Governor Signs Conflict Free Case Management Bill

Bill reduces conflicts of interest in management and delivery of HCBS waiver services


June 5, 2017

Media Contact:
Marc Williams

Denver, CO - Today Governor Hickenlooper signed HB17-1343 into law which allows Health First Colorado (Colorado’s Medicaid program) members to select the agency providing their case management services for home and community based services (HCBS), separate from those providing direct, ‘hands on’ services for the member.

Historically, case management services and direct services have often been provided by the same person or organization. If a Health First Colorado member or guardian had a concern or complaint about the services received, often the complaint would be heard or decided by the same agency providing direct services, which created a conflict of interest. This legislation eliminates conflicts of interest and better assures the needs of approximately 45,000 Health First Colorado members are met.

“Colorado has been working on issues related to conflict free case management with our state, federal and community partners for more than ten years,” said Susan E. Birch, MBA, BSN, RN, executive director for the Department. “This bill helps people choose who provides their case management services, and helps move Colorado toward a long-standing goal of conflict free case management and into compliance with federal regulations.”

In March 2014, the Centers for Medicare and Medicaid Services implemented a final rule requiring states to separate case management from service delivery functions to reduce conflicts of interest for services provided under home and community-based services waivers. This rule addresses conflicts of interest that may arise when one entity is responsible for both performing case management functions and providing direct services.

Community Centered Boards (CCBs) are currently the only entities in Colorado that conduct targeted case management for individuals with intellectual and developmental disabilities, and most also provide or contract for direct services for individuals enrolled in the HCBS waivers. CCBs can continue offering case management and direct services, but cannot provide both services to the same individual. This legislation allows for the creation of case management agencies whom members would select to provide their case management.

“Sometimes the CCBs are the only provider in our rural and frontier communities,” said Gretchen Hammer, Medicaid director. “We believe this bill gives the state flexibility and safeguards to ensure persons in those communities will maintain access to services.”

HB 17-1343 was sponsored by Rep. Dave Young (D-Greeley) and Sen. Dominic Moreno (D–Commerce City) and widely supported by many Colorado organizations that advocate for people with intellectual and developmental disabilities.


About the Colorado Department of Health Care Policy and Financing: The Department administers Health First Colorado (Colorado's Medicaid Program) and Child Health Plan Plus as well as a variety of other programs for Coloradans who qualify. For more information about the Department, please visit