August 2016 CFCM Implementation Presentation by HCPF DIDD Director and staff
Conflict Free Case Management (CFCM) is a federal requirement, under the Final Rule, from the Center for Medicaid and Medicare Services (CMS). Colorado is not in compliance and will be required to have an approved plan in place or risk approximately $250 Million in Federal monies (the Feds match the State contribution.)
Colorado's Healthcare Policy and Finance department (HCPF) has submitted the CFCM plan to the General Assembly (Colorado State Legislature) through the Joint Budget Committee. This CFCM implementation plan was funded using a consultant Navigant, via a contract funded through HB15-1318. This report is the first plan toward compliance with CMS's requirement to reduce the inherent conflict of interests when Colorado's 20 state Community Centered Boards (CCBs) are the sole provider for eligibility and targeted case management; another conflict is that most do also provide direct services. The federal Final Rule does has found this current Colorado arrangement in violation of the new Federal Final Rule for CFCM.
A copy of the July 1, 2016 Conflict Free Case Management Implementation Plan is below: