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Committee hears DAIL plan for conflict-free case management and payment reform, full federal compliance due April 2026
Summary
The House Committee on Oversight and Accountability on Feb. 11 heard a detailed briefing from the Department of Disabilities, Aging, and Independent Living about implementing federally required conflict‑free case management and a new payment model tied to standardized assessments.
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The House Committee on Oversight and Accountability on Feb. 11 heard a detailed briefing from officials at the Department of Disabilities, Aging, and Independent Living about implementing federally required conflict‑free case management and a new payment model tied to standardized assessments.
Committee Chair Lloyd opened the session by noting the committee would “take up conflict free case management and payment reform at the Department of Disabilities, Aging, and Independent Living.” The presentation traced the changes back to Act 186 of 2020 and to a Centers for Medicare & Medicaid Services corrective action plan that requires Vermont to separate case management from service provision and to standardize assessments and budgets.
The changes matter because they affect how people with developmental disabilities and brain injury services are assessed, how budgets are set, and which organizations provide intake, case management and direct services. Dr. Gilbohan, Commissioner for DAIL, and payment‑reform staff said the aim is federal compliance while preserving individualized planning and minimizing service disruption.
Jessica Bernard, deputy director of payment reform with the Department of Disabilities, Aging, and Independent Living, told the committee the state’s current developmental‑services payment system “doesn’t have a standardized rate or needs assessment,” which limited the state’s ability to validate budgets and track service delivery. Bernard said the department worked with contractor Human Services Research Institute (HSRI) and identified six SIS‑A support levels that underpin the new budget ranges.
Under the plan DAIL described, intake eligibility and initial assessments will move to independent entities rather than remaining with designated and specialized service agencies (DSAs/SSAs). The state will use the Supports Intensity Scale–Adult (SIS‑A) as the standardized needs assessment and will consider additional contextual questions during person‑centered planning so that budgets reflect individualized circumstances. Case management will be a separate, billable service; program management and service coordination will remain with provider agencies.
Officials said the state budgeted about $8,600,000 in FY2025 for conflict‑of‑interest implementation components, including contracts for independent intake and assessments. Agencies and family members had asked for transition grant funding; department staff said transition grants and a procurement to select case‑management entities are underway.
DAIL staff described operational expectations: case manager caseload targets of roughly 30–34 for the new standalone case‑management entities (with higher or lower caseloads depending on participant acuity), a requirement that case managers be located within 60 minutes or 60 miles of the people they serve, at least one required in‑home visit annually, and program‑specific caseload ranges for Choices for Care (traditional ranges cited in testimony were roughly 35–50 for moderate‑needs work, with lower caseloads for high/highest needs). The department said Choices for Care case managers continue to coordinate annual assessments and person‑centered care plans for that population.
Committee members pressed staff on how many people might see budget changes when SIS‑A scores and budget ranges are applied. Bernard said preliminary modeling showed about 87–88% of people were likely to receive a budget consistent with current service levels; some individuals could receive more or fewer services based on the SIS‑A and the context questions. The department emphasized an exceptions process for individuals whose final person‑centered plan does not fit the assigned budget range.
DAIL offered a transition timeline the committee was shown: selection and announcement of case‑management entities in April 2025; open houses and enrollment beginning May–June 2025; initial SIS‑A assessments completed and funding assigned by July 2025; a transition period that the department said would largely end in September 2025 with service coordination converting to program management and case management becoming billable; lingering transition items to complete by December 2025; and full federal compliance required by April 2026.
Multiple legislators said they remained concerned about consumer and provider anxiety and asked for follow‑up briefings. The committee indicated the department may be asked to return for additional, likely virtual, briefings specifically on payment‑model details, provider impacts and the exceptions process.
The department and its partners requested continued communication with families and providers during the rollout; staff said additional mailings and a communications packet had been sent to providers and that direct mail to families would increase during the transition.
No formal committee action or vote was recorded during the session; staff presented the briefing and answered questions.
The committee closed the item by saying it would seek clarification on the statute’s requirement that the department “seek approval from the General Assembly prior to implementing a systemwide payment reform and conflict‑free case management” (Act 186 of 2020, section 6) and that legislative counsel be consulted about what form that approval must take.
The committee did not adopt any motions during the hearing; members asked the department to return with more concrete budget and provider‑impact information in a follow‑up meeting.

