Conflict of Interest Corrective Action Plan
Information and resources regarding the Corrective Action Plan (CAP) relative to three of the state’s 1915 (c) Home and Community Based Services (HCBS) Waivers through the Center for Medicare and Medicaid (CMS). The three 1915 (c) waivers under this CAP are: Developmental Disability, Acquired Brain Disorder, and Children’s In-Home Services.
06/06/2023: BDS shares Compliance Webinar Series and invites families to Information Sessions
06/06/2023: BDS shares Compliance Webinar Series and invites families to Information Sessions
BDS has developed the webinar series "Introduction to Direct Bill and Conflict-Free Case Management in New Hampshire's Developmental Disabilities Service System" to provide individuals and families an overview of the changes regarding Compliance and Direct Bill that go into effect July 1, 2023. After viewing the series links below, please join BDS at one of the Information sessions to learn more about the changes. Please view the invitation for more details.
BDS Systems Work Compliance Webinar Series, Spring 2023
- Session 1 - Introduction to Compliance (3:43)
- Session 2 - History of Compliance Initiatives (3:10
- Session 3 - Path to Compliance (5:01)
- Session 4 - Direct Bill Process (3:57)
- Session 5 - Conflict Free Case Management (4:57)
- Session 6 - Conclusion & Key Takeaways (1:25)
- Session 7 - Family Information Sessions (0:42)
10/28/2020: CMS Approves NH Request for Extension for Compliance with Conflict of Interest & Direct Billing Requirements
The Center for Medicare and Medicaid Services (CMS) has approved New Hampshire’s request to extend the date, from August 31, 2021 to July 1, 2023, for which the state must meet Home and Community Based Services (HCBS) waiver Conflict of Interest and Direct Billing requirements. The CMS Approval Letter memorializes the approval.
09/22/2020: Home and Community Based Services Waiver Extension Request
New Hampshire Department of Health and Human Services has requested that the Center for Medicare and Medicaid Services (CMS) extend the date, from August 31, 2021 to July 1, 2023, for which the state of New Hampshire must meet Home and Community Based Services (HCBS) waiver Conflict of Interest and Direct Billing requirements. The letter of request to CMS details the reasons for extension and the state’s continued commitment to working with federal partners to eliminate conflict of interest to support the people and families through the developmental services system.
New Hampshire is currently under a Corrective Action Plan (CAP) relative to three of the state’s 1915 (c) Home and Community Based Services (HCBS) Waivers through the Center for Medicare and Medicaid (CMS). The three 1915 (c) waivers under this CAP are: Developmental Disability, Acquired Brain Disorder, and Children’s In-Home Services.
The focus areas of the CAP are:
- Conflict of Interest regarding the provision of case management and direct service delivery; and
- Compliance with Direct Pay rules, which allow qualified Medicaid providers to bill directly to the State.
The Department of Health and Human Services has worked closely with CMS regarding compliance dates for the CAP. On October 28, 2020 CMS granted an extension for implementation of the CAP from August 31, 2021 to July 1, 2023 due to the significant impact of the COVID 19 pandemic.
Waivers are an essential and critical component for the delivery of services to individuals with disabilities and their families. Compliance is critical for continuation of this funding stream. The Department is working closely with NH stakeholders to move the CAP forward, while offering transparency and opportunity for feedback, and welcomes full participation in this process.
New Hampshire Home and Community Based Services (HCBS) Corrective Action Plan (CAP)
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Only Willing and Qualified Provider
- Only Willing and Qualified Provider (OWQP) Policy (02/20/2019, revised 09/30/2020, 01/19/2023, 11/7/2023, and 02/26/2024)
- OWQP Exemption Request Form (11/2023)
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Firewall Policy
- Firewall Policy (02/04/2019)
- Firewall Policy (02/04/2019)
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NH CAP for DD, ABD & IHS waivers
- NH CAP Completion Letter (03/25/2024)
- NH CAP Workplan Final (01/24/2024)
- Conflict Free CM Guidance (06/05/2023)
- NH CAP Guidance Memorandum (01/20/2023)
- NH CAP Template (CMS approved 04/21/2017, amended 04/27/2018 and 01/01/2023)
- NH CAP PDMS Guidance (01/23/2023)
- NH CAP Completion Letter (03/25/2024)
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Corrective Action Plan (CAP) Stakeholder Advisory Group
- Participant List
- Correspondences
- CAP Letter (09/10/2018)
- CAP Survey Letter (10/12/2017)
- CAP Letter (05/26/2017)
- CAP Letter (02/13/2017)