabilities Aging and Independent Living (DAIL) Information:

• DAIL Case Management Activities (March 2019)
• Summary of Phase 1 feedback for Department of Disabilities, Aging, and Independent Living (DAIL) programs. (July 2019)
• Presentation of DS Program solutions and conflict of interest requirements (August 2019)
  • Recorded webinar of DS Program solutions and conflict of interest requirements (August 2019)
• Analysis of Proposals to Address Potential Conflict of Interest (August 2019)
• Feedback on Options for Addressing Conflict of Interest in Case Management in Developmental Disabilities Services (October 2019)
• Presentation of DAIL program solutions and conflict of interest requirements (September 2019)
• Choices for Care: Analysis of Proposals to Address Conflict of Interest (August 2019)
• Presentation of DAIL program solutions and conflict of interest requirements (September 2019)
• Brain Injury Program: Analysis of Proposals to Address Conflict of Interest (August 2019)
• Summary of Phase 2 Feedback on Choices for Care Program Solutions (April 2021)
• Presentation of DAIL Choice Model and Summary of Work to Date (July 2021)
• Summary of Phase 3 Feedback on the DAIL Choice Model (October 2021)

Centers for Medicare and Medicaid Services (CMS) Information:

• HCBS Conflict of Interest Presentation Part I (January 2016)
• HCBS Conflict of Interest Presentation Part II (July 2018)
• Mitigating Conflict of Interest in Case Management: Outcomes to Date (July 2019)

Stakeholder Feedback:

• General feedback on this project or questions can be submitted at any time to: ahs.medicaidpolicy@vermont.gov. Please say what program(s) you are commenting on.