HCBS-COI Options

Vermont HCBS-COI Options

The State of Vermont is working to redesign parts of the Home and Community-Based Services (HCBS) system to avoid conflict of interest issues and follow federal rules. The State also wants to make the system work better for people who receive services.

The State has developed different structural options for the delivery of case management for each of the five Medicaid programs that include HCBS.

The information below and on the linked pages describes these options. (For more information about the history of this process and this project please visit this page.) The State of Vermont received public feedback on the HCBS-COI options from August 11-September 15, 2023. The comment period is now closed, but you are always welcome to provide feedback through this form.

Feedback was provided through in-person and virtual public forums, online surveys, mail-in surveys, letters, and website comments. Over 1,000 responses* were received. The responses have been summarized here.

*Some people may have submitted a response to more than one option, so this count does not represent the number of individuals who provided feedback.

Important things to note about the Vermont HCBS-COI options

  1. This is one step in the planning process and system changes. There will be ongoing stakeholder input through mid-2025, when the new case management structures and approaches need to be in place.
    • The options presented here will begin to address the biggest changes that need to occur to address conflict of interest.
    •  There are many other important, detailed decisions that will also need to be developed with stakeholder input.
  1.  All options and policy decisions are subject to federal approval by the Centers for Medicare & Medicaid Services (CMS).
  1. Federal policy allows for some differences between Mental Health services and other kinds of HCBS.
    • Rehabilitative services are designed to support people with mental health conditions to get back or improve skills and functioning. These are often recovery-focused and delivered on a more episodic or short-term basis.
    • Ongoing home and community-based services are often habilitative. This means they are designed to help people keep, learn, or improve skills or functioning for daily living. These services are usually delivered on a long-term basis.
    • This difference allows for a different approach to address COI in the Department of Mental Health services than in the Department of Disability, Aging and Independent Living HCBS programs.
  1. Certain HCBS activities and who completes them may change.
    • It is important to remember that access to services and supports for participants is not expected to change. This will be true regardless of the HCBS-COI option or direction the state may choose.


To learn more about each program option, please visit:

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Brain Injury Program

HCBS for people with traumatic brain injury

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Choices for Care

HCBS for older adults and people with physical disabilities

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Developmental Services

HCBS for people with developmental disabilities

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