Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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6/16/23  10:16 am
Commenter: James Vann

Conflict of Interest pg 5-6

The language used contradicts the language used in the last work group. COI was defined as specific to the individual and not the organization. This language allows an organization to have both HCBS and case management services, however they cannot support the same individual in both HCBS and case management. The language in this document clearly states that an organization providing case management services may NOT also provide HCBS. This contradiction is glaring and important to resolve given the structure of the current brain injury service system.

CommentID: 217280