I know the general theorem of Kadeishvili which says that, for a DGA $C$, when $H^{i}(C)$, $i\geq 0$, is free, $H(C)$ can be made into an $A_{\infty}$ algebra. If my understanding is correct, the proof essentially uses the freeness of $H^{i}(C)$ to produce a section $$s:H(C)\to C$$ of the projection $p:C\to H(C)$. Then a choice of chain homotopy between the identity and $sp$ can be used to define the maps $$m_{i}:\otimes^{i}H(C)\to H(C).$$ It is not hard to see that these give you an element of the higher Massey products (when defined).
Here is my question: When $H^{i}(C)$ is not free, is there any good way to define an $A_{\infty}$ structure on $H(C)$? It seems that the fact that one has an actual chain homotopy is crucial to the construction and in general $p$ may only be a quasi-iso. I hope this question is not too elementary (I am still a lowly graduate student). It just seems odd to me that the higher Massey products can be defined in general, even for torsion $H(C)$ (as long as the lower ones vanish) but one may not be able to identify these with a full $A_{\infty}$ structure.