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Seeking Clarity on Conflict of Interest Rules

Armed with ample member input and questions from the field, n4a staff met with a broad cross-section of top CMS officials this week to discuss the conflict of interest (COI) rules that are causing numerous concerns across the country as states move to implement the new standards. 

Speaking to eight CMS officials across several LTSS and managed care teams, n4a CEO Sandy Markwood and staff explained the Aging Network's role in supporting a person-centered HCBS system, including the Network's history of proper firewalls and other mechanisms to prevent conflicts of interest from occurring.
n4a then raised concerns about the federal guidance on the COI rules, how states were interpreting those rules and the implications for consumers served by the Aging Network. Several examples of potential state overreach or misinterpretation were shared and n4a intends to document additional questions and concerns in follow-up correspondence with CMS. If your state's AAAs have not already shared your most burning questions with n4a's Autumn Campbell, it's not too late. This is a very complicated issue, as the answer to a conflict of interest question depends, at the very least, on the state's take as well as the authority or program (e.g., fee-for-service vs. managed care, specific waivers vs. state plan, etc.).
n4a will continue its advocacy to secure greater clarity and/or guidance from federal officials and we are working to identify strategies for AAAs to ensure compliance while meeting consumer needs. The April 25-26, 2016 Aging Policy Briefing will also feature a COI pre-conference session. 
 

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