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Conflict Free Access and Planning

The 2014 Home and Community-Based Services (HCBS) final rule established requirements for conflict-free case management for beneficiaries obtaining HCBS.

In Michigan, agencies can have more than one role: access, plan development, and service delivery. If one agency is helping you to access and plan your services while providing services, there could be a conflict of interest. A conflict of interest happens when a professional uses their role to benefit themselves or their employer. This conflict of interest may not be intended but could still affect your experience.

Conflict-Free Access and Planning (CFA&P) requires that assessment and coordination of services are separate from the delivery of services. This means that case management and support coordination activities are separate from the delivery of services.

The goal of CFA&P is to promote choice and independence for people receiving services. Your planning process should not be influenced by provider’s self-interests.

If you have questions or concerns regarding Conflict-Free Access and Planning, please send an email to

The Conflict-Free Access and Planning (CFA&P) workgroup serves to support MDHHS in creating new policies to protect beneficiary choice in behavioral health service delivery. The Conflict-Free Access and Planning workgroup includes representatives from MDHHS, PIHPs, CMHSPs and advocacy members.

CFA&P Workgroup 


Dana J. Moore

Specialist, Division of Adult Home and Community Based Services