Recently there has been talk about eliminating the potential for conflicts of interest in the developmental disability services delivery system. This is related to the multiple roles that not-for-profit corporations hold, and consolidating case management to a state directed or other non Community Centered Board (CCB) system.
What is the potential for conflict of interest?
After 30 years of practice, the State of Colorado Departments of Human Services and Health Care Policy and Financing consider it problematic that not-for-profit corporations provide both Case Management as a Community Centered Board, and Direct Services as a Program Approved Service Agency. In general, the concern of potential for conflict of interest is that the Community Centered Board could in some way unfairly treat individuals or providers. As a result, the State set up a Conflict of Interest Task Force to determine how to resolve this structural potential for conflict of interest issue. The task force, including the Executive Directors of the ARC of Colorado and the Association for Community Living in Boulder County, voted to recommend that case management functions be performed completely independently from any service providers. Click here to see the Conflict of Interest Task Force Report.
What are Imagine!’s thoughts on the separation of case management and service providers?
Imagine! is aware of the potential of a conflict of interest inherent in the system of funding and delivering services for people with developmental disabilities in Colorado, and has always been proactive in taking steps to avoid and mitigate that potential (see below for more). That being said, there are many reasons Imagine! believes that there are better alternatives and the separation of case management and service providers is not the solution and this is not the time, including:
The evidence does not support the need for a change.
In 21 months of data, only 5 complaints (and none at Imagine!) of conflict of interest have been reported from over 21,000 individuals served by CCBs, and 97.2% of individuals receiving case management services reported they are happy with their present case manager. Additionally, the public comments given to the Conflict of Interest Task Force indicated that the large majority of the public, both family members and self advocates, did not want change in their current services or personnel, and that there was overwhelming support for the local availability of case managers, and that many people felt that the system is not broken. Even among members of the Conflict of Interest Task Force, there was not agreement that the separation of case management and direct services was necessary. The key recommendation of the report, that “ Service planning (case management) will be done by an entity (or entities) that can provide local availability of case management services and is independent, with separate finances and governance, from those entities responsible for eligibility determination or service provision,” was passed by a vote of the slimmest of margins, 9 for and 8 against.
There will be a negative impact on the individuals and families we serve.
If case management and service provider functions are completely separated, 21,210 individuals with developmental disabilities will no longer have their present case manager. The separation would likely create many separate entities for individuals and families to contact and work, adding another layer of difficulty to an already complicated service delivery system. Additionally, it would reduce the local responsibility, community interest, investment and connections that have made Community Centered Boards and service providers so successful over the last 30 years, especially with limited funding. Finally, 524 experienced case managers and related support staff specializing in developmental disabilities will lose their current jobs and benefits.
The financial impact has not been considered.
In addition to the Medicaid and State funds, Community Centered Boards bring in an additional $49.2 million dollars from cities and counties, grants and public support in revenue. This is 14.4% of the total revenue for the entire service delivery system. This revenue is used to provide services to additional individuals, enhance services for individuals enrolled in programs and supplement insufficient funding for state requirements. Splitting case management and service provision will put that revenue at substantial risk. Additionally, no financial analysis been made regarding the cost of this plan. Considering the State’s budget woes, this seems especially irresponsible.
The impact on rural communities has not been considered.
In some rural Colorado communities, there simply aren’t enough qualified providers to make the separation of case management and service provision feasible. It is already difficult for families and individuals with developmental disabilities living in rural Colorado areas to access services, and the proposed switch would likely only compound that problem.
This is not the time to take this action.
Considering all of the challenges currently facing the system of funding and delivering services for people with developmental disabilities in Colorado, the effort that will be required to separate case management from service providers appears to be a poor choice as to how the State should be investing time, energy, and money. For example, the developmental disabilities system in Colorado has endured millions of dollars of budget cuts in the past few years. And in 2006, the State switched from a managed care system to a fee for service system that resulted in a system where now services are directed to meet the needs of regulations and not the needs of the people served, which in turn has resulted in lower quality services that cost more. And currently more than 12,000 people with developmental disabilities are currently on a waitlist for services in Colorado.
What has Imagine! done to address the potential for conflict of interest?
Imagine! is committed to respecting individual choices and to helping individuals make choices or changes whenever possible.
Part of Imagine!’s contract with the State of Colorado states, “Upon client or guardian request, the contractor must provide an option for the client and/or guardian to request a different CCB to develop and monitor the Service Plan.” In other words, each CCB must have at least one alternative option for individuals/families to choose another CCB to serve in this case management role. Imagine! has joined with 14 other CCBs across the State in an agreement to honor requests for alternative case management provision from any other CCB. We believe this provides families with a wide and diverse selection of case management options.
At Imagine!, we also work with over 180 providers across Boulder and Broomfield counties to ensure that the individuals and families we serve can select the provider that best meets their needs, goals, and desires. To assist families in making informed choices, Imagine! publishes an annual “Guide to Services” that is featured prominently on our website. The guide provides information about the quality of services delivered by each Program Approved Service Agency Imagine! works with, including Imagine! provider organizations. The information includes provider profiles or websites, results of quality assurance evaluations, and customer satisfaction responses. The Guide to Services also providers a more in-depth explanation of provider choices and transferring funds procedures.
Additionally, as an organization dedicated to serving our community, we strive to be transparent in all our actions. Imagine!’s websites, social media sites, and newsletters are all designed to serve as resources to consumers, families who have a family member with a developmental disability, service providers, Imagine! employees, and members of the community at large.
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