The Business Institute, in partnership with the National Council on Aging, created the COI Action Plan to train staff to recognize and respond to potential conflicts of interest (COIs) during benefits outreach and enrollment. The plan provides a step-by-step process for documenting and addressing COIs, helping agencies establish clear program policies and demonstrate their accountability.
Having procedures to prevent and resolve conflicts of interest is crucial when providing benefits and counseling enrollment assistance. The COI Action Plan is a key tool for strengthening an organization’s COI process, helping to reduce risk and maintain integrity.
Endnotes
1 USAging. 2023 Chartbook-More older adults, more complex needs: Trends and new directions from the National Survey of Area Agencies on Aging, 2024. 2023 Chartbook–More Older Adults, More Complex Needs
2 USAging Aging and Disability Business Institute. 2023 at the nexus of social care: Successful contracting between CBOs and health care entities, 2024. 2023 At the Nexus of Social Care: Successful Contracting Between CBOs And Health Care Entities – Aging and Disability Business Institute
3 Administration for Community Living. Conflicts of interest: Identification, remedy and removal, 2020. OHIC COI Resource 071720- Final.pdf
September 2025
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This publication was supported by the Administration for Community Living (ACL), U.S. Department of Health and Human Services (HHS) as part of a financial assistance award totaling $14,707,650.00 with 100 percent funding by ACL/HHS. The contents are those of the author(s) and do not necessarily represent the official views of, nor an endorsement, by ACL/HHS or the U.S. Government.
The Aging and Disability Business Institute (Business Institute) produced this publication in partnership with the National Council on Aging (NCOA). Led by USAging in collaboration with the most experienced and respected organizations in the Aging and Disability Networks, the mission of the Business Institute is to build and strengthen partnerships between aging and disability community-based organizations (CBOs) and the health care system. The Business Institute provides CBOs with the tools and resources to successfully adapt to a changing health care environment, enhance their organizational capacity and capitalize on emerging opportunities to diversify funding. Learn more at www.aginganddisabilitybusinessinstitute.org.
NCOA is the national voice for every person’s right to age well. NCOA delivers the resources, tools, best practices and advocacy our nation needs to ensure that every person can age with health and economic well-being. Since 1950, NCOA has made improving the lives of older adults our passion and mission. NCOA helped end mandatory retirement and advocated to secure Medicare, Medicaid, the Older Americans Act and the Affordable Care Act.