Managing Conflicts of Interest in SHIP, SMP, and MIPPA Programs

As the Medicare population grows, the networks serving them continue to feel conflicting pressures as they seek to serve as many individuals as possible, adhere to federal funding and policy requirements, and identify innovative funding streams. Organizations that house the State Health Insurance Assistance Program (SHIP), Senior Medicare Patrol (SMP), and the Medicare Improvements for Patients and Providers Act (MIPPA) programs must be especially conscientious in navigating these pressures, as their Team Members are tasked with providing unbiased, objective information to Medicare-eligible individuals on their health insurance options.

To assist with addressing these challenges, the Administration for Community Living convened a workgroup starting in the fall of 2019 to draft guidance and resources for the SHIP, SMP, and MIPPA networks and community partners.  This workgroup was comprised of representatives from SHIP, SMP, and MIPPA programs at both the state and local levels; area agencies on aging; national network partner organizations; and ACL. The workgroup met monthly over the course of nine months and provided thoughts, feedback, examples, and suggestions which were used to develop a grantee guidance document. 

The guidance document, Conflict of Interest: Identification, Remedy, and Removal, provides technical assistance to SHIP/SMP/MIPPA programs and their partner Community-Based Organizations (CBOs) on how to avoid actual and perceived Conflicts of Interest (COI) and mitigate risk. The ACL Office of Healthcare Information and Counseling’s (OHIC) intention in preparing this resource is not to be prescriptive, as we know that each state and scenario is different, but instead to provide identification and remedy or removal strategies to help support grantees' risk mitigation efforts. Nor is this document intended to discourage grantees or CBOs from forming new partnerships or contracts when appropriate.

The purpose of this document and related technical assistance is to support grantees in identifying and mitigating risks in administering their SHIP/SMP/MIPPA programs. Responsibility for managing COI risk falls on the SHIP/SMP/MIPPA grantee, not upon ACL. All information provided within this resource impacts not only the direct SHIP/SMP/MIPPA grantees, but also each entity receiving sub-awarded or pass through funding.

Questions and technical assistance requests can be sent to OHIC@ACL.hhs.gov.


Last modified on 07/23/2020


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