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

For questions regarding this effort, please email

  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.

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 implementation plan last updated on March 11, 2024
Implementation plan last updated on March 11, 2024. 

Providers and community partners are invited to share the below resources in multiple languages with program participants. 

Understanding Medicaid Conflict-Free Case Management: Learn more about what this change means for older adults and people with intellectual or developmental disabilities in 2024. English | Spanish | Portuguese | Arabic | Cape Verdean Creole | French | Haitian Creole | Khmer | Laotian | Russian | Simplified Chinese | Swahili

Roles and Responsibilities Under CFCM: What It Means for Long-Term Services in Home and Community-Based Settings. English | Spanish | Portuguese | Arabic | Cape Verdean Creole | French | Haitian Creole | Khmer | Laotian | Russian | Simplified Chinese | Swahili

Document Link Description Issue Date
RI EOHHS Conflict Free Case Management (CFCM) Certification Standards  Final certification standards for CFCM January 12, 2024
RI EOHHS Conflict Free Case Management (CFCM) Certification Standards Application Application to become a certified CFCM January 12, 2024
Response to Draft CFCM Certification Standards Comments RI’s responses to public comments on the draft CFCM certification standards January 12, 2024
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 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
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

Small Group Listening Sessions

RI EOHHS in collaboration with BHDDH, OHA and DHS hosted 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