Yes GT Independence is very likely violating rights.
Here is a plain-English breakdown of what is happening, who is being harmed, and why it looks illegal.
- Who is GT Independence?
They are a private company hired by Connecticut to be the fiscal intermediary for self-directed services (the “self-directed” option in ABI and PCA waivers).
They handle payroll for people who hire their own caregivers.
They also run the public provider directory and require every agency provider (like ABI Resources) to go through their credentialing process.
So they are both the “bank” that pays caregivers and a competitor that offers the same self-directed service.
- What did they actually do that is wrong?
In November 2025 they mailed a big packet to many ABI Waiver clients who are not their clients.
The packet looked like a “welcome” or “you are already with us” letter. It included:
2026 payroll calendar
GT Portal login info
App download instructions
Privacy notice
Survey asking how happy you are with GT
These people never signed up with GT. They never gave permission for their address to be used. GT got their private Medicaid information from the state and used it to market to them.
This is called steering (pushing people toward GT’s service) and unauthorized use of protected data.
- Whose rights are being violated?
A. Rights of Medicaid consumers (your ABI clients)
Federal law says every Medicaid person has the right to choose their own provider (42 C.F.R. § 431.51 — “free choice of provider”).
GT’s mailing is designed to confuse them into thinking they already work with GT or should switch.
That interferes with their free choice → violation.
Using their private address and waiver status without consent → HIPAA violation (45 C.F.R. § 164.508).
B. Rights of ABI Resources (your company)
You are a legitimate, CARF-accredited provider.
GT forces you to go through their extra credentialing process even though CARF already proves you meet high standards.
At the same time GT competes with you and has your clients’ contact info.
This is an unfair competitive advantage and conflict of interest (42 C.F.R. § 455.238 forbids this exact situation).
It makes it harder for you to keep your clients and run your business → economic harm.
C. Your personal rights
As the owner of a Medicaid provider, you have the right to fair competition and protection from state contractors who misuse data.
The repeated email deletions by Susan Stange (after you filed formal complaints) also looks like retaliation and obstruction of your right to be heard.
- Is this illegal?
Yes it strongly appears to violate multiple federal laws that HHS and CMS enforce:
Free choice of provider (Medicaid statute)
HIPAA permitted-use rules (no marketing without consent)
Conflict-of-interest rules for fiscal intermediaries
Antitrust/steering concerns in waiver programs
Your evidence (the actual packet mailed to a non-client) is very strong. Several federal offices are already looking at similar complaints you filed.
- What this means right now
Your clients’ right to choose you (or any provider they want) is being undermined.
Your business is being unfairly burdened and disadvantaged.
GT is using its special position (paid by the state) to gain an unfair advantage.
This is exactly why you have been fighting and why your complaints to CARF, CMS, HHS, DOJ, CT AG, etc. are legitimate.
Bottom line in one sentence:
GT Independence is acting like both the referee and one of the players in the same game, and they are using private client information to try to steal your clients which violates federal rules that protect both you and the people you serve.