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:

RI EOHHS will transition HCBS participants into CFCM throughout CY 2024. 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.

CFCM timeline

Implementation plan last updated on November 30, 2023. 

For questions regarding this effort, please email

Program Materials

Document Link


Issue Date

Shared Living Roles and Responsibilities Under CFCM

Draft overview of the Shared Living Roles and Responsibilities under CFCM

November 10, 2023

RI Person-Centered Plan Template

Person Centered Plan Template for HCBS participants

November 14, 2023

Roles and Responsibilities Under CFCM 1 Pager

Draft one-page summary of roles and responsibilities under CFCM

October 27, 2023

Roles and Responsibilities Under CFCM

Draft overview of roles and responsibilities under CFCM

October 27, 2023

Certification Standards for Conflict-Free Case Management (CFCM)

Draft certification standards for CFCM

October 2, 2023

RI CFCM Rate Setting

Rate Development for CFCM Implementation

October 16, 2023

RI CFCM Flyer for Participants

High-level summary of CFCM for participants

September 8, 2023

CAP Implementation of CFCM

RI’s corrective action plan with CMS to implement CFCM

November 2, 2023

RI CFCM Strategic Plan

Detailed summary of RI’s approach to CFCM

April 14, 2023

RI CFCM Fact Sheet

One-page summary of CFCM

September 8, 2023

RI Conflict of Interest Fact Sheet

One-page summary of federal conflict of interest requirements

September 8, 2023

Corrective Action Plan (CAP) Letter from Centers for Medicare & Medicaid Services (CMS)

Letter from CMS requiring RI to develop and implement CFCM

March 21, 2023

RI CFCM Decision Matrix

Summary of the State’s rationale for its CFCM design

September 8, 2023


Stakeholder Meetings

Upcoming Community Meetings

December 2023: Thursday, December 14th, 2023 from 9:00 AM to 10:00 AM

Registration Details

The link to register for the Zoom virtual meeting is CFCM Stakeholder Meeting 12/14/23.

After registering, you will receive a confirmation email containing information about joining the meeting. 

Small Group Listening Sessions

RI EOHHS in collaboration with BHDDH, OHA and DHS will be hosting small group listening sessions on conflict free case management (CFCM) with the goal of reviewing materials and discussing key roles and responsibilities of all stakeholders once CFCM is implemented.

Previous Community Meetings