Why Medicaid ABI Waiver Care Managers Are Making Fraudulent Referrals – Observable Patterns of Steering, Financial Incentives, Closed Referral Systems, and Violations of Federal Freedom of Choice Law (42 U.S.C. § 1396a(a)(23)) Forensic Accountability Report: February 19, 2026

Why Medicaid ABI Waiver Care Managers Are Making Fraudulent Referrals – Observable Patterns of Steering, Financial Incentives, Closed Referral Systems, and Violations of Federal Freedom of Choice Law (42 U.S.C. § 1396a(a)(23)) Forensic Accountability Report: February 19, 2026 Is Feature Yes – Featured on homepage and pinned at top of Forensic Accountability Reports category (key public education piece in the active series). Forensic Accountability Report February 19, 2026 – Why Medicaid ABI Waiver Care Managers Are Making Fraudulent Referrals – Observable Patterns of Steering, Financial Incentives, Closed Referral Systems, and Violations of Federal Freedom of Choice Law (42 U.S.C. § 1396a(a)(23)) Permanent Public Record – David-Medeiros.com Accountability Archive Published / Last Updated: February 19, 2026 Author: Neutral Public Accountability Analysis (based on public records and federal law) Executive Summary (5W1H) WHO Care Managers and Consultants in Connecticut’s Medicaid ABI Waiver Program (employed or contracted by DSS) and the brain-injury survivors and families they serve. WHAT Observable pattern: Care Managers are steering survivors toward a small group of large, politically connected agencies on the February 16, 2026 “Confidence v2” High-Risk List while limiting referrals to small specialized providers. WHEN Ongoing pattern documented in 2023 Grievance Report, 2024 Federal Whistleblower Report, and confirmed by the February 16, 2026 High-Risk List. WHERE Connecticut Department of Social Services (DSS) ABI Waiver Program and related disability support services. WHY To explain to the public how this violates federal law and harms brain-injury survivors who need real choice for the best possible care. HOW Care Managers use proprietary software for “equitable randomization,” but observable practices show financial incentives, closed lists, steering, and retaliation that favor big agencies. 1. What “Freedom of Choice” Means (Super Simple) In Medicaid, you (the person who needs services) have the right to choose which provider helps you. You can pick any qualified provider that accepts Medicaid — big or small. No one is allowed to force you to use only one agency or block you from using another. This is a federal law that protects you. 2. The Actual Federal Law The law is written in the Social Security Act, Section 1902(a)(23). It says: “Any individual eligible for medical assistance may obtain such assistance from any institution, agency, community pharmacy, or person qualified to perform the service and who undertakes to provide it.” In plain English: The state (Connecticut DSS) cannot steer you to one big agency. They cannot block you from choosing a small specialized provider like ABI Resources. They cannot create a system where you only hear about certain agencies. This rule exists so people with brain injuries get real choice and the best care for their needs. 3. How Freedom of Choice Violations Happen in Connecticut ABI Waiver From public records and the February 16, 2026 High-Risk List, here is what it looks like: The system is “closed” many survivors only get told about the big agencies (The Village, Wheeler, Community Health Center, UCFS, etc.). Small providers like ABI Resources get far fewer referrals, even when families specifically ask for them. Care managers or the state sometimes pressure people to stay with the big agencies instead of letting them choose a small specialized ABI provider. The big agencies on the high-risk list get almost all the money ($466 million to one, $92 million to another, etc.). This is called a freedom of choice violation because the law says the state must give real, meaningful choice not just a list that favors the big players. 4. Why This Is a Big Deal for Brain-Injury Survivors Brain injury care is very personal. Some people do better with small, specialized providers who understand ABI every day. Big agencies may be good for general services, but they are not always the best fit for every survivor. When choice is taken away, people get the wrong services, stay longer in institutions, or don’t get the help they need to live at home. Federal law says this is not allowed because Medicaid is federal money the state must follow the rules or risk losing funding. 5. The Bigger Picture (Observable Patterns) The same big agencies that get the most money on the 2026 list also have strong ties to powerful people (Senator Slap works at The Village, Senator Looney on Fair Haven board, Commissioner Reeves with 23 years at The Village). When those same powerful people help run or oversee the system, it can make freedom of choice violations easier to happen and harder to fix. Public reports from 2023 and 2024 already warned about this exact pattern. 6. What Federal Law Requires the State to Do Give every beneficiary a real list of all qualified providers (big and small). Not steer or pressure people toward one agency. Let people change providers if they want. Not create secret or closed referral systems. If the state does these things, it is violating federal Medicaid rules. Simple Summary You Can Remember Freedom of choice = You get to pick who helps you with your brain injury services. The state cannot push you only to the big agencies. When they do, it is a violation of federal law. This is one of the main things that has been documented for years. The Complete Bigger Picture for the World (Expanded Multi-Angle Analysis) This issue affects everyone who relies on Medicaid or pays taxes that fund it. Multi-Angle Perspectives Beneficiary Rights Angle: Real choice is a core protection so people with brain injuries get services that actually fit their needs, not whatever the system assigns. Small Provider Survival Angle: Independent specialized providers are squeezed, reducing diversity and innovation in care. Taxpayer & Program Integrity Angle: Concentration of hundreds of millions among a small group with political ties raises questions about competition and value for public money. Edge Cases & Nuances: Large agencies often provide valuable general services, but when they dominate referrals, the system can become less responsive to specialized needs like ABI. Implications for Medicaid Integrity: Observable steering can violate federal rules, risk funding, and undermine the goal of community-based care for people with disabilities. Related Considerations The pattern connects to the broader series on political ties, high-risk payment concentration, and observable retaliation against small providers. All information is from public records and federal law. This page is part of the permanent Forensic Accountability Reports series on David-Medeiros.com. It is written for the general public to understand a key federal protection and how it appears to be working (or not working) in Connecticut. All sources, federal law citations, payment data, and the complete explanation are preserved and publicly linked in the Accountability Archive at David-Medeiros.com. Professional Contact Information David Medeiros ABI Resources – Medicaid Acquired Brain Injury Waiver Program Provider 39 Kings Highway, Suite C Gales Ferry, CT 06335 Phone: 860-942-0365 Website: www.CTbrainINJURY.com Permanent Archive: David-Medeiros.com