Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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6/8/23  2:27 pm
Commenter: Lisa McCarthy, Brain Injury Services

Conflict of Interest

There is continued confusion regarding the Conflict of Interest provision and there are two vastly different interpretations of the conflict of interest statutes.  Initially the workgroups were told by DMAS, that a provider could not be a provider of Targeted Case Management and a provider of other HCSB services.   Then, more recently, we have been told that the conflict of interest is related only specifically to the person enrolled in services and that a provider could not provide both case management services and other HCBS services to the same enrolled person.    Under this interpretation, a provider could provide both case management and other HCSB services, just not to the same individual at the same time.  These are extremely different scenarios, and we need this clarified and applied to all providers of TCM.  

CommentID: 217112