Page 7 Conflict of Interest – has not been changed although there is contradicting information: Please clarify this: ‘Pursuant to 42 CFR 441.301(c)(1)(vi), … and/or develop person-centered plan of cares in a geographic area also provides HCBS.

In order to meet this requirement an individual that provides case management services must not be employed (directly, or as a contractor) by an entity that provides other HCBS services.

Furthermore, an individual or entity that provides case management/support coordination services must not have an interest (as defined in 42 CFR 411.354) in a provider of other HCBS services.’

While throughout the development of TCM services this COI was emphasized, in the most recent meeting with DMAS is was said at three different occasions that an agency could provide both, TCM and other direct brain injury services but the agency could not provide TCM and other services to the same person.

This is contradicting information and has great consequences for the current brain injury providers.

Does either one applies to all providers (including CSBs)? It should, otherwise it will create an unfair (financial) situation between CSBs and all other service providers which will be certainly interesting to all stakeholders.