HCBS-COI Recommendations

Vermont HCBS-COI Recommendations

The Vermont Agency of Human Services 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 and their families. Conflict of Interest (COI) occurs when the interests of an organization or an individual could compromise the judgment, decisions, or actions taken on behalf of people served.  

Vermont has developed recommendations for the delivery of case management for each of the three Medicaid HCBS programs of the Department of Disability, Aging and Independent Living (DAIL). There are different recommendations for each of the DAIL programs, to meet the unique needs of each population. There will be more details about these changes in coming months, and the state will want input on those decisions. All options that the State chooses will have to be approved by the federal Medicaid agency (CMS).

Stakeholders were invited to provide feedback on these Recommendations from December 15, 2023 to January 26, 2024 through in-person and virtual public forums, online surveys, mail-in surveys, letters, and website comments. A summary of public feedback is available here.

The information below and on the linked pages describes the recommendations. We have also created a set of FAQs related to the recommendations. You can find the FAQs by clicking here.

For more information about the history of this process and this project, please visit this page.


To learn more about each program recommendation, 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

Principles of the HCBS-COI Redesign

As a result of this process, certain HCBS activities and who completes them may change.  Vermonters who need home and community-based services (HCBS) will have equal opportunity to: 

    • Learn about service and support options from a neutral, trusted source.  
    • Access publicly funded services through an easy-to-use, unbiased and equitable process.  
    • Be empowered and supported to make informed choices about a range of available services
      and supports and who delivers them, such as opportunities to live at home or in the community.  
    • Participate in person-centered planning and services that respect and encourage
      self-determination, independence, growth, dignity, individual preferences and goals. 
    • Feel confident about the quality of services and supports, including the focus on individual
      health and welfare, integration and coordination of care, and participants’ rights.  
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