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Conflict Free Case Management

On January 7, 2015 the board of directors for Community Support Network Inc. (CSNI) voted to adopt a “Protocol to Remove Conflict” in the provision of case management services for its member agencies. This protocol reflects current practice in the system.

Conflict Free Case Management is one of the three structural change requirements that apply to all states that have accepted grant funds from the Center for Medicaid Services (CMS) through the Balancing Incentive Program (BIP). CMS provides guidance for states on how to insure that case management is conflict free.

Protocol for Removing Conflict

New Hampshire’s developmental services system revised its regulations more than a decade ago to provide its consumers with choice and control over all aspects of their services, including selection of providers. Within that approach, consumers are able to choose their service case managers. Notwithstanding that opportunity, the great majority of the individuals currently receive their case management services from area agencies, geographically dispersed throughout the State, some of which also provide direct services.

Although NH regulations clearly articulate case management responsibilities, the current organizational arrangement of case management services can give the impression it is not “conflict-free” in all cases. Developing and adopting stronger conflict of interest standards for the State’s Developmental Services System could provide greater assurances to individuals and their families regarding the disposition, transparency, and integrity of the advocacy that their case managers would provide. For this reason the Protocol to Remove Conflict will insure that the following mitigating factors will be in place to remove conflict:

Assuring that individuals can advocate for themselves or have an advocate present in planning meetings.

Documentation that the individual has been offered choice among all qualified providers of direct services.

Establishing administrative separation between those doing assessments and service planning and those delivering direct services.

Establishing clear, well-known, and easily accessible means for consumers to make complaints and/or appeals to the State for assistance regarding concerns about choice, quality, and outcomes.

Having state quality management staff to oversee providers to assure consumer choice and control is not compromised.

Clinical/non-financial eligibility processes are conducted by personnel employed by the CSNI organization with recommendations to the area agency directors. Financial eligibility is determined by the Bureau of Developmental Services.

The NH Department of Health and Human Services has established Ombudsman program that serves as an independent and confidential resource to individuals and their families as appropriate.

Area Procedure for Protocol to Reduce Conflict

To download a copy of sample procedures designed for consideration by agencies in adopting practices that fall within the “Protocol to Reduce Conflict” for CSNI affiliated agencies, please use the link below.

Downoload PDF

Nine Elements for Conflict Free Case Management System

To download a copy of the Nine Elements for Conflict Free Case Management System, please use the link below.

Downoload PDF

Certificate of Agency Compliance

Area agencies across New Hampshire have implemented administrative practices that are in conformity with protocols to remove conflict regarding the provision of case management services. To see declarations of participating agencies, please use the link below.

Downoload PDF