Area Agencies on Aging (AAAs) deliver an average of 28 vital services to older adults and caregivers in their communities.¹ AAAs offer information and referral services (86 percent), benefits and health insurance counseling (81 percent), case management (85 percent), and various meals and nutrition programs, such as nutrition counseling and farmer’s market vouchers (88 percent).² Overall, funds from the Older Americans Act (OAA) account for about 39 percent of AAA budgets, with more than half coming from health care contracts, other grants, private pay, cost sharing, and local, state and federal sources like Medicaid and the Veterans Administration.²

Many AAAs generate new revenue and expand their services to meet community needs by contracting with health care payers and providers. USAging’s Aging and Disability Business Institute (Business Institute) conducts periodic CBO–Health Care Contracting Surveys, in partnership with Scripps Gerontology Center at Miami University, which show that contracting between health care entities (such as health plans, health systems, accountable care organizations and more), AAAs, community-based organizations and community care hubs has increased significantly between 2017 and 2023.² In 2023 over 18 percent of AAAs, CBOs and CCHs with health care contracts indicated that they were providing public benefits outreach and enrollment assistance under those contracts. However, AAAs need to be aware of both perceived and actual conflicts of interest (COIs) when working with health care providers and payers, especially when counseling on health insurance options, to ensure their services remain unbiased.

Being aware of perceived and actual COIs is particularly important for organizations housing the federally funded State Health Insurance Assistance Program (SHIP), the Medicare Improvements for Patients and Providers Act (MIPPA) and Senior Medicare Patrol (SMP) programs. COIs can include a SHIP/SMP/MIPPA team member having an immediate family member with a financial connection to a plan, health system or provider group, or being a former or retired insurance agent or broker. Establishing clear and transparent processes to identify and manage these risks is the responsibility of organizations providing information and referrals for health insurance programs for Medicare recipients. The Administration for Community Living (ACL) offers a guidance document specifically for SHIP, MIPPA and SMP programs.³

As part of a pilot project, the Business Institute, in partnership with the National Council on Aging, developed the COI Action Plan to train staff to recognize and respond to perceived, potential, or actual COIs related to their benefits outreach and enrollment assistance work. The COI Action Plan can play a key role in establishing clear program policies and guidelines. It functions as a comprehensive tool for clarifying and reviewing methods for providing information, identifying COIs, and mediating them. The COI Action Plan outlines a step-by-step process for documenting and recording the staff member responsible for each action, as well as the specific steps taken during the identification and mitigation process. This tool demonstrates that an agency diligently reviews its health insurance counseling programs for COIs and can be used to showcase the agency’s accountability and integrity.

When providing benefits and counseling enrollment assistance, it is crucial to have training and procedures in place to prevent actual and perceived conflicts of interest, reduce risk, and establish clear identification, resolution or removal strategies. The COI Action Plan is one of several tools and best practices to help your organization address conflict of interest issues. The following ideas and practices from the field can help strengthen the COI process your organization develops.

Ideas for COI Remedy or Removal*

1. SHIP/SMP/MIPPA staff and health plan contracted activities are structurally delineated via staffing, leadership and financial firewalls.
2. Staff working on SHIP/SMP/MIPPA and contract work report through different chains of command.
3. Health plan contracts, funds or activities do not fund SHIP, SMP and MIPPA staff and supervisors.
4. Strict and strategic time commitment expectations are in place to eliminate the possibility of double-billing time.
5. Eliminate cross-training expectations or activities between SHIP/SMP/MIPPA staff and any work with health plans.
6. Institute the COI Action Plan for programs.
7. Conduct an annual COI review to ensure continued compliance.

*Christine Vanlandingham, CEO, Region IV Area Agency on Aging, an active SHIP site that contracts with a health plan to provide network management and long-term services and supports.

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.