Conflict-Free Case Management

RI EOHHS is leading an interagency initiative to establish a statewide effort to provide conflict-free case management (CFCM) to Medicaid long-term services and supports (LTSS) beneficiaries who are participants in the State’s home and community-based services (HCBS) programs. A core component of this initiative is the establishment of a contractual network of qualified CFCM entities with the capacity to serve approximately 11,000 Rhode Island HCBS participants who have a varying and changing array of LTSS needs.

The CFCM initiative is one of several the State is pursuing as part of multi-faceted, multi-year LTSS redesign effort focusing on making the system more person-centered, quality-driven, and resilient. The CFCM initiative serves these broader goals and the more specific purpose of bringing Rhode Island into compliance with federal requirements governing the Medicaid HCBS programs authorized by the State’s Section 1115 Demonstration Waiver.

The goals of the CFCM initiative include:

Goal table

WHY CFCM is needed:  

  1. RI EOHHS is under a Corrective Action Plan with the Centers for Medicare and Medicaid (CMS) to deliver “conflict-free” case management and person-centered planning in accordance with CMS’s HCBS Final Rule (42 CFR 441.301). Approximately 7,500 or 75% of Rhode Island’s Medicaid HCBS participants, who fall under CMS’s HCBS Final Rule, receive case management that is not “conflict-free” (i.e., the same entity provides both eligibility assessment and enrollment service or case management services and direct services to a participant).
  2. There is inequity in HCBS participant access to high quality case management services. Approximately 2,500 or 25% of Rhode Island’s Medicaid HCBS participants, who fall under CMS’s HCBS Final Rule, receive no or limited service planning and case management.
  3. Case management delivery and quality is inconsistent across vendors.
  4. The State’s HCBS programs continue to function in administrative silos where different State agencies maintain separate business processes, approaches to oversight and monitoring, instruments, and IT systems for performing case management tasks.
  5. The State uses different reimbursement rates and units of service (e.g., 15-minute increments vs. monthly) for case management services. Current payment methods create the opportunities for conflicts of interest, steering, and uneven access and choice.

WHEN CFCM will happen:

Beginning January 1, 2024, RI EOHHS estimates that approximately 11,387 Medicaid HCBS participants are targeted to receive CFCM under this initiative. RI EOHHS will transition HCBS participants into CFCM throughout CY 2024 based on a HCBS Participant Transition Plan. RI EOHHS anticipates that all HCBS participants under this initiative will be enrolled in the CFCM services system by December 31, 2024.

The figure below provides a summary of the State’s implementation of CFCM. RI EOHHS will use this timeline for internal planning and project tracking. There are multiple factors influencing the State's implementation timeline including federal requirements and a BHDDH consent decree. At this time, RI EOHHS believes that its CFCM design and timeline is appropriate and attainable; however, as with any new program or service, it will regularly monitor its progress and course correct as needed based on CMS guidance.

milestone table

The above CFCM implementation plan was last updated on April 14, 2023.

The materials posted below provide additional context and information regarding Rhode Island’s implementation of CFCM.

Upcoming Community Meeting

You are invited to participate in a virtual community meeting on Tuesday, May 30th, 2023, from 10:00 AM to 11:30 AM to provide an update regarding the State’s implementation of Conflict Free Case Management (CFCM).

Meeting Purpose

The Rhode Island Executive Office of Health and Human Services (RI EOHHS) will address issues raised at the last meeting with the assistance of New Editions, our CMS technical advisory team. Short notice is due to New Editions limited availability.


The link to registering for the Zoom virtual meeting is CFCM Stakeholder Meeting 5/30/23    Click on the link to register. After registering, you will receive a confirmation email containing information about joining the meeting.    


If there are any specific questions you would like to have addressed during the meeting, please send an email with your questions to by, May 26th, 2023, end of day.

For questions regarding this effort, please email

Click here to view the 5.11.23 RI CFCM Stakeholder Meeting

Click here to view the 12.15.22 Conflict Free Case Management and Person-Centered Planning Community Meeting

Click here to view the 7.11.22 Conflict Free Case Management and Person-Centered Planning Community Meeting