As part of the 2014 home and community-based services (HCBS) final rule, the Centers for Medicare and Medicaid Services (CMS) established requirements for conflict-free case management for Medicaid beneficiaries obtaining HCBS, generally requiring that case management activities, including the assessment and coordination of services, be independent from the delivery of HCBS services.
The intent of these requirements is ultimately to promote consumer choice and independence by limiting any conscious or unconscious bias by a case or care manager when assisting a consumer in identifying HCBS needs and developing plans to access services (i.e., preventing a care manager from steering consumers to the agency where they are employed).
To ensure compliance with the final rule and prepare Behavioral Health I/DD Tailored Plans and providers for the July 2022 launch of Tailored Care Management, NC DHHS is releasing guidance for ensuring conflict-free Tailored Care Management for Tailored Plan members. This guidance will apply to members enrolled in the 1915(c) Innovations and Traumatic Brain Injury (TBI) waivers or members who obtain HCBS authorized via the 1915(i) State Plan Option, as described in more detail in this document.
To share feedback or questions related to the conflict-free care management guidance, please email Medicaid.TailoredCareMgmt@dhhs.nc.gov. For more information about Tailored Care Management, please visit: https://medicaid.ncdhhs.gov/transformation/tailored-care-management.