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Conflict of Interest: Home- and Community-Based Services (HCBS)

last modified 05/22/2019 - 02:49 PM

This site provides information on the concept of conflict of interest in HCBS and describes how HCBS case management is provided in Vermont.


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 HCBS 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. Enhanced Family Treatment (Intensive Home and Community Based Services)


AHS is in the process of assessing the status of conflict-free case management in the HCBS programs mentioned above with the goal of ensuring compliance with applicable federal regulations. As part of this assessment, the Agency seeks feedback from stakeholders on their experience with each of these programs in 2 phases:

  • Stakeholder Engagement Phase 1: Feedback will be collected to inform ways in which the potential for conflict of interest in HCBS case management can be prevented or reduced. AHS seeks feedback and is not proposing changes in this phase.
  • Stakeholder Engagement Phase 2: AHS will re-engage stakeholders following the collection of this feedback, and if any changes are needed, AHS will explain the change(s) and ask for formal stakeholder input in this phase. Changes could vary by program.


HCBS Conflict of Interest Information:

Department of Disabilities Aging and Independent Living (DAIL) Information:
Centers for Medicare and Medicaid Services Information:
Stakeholder Feedback:
Not able to download a feedback form?
  • Email with your feedback directly, and feel free to answer these questions:
    1. What program are you commenting on?
    2. When you think about case management in this program, what works well? What doesn't work well?
    3. What potential conflicts of interest in case management do you see in this program?
    4. What suggestions do you have to prevent or reduce conflicts of interest?
    5. What should we consider when deciding how to prevent or reduce conflicts of interest?