Conflict Free Case Management

The efforts of the Department to comply with federal requirements of Conflict Free Case Management (CFCM) have evolved into several initiatives that will help make accessing long-term services and supports easier by changing case management agencies to serve all HCBS waivers so people have one place to go, making sure there are the right number of case management agencies in Colorado, and increasing the quality of case management services.

Visit the Case Management Redesign webpage for more information.

CFCM prohibits the delivery of Case Management Support and Home and Community Based Direct Services by the same agency or entity.

The sections below explain why these changes are being made and how they may impact individuals receiving home and community based services (HCBS), their families, case management agencies, and direct service providers.

Federal Regulations regarding Conflict Free Case Management

Pursuant to authority provided by 1915(c) of the Social Security Act, the Department has established contractual agreements about services and supports provided to eligible individuals with Intellectual and/or Developmental Disabilities. Commonly called Medicaid Waivers, the federal government, through the federal Centers for Medicare and Medicaid Services (CMS), provides approximately 50% of the total funding for these Medicaid Waiver services.

The federal Centers for Medicare & Medicaid Services passed a final rule (42 CFR ยง 441.301(c)(1)(vi)) in March 2014 requiring separation of case management and direct services. Colorado must comply with this rule to continue receiving these funds. View the pertinent portions of the final rule and or view the entire rule citation.

House Bill 15-1318 and the Report on Conflict Free Case Management

The Colorado General Assembly passed House Bill 15-1318 in the Spring of 2015. In addition to directing the Department to create a combined Medicaid waiver for adults with Intellectual and/or Developmental Disabilities, the legislation directed the Department to create a plan, in consultation with stakeholders, for how it will comply with the federal regulations regarding Conflict Free Case Management. The plan was submitted to the Joint Budget Committee of the Colorado General Assembly on July 1, 2016.

Conflict Free Case Management Task Group

The Conflict Free Case Management Task Group met in 2014 to develop recommendations for consideration by the Department regarding a process to establish a conflict free-case management model for people enrolled in the Home and Community Based Services (HCBS) waiver for persons with a Developmental Disability (HCBS-DD) the HCBS Supported Living Services (HCBS-SLS) waiver, and the HCBS Children's Extensive Support (HCBS-CES) waiver. The group published a final recommendation report in 2014 to the Department. This group is no longer actively meeting. 

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