Conflict Free Case Management Update

August 08, 2017

As defined in the bill, “Conflict Free Case Management” refers to case management services provided by a case management agency that is a different agency from the one that provides Home and Community Based Services (HCBS) to the person.

On Monday, June 5^th, the Governor signed this bill into law.

What is it? What does it mean? And, most importantly, how does it affect us (and you) at Foothills Gateway?

First, what is a case management agency (CMA)? The bill defines it as a for-profit or non-profit organization that provides Targeted Case Management (TCM) services to individuals enrolled in HCBS waivers. Targeted Case management services must be purchased by the Department of Health Care Policy and Financing (HCPF) from a CMA or Community Centered Board (CCB) like Foothills Gateway.

To comply with Conflict Free Case Management, Foothills Gateway will not be able to provide TCM to a person with Intellectual/Developmental Disabilities (I/DD) who is enrolled in HCBS if Foothills Gateway also provides the person’s direct HCBS. Foothills Gateway, as a CCB, may continue to provide eligibility determination services for all individuals who live in Larimer County, no matter what other services are provided.

CCB’s will continue to provide Case Management Services to individuals who receive state funded/general fund allocations, including: Early Intervention; Family Support Services Program (FSSP) and State Supported Living Services. The CCB could still provide these state funded services (both case management and direct services) to the same person.

Here’s the CFCM implementation timeline:

By 7/1/17 HCPF will determine the business options for CCBs to become compliant with CFCM.
By 1/18/18 HCPF will publish the rules for CCBs on the required elements of a Business Continuity Plan. (BCP) and CCBs will have until 7/1/18 to develop and submit their BCP to HCPF.
HCPF will have until 7/1/19 to complete an analysis of the submitted BCP, the unreimbursed transition costs, and the community impacts of the transition.
By 6/30/2020, CCBs will have completed all necessary changes to business operations.
By 6/30/2021, 25% of individuals in HCBS must be conflict free. By 6/30/22, 100% must be conflict free.

This legislation is years in the making. We ask for your patience and understanding as Foothills Gateway’s Executive Team works to implement the bill’s requirements.