Frequently Asked Questions


Click on a question below to see the answer. We will continue to update these as the project continues. You can also download the HCBS-COI Recommendations frequently asked questions as a PDF by clicking here.

  • Federal rules about case management changed in 2014, and Vermont has not yet addressed these rules. Vermont is under a Corrective Action Plan with the federal government. This federal plan requires changes to address conflict of interest to keep our federal funding. Vermont also wants to protect participants’ rights, ensure equity and fairness, and improve quality. The recommended changes expect to address all these issues.

    • A webinar explaining the recommendations and the process for feedback was recorded on December 15, 2023. This recording will be available on the website soon.
    • Please contact Jacob Briscoe at or (202) 839-4742
      if you have questions about the survey, meetings, or Recommendations process. Jacob can also help if you need any accommodations to participate in the process.
  • Vermont is under a Corrective Action Plan with the federal government that requires it to start coming into compliance with conflict-free case management rules by May 2025. Vermont must be fully compliant by the end of April 2026. Changes affecting participants and providers will start in 2025 and will be complete by April 30, 2026. This allows for a year of transition time.

  • This coming year, 2024, is a time for planning and input. AHS will collect feedback on its recommendations through January 2024. Then AHS will work on a draft implementation plan to share with the public in Spring 2024, with a final implementation plan complete in Fall 2024. The plans for the new conflict-free case management will need to be approved by the federal agency, CMS.

  • Beyond separating case management and direct services as required under the rules, many implementation decisions still need to be made. AHS wants to hear from stakeholders about how we can use these recommendations to improve case management and ensure quality across all of the HCBS programs.

  • Participants do not need to change their case manager now, unless they want to do so. If people need to select a new case management agency in 2025, they will receive notice ahead of time. However, HCBS participants may request to change their case manager at any time.

  • The redesign of case management in these programs is not meant to change the direct services people receive. Some people will change case managers or have a change in the agency delivering case management. Because some Vermont organizations combine direct services and case management activities, the way some services are delivered may be different in the new system. But conflict-free case management implementation will not change the amount or kind of services participants can receive.

  • AHS is in the process of reviewing current case management and direct service rates. This work will occur throughout 2024. Changes to payment methodologies and rates may be needed in some programs.

  • The rate development work that is underway will continue through 2024 and will inform the need for budget appropriations in State Fiscal Year 2026. AHS will also review the need for ongoing funding related to training, information technology, or other needs.

  • Case management agencies and their employees are encouraged to review the recommendations and provide feedback in the surveys and forums. As the State plans for implementation, the perspectives of case managers and agencies will be very important to improve the process and minimize disruptions for people.

    Agency staff may also receive questions or concerns from participants about this process. If an agency cannot resolve the question or concern, please contact Jacob Briscoe at or (202) 839-4742 with questions about the survey, meetings, or Recommendations process. For other questions or concerns, please email AHS – Medicaid Policy

  • AHS understands that this process may be difficult for some people who receive services and their families. AHS is working on plans and strategies to make sure people have the information they need and many chances to ask questions and express concerns, as well as supporting people through the transition. We welcome your ideas and feedback about how to make this process as easy as possible for everyone.

  • AHS understands that this process may be difficult for agencies and their employees. AHS will meet with affected agencies in early 2024 to gain a better understanding of how we can support providers and participants through the transition process. Maintaining experienced and knowledgeable staff in the Vermont HCBS workforce is critically important to AHS and to participants. AHS values HCBS case management staff and will work with agencies on retention strategies, as well as offering funding resources to help with the costs of transition.

  • AHS is not asking participants and providers to make changes now. If you have problems with your current services or case management, you may talk to the provider, your case manager, or you may file a complaint or grievance with AHS.

  • The State has explored options to address conflict of interest in two DMH programs: Community Rehabilitation and Treatment (CRT) for adults, and Intensive Home and Community-Based Services (IHCBS) for children and their families. AHS has determined that most mental health services offered through the CRT and IHCBS programs could be delivered under a different set of rules. This changes the expectations for conflict of interest and case management in DMH programs, requiring fewer changes to these programs than DAIL will need to make for Developmental Services, Choices for Care and the Brain Injury Program.

  • AHS has been working to address HCBS conflict of interest issues for over 6 years. In 2023, the state’s contractor completed an assessment of the HCBS concerns. AHS requested public input on case management options, with the results of this process summarized here. These activities informed AHS decisions about the recommendations. For more information about the history of HCBS-COI in Vermont, please visit this page.

  • Medicaid home and community-based services (HCBS) provide opportunities for people to receive services in their own home or community rather than institutions or other isolated settings.

    States can offer a variety of services under a Medicaid HCBS Waiver program. Programs can provide a combination of standard medical services and non-medical services. HCBS often includes case management, personal care, homemaker, home health aide, adult day health services, habilitation (both day, including employment, and residential), and respite care.

    In Vermont, the list of HCBS for each program is listed in Attachment F (page 120) of the Vermont 1115 Global Commitment to Health Waiver.

  • CMS gives states a lot of flexibility to define the specifics of case management and how it is delivered, but generally the expectation is that case management is a set of activities that help participants receive appropriate and needed services, including assessments, assistance in accessing both Medicaid and non-Medicaid services and resources, and service planning, implementation, and monitoring.

  • Vermont defines case management a little differently for each HCBS program. For example:

    “Assistance to enrollees in gaining access to needed waiver, medical, social, educational and other services. Case management includes comprehensive assessment; treatment planning and plan of care development; service coordination; monitoring; and collateral contacts with persons involved and/or designated by the enrollee.”

    “Case management and assistance to individuals and families in planning, developing, choosing, gaining access to, coordinating and monitoring the provision of medical, social, educational and other services and supports, including planning, advocacy, monitoring and supporting them to make and assess their own decisions.”

    The specific definitions of Vermont case management services, by program, are listed in attachment F (page 120) of the Vermont 1115 Global Commitment to Health Waiver.

  • Case Managers (also called Service Coordinators) help people with accessing services and supports. There are different parts of case management. Sometimes teams help people with these tasks (it is not always one person who does everything.)

    In Vermont, case management:

    • Helps people get services they may need
    • Assesses needs (the way programs figure out what someone needs)
    • Creates and updates person-centered plans (thinking about what is important to and for a person and making a plan for supports and services)
    • Coordinates across different services
    • Makes sure services are being delivered and are working for the person
    • Connects with people who are important in the person’s life
  • Functions that must be independent from direct service delivery:

    • Eligibility evaluations/determinations
    • Needs assessments
    • Development and oversight of the person-centered plan (including service referrals)

    And the people delivering those functions must not have other conflicts:

    • May not be a family member of the participant or a paid caregiver
    • May not have legal power to make financial or health-related decisions
    • May not be financially responsible for the participant
    • May not have a financial interest in organization(s) paid to provide services
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