Forensic Accountability Report November 16, 2023 Formal Complaint to the Federal Trade Commission: Unethical Practices and Possible Kickback Schemes in Connecticut’s Medicaid Acquired Brain Injury (ABI) Waiver Program
Permanent Public Record – David-Medeiros.com Accountability Archive
Published / Last Updated: February 18, 2026
Author: David Medeiros, Brain-Injury & Stroke Survivor, Founder & Provider, ABI Resources – Medicaid Acquired Brain Injury (ABI) Waiver Program
WHO
Complainant: David Medeiros, brain-injury and stroke survivor, founder/owner/CEO/Director/Team Member of ABI Resources, a Medicaid ABI Waiver Program provider.
Recipients: Federal Trade Commission (FTC) – Electronic Filings, Office of Inspector General (OIG), Antitrust Division.
Subject Entities: Unnamed agency providing both Clinical Behavioral Therapy (CBT) and daily non-medical services to the same ABI Waiver consumers; broader Connecticut Department of Social Services (DSS) oversight.
WHAT
Formal 11-page complaint alleging systemic unethical practices: dual-service conflicts of interest, therapeutic recommendations overlapping with financial gain, manipulative consumer steering, staff poaching, cyclical billing, and potential kickback arrangements. These actions allegedly harm ethical providers like ABI Resources (revenue loss, increased marketing/legal costs, reputation damage) and undermine consumer choice, program integrity, and Medicaid compliance.
WHEN
November 16, 2023, 3:17 PM: Complaint email sent with 11-page PDF attachment.
December 28, 2023, 1:44 PM: FTC read receipt confirmed.
WHERE
Submission: Electronic filings to FTC (federal antitrust/consumer protection authority).
Program context: Connecticut Medicaid ABI Waiver Program administered by DSS.
Public Archive: David-Medeiros.com – Accountability Archive.
WHY
To expose practices that appear to breach ethical standards, Medicaid regulations, antitrust laws, and the public trust in a federally funded program serving vulnerable brain-injury survivors. The goal is to protect consumers, ethical providers, and taxpayer dollars while ensuring fair competition and person-centered care.
HOW
The complaint systematically documents:
An agency using CBT sessions to recommend its own non-medical services.
Steering consumers away from other providers.
Poaching staff to weaken competitors.
Creating cycles of unnecessary or excessive services for financial gain.
Formal requests for investigation, corrective action, policy overhaul, and enhanced oversight by multiple Connecticut agencies.
Detailed Forensic Timeline
November 16, 2023, 3:17 PM: Email sent to electronicfilings@ftc.gov, oig@ftc.gov, antitrust@ftc.gov (Bcc: self).
Attachment: 11-page PDF complaint.
Read Receipt: Confirmed opened by FTC on December 28, 2023, 1:44 PM.
Core Allegations (Preserved Verbatim from the 11-Page Complaint)
Dual Service Conflict: Agency provides both CBT and non-medical services to the same consumers, creating financial incentives to recommend additional services it controls.
Manipulative Consumer Steering: CBT providers direct consumers toward the agency’s own services, undermining autonomy and informed choice.
Staff Poaching: Agency poaches personnel from competitors, disrupting operations and consolidating market power.
Potential Kickback Arrangements: Referrals appear driven by incentives rather than consumer need, leading to overutilization and inflated Medicaid costs.
Impact on ABI Resources: Significant revenue reduction, increased marketing and legal costs, erosion of consumer trust, and reputation damage.
Direct Harm Analysis (Multi-Angle View)
To Consumers with ABI/TBI: Reduced choice, potential over-service, biased recommendations that may not prioritize their best interests.
To Ethical Providers (ABI Resources): Revenue loss, higher operational costs, damaged relationships, and competitive disadvantage.
To Taxpayers: Risk of unnecessary Medicaid expenditures from overutilization and inefficient service allocation.
To the Broader System: Undermines fair competition, ethical standards, and public trust in the ABI Waiver Program.
Edge Cases & Nuances
Even if no explicit cash kickbacks exist, the structural conflict (same agency controlling therapy and non-medical services) creates the appearance of impropriety, which antitrust and Medicaid rules are designed to prevent.
Staff poaching, while sometimes legal, becomes problematic when used strategically to weaken competitors in a limited market serving a protected class (disabled individuals).
For a brain-injury survivor running a provider, the stress of these practices exacerbates TBI symptoms while simultaneously limiting their ability to advocate effectively.
Bigger-Picture Constitutional, Whistleblower, ADA, Medicaid & TBI Context (For the World)
This complaint is part of a larger pattern documented across multiple federal and state filings:
Constitutional Right to Petition: Filing with FTC is protected speech and petitioning for redress. Retaliatory market manipulation chills this right.
Whistleblower Protections: Reporting potential fraud/kickbacks in a federally funded program triggers federal safeguards.
ADA Obligations: As a disabled provider and advocate, David Medeiros is entitled to reasonable accommodations and protection from retaliation when exposing barriers affecting the TBI community.
Medicaid Integrity: Federal dollars require transparency, fair competition, and person-centered care. Alleged kickbacks and steering violate these principles.
TBI/ABI Realities: Cognitive and communication challenges make self-advocacy harder; systemic barriers compound the disability itself.
When one small ethical provider is allegedly squeezed out while consumers are steered toward a single agency, the entire national model of community-based disability services is tested. This affects millions of Americans with disabilities, their families, ethical providers, and every taxpayer.
All source emails, read receipts, and the full 11-page complaint PDF 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
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