Forensic Accountability Report (Nov. 13, 2023): CT DSS Denial of Access to Official Medicaid ABI Waiver Provider Directory

Forensic Accountability Report Denial of Access to Official Directory of Qualified Providers Medicaid Acquired Brain Injury (ABI) Waiver Program Freedom of Information Act (FOIA) Request – Connecticut Department of Social Services Acquired Brain Injury (ABI) Waiver Program Executive Summary (Who, What, When, Where, Why, How) WHO Requester: David Medeiros, brain-injury and stroke survivor, founder and owner of ABI Resources, a provider in the Medicaid ABI Waiver Program. Agency: Connecticut Department of Social Services (CT DSS), FOIA Officer. WHAT Formal FOIA request for the official Directory of Qualified Providers (both agency and private lists) for the Medicaid ABI Waiver Program, plus process/criteria documents, statistical data, policy manuals, internal communications, and records on public accessibility and procedure. DSS responses repeatedly claimed no access to the directory (despite oversight role), provided only the 2-1-1 map and partial policies, and directed the requester to Allied Community Resources. Multiple appeals highlighted two distinct directories, public interest, ADA accommodations for TBI, and transparency failures. Expedited processing requested on January 3, 2024 citing ADA, whistleblower protections, and urgency. Request remains unresolved. WHEN November 13, 2023: Initial FOIA request submitted. November 14–21, 2023: DSS partial responses and follow-ups. November 15 & December 12, 2023: Appeals filed with new evidence of two directories. January 3, 2024: Formal expedited-processing request due to TBI and public interest. WHERE Connecticut Department of Social Services, Hartford, CT (FOIA.DSS@ct.gov and FOI@ct.gov). All communications preserved at David-Medeiros.com. WHY The official directory is essential for disabled individuals and families to make informed choices about qualified providers under the ABI Waiver Program. Withholding it (or claiming no access) undermines person-centered planning, transparency, and accountability in a federally funded Medicaid program serving vulnerable brain-injury survivors. This directly impacts self-advocacy for a person with a documented brain injury who requires accessible formats and timely responses. HOW DSS consistently stated it “does not have access” to the directory maintained by Allied Community Resources, provided the 2-1-1 map instead, and required the requester to apply through Allied. Appeals with evidence of two separate directories (ABI Waiver Program 1 and 2) and ADA accommodation requests were not resolved. The pattern shows systemic barriers to public records despite legal obligations under FOIA and ADA. Detailed Forensic Timeline (Chronological, Evidence-Based) November 13, 2023 (6:52 AM): Initial FOIA request submitted for the Directory of Qualified Providers, process/criteria, statistical data, policy manuals, internal communications, and public accessibility records. Request explicitly notes need for accessible electronic format due to disability. November 13, 2023 (9:49 AM): DSS acknowledges receipt and states response will follow CT FOIA requirements. November 13, 2023 (10:02 AM): DSS provides partial response highlighting items and asks for clarification on item g (public accessibility records). November 14, 2023 (10:37 AM): DSS sends attached policy information, explains partial fulfillment, and provides second follow-up question in red. Reiterates 2-1-1 map for directory and refers credentialing to Allied. November 14, 2023 (2:11 PM): Detailed response from requester clarifying that 2-1-1 map is not the official directory, reiterating request for both agency and private provider lists in document format, and providing comprehensive breakdown of records sought for item g (creation, maintenance, presentation, public access, transparency). November 14, 2023 (3:53 PM): DSS responds that it does not have access to any directory records (maintained by Allied), provided 2-1-1 map as assistance, and considers most portions completed except statistical data. Directs requester to Allied application process. November 15, 2023 (6:25 AM): Formal appeal filed addressing portions a and g. Emphasizes public interest, agency oversight, transparency, and provides detailed records request for directory creation/maintenance/presentation/accessibility. November 15, 2023 (10:51 AM): DSS states it reached back out to Allied and was directed to submit formal request form (5–8 day turnaround). Working on direct contact. November 15, 2023 (11:05 AM): Requester provides Allied contacts (Valerie Giannelli, Nicole Simmons, Marihonor Flag) and notes concern that DSS does not have this information. November 16, 2023 (10:27 AM): DSS apologizes for confusion, confirms contacts, and states waiting for response from Giannelli and Flag who are out of office. November 21, 2023 (1:01 PM): DSS attaches “Provider Directory” and states still working on statistical data. December 12, 2023 (2:08 PM): Revised appeal filed after discovering two distinct directories (ABI Waiver Program 1 and 2) from Allied. Lists 8 grounds for appeal, reaffirms request for all related documents, and requests accessible electronic format due to disability. January 3, 2024 (12:19 PM): Formal request for expedited processing citing ADA reasonable accommodations for brain injury, whistleblower protections, public interest, and personal circumstances. Read Receipts Confirm Delivery of all appeals and expedited request to DSS FOIA and FOI offices. Core Allegations (Preserved Verbatim from Record) The official Directory of Qualified Providers for the Medicaid ABI Waiver Program is a vital public resource that must be accessible under FOIA for informed decision-making by individuals and families relying on the program. DSS responses indicate the directory is maintained by Allied Community Resources but do not provide it, claiming no access despite oversight role. This is incongruent with DSS responsibilities. Recent communications with Allied revealed two distinct directories (ABI Waiver Program 1 and ABI Waiver Program 2), each listing different providers and services, both provided and maintained by DSS. Due to brain injury, accessible electronic format is requested as a reasonable accommodation under the ADA. Expedited processing is sought due to compelling needs including ADA compliance, whistleblower protections, public interest, and urgency for self-advocacy. Direct Harm Analysis (Multi-Angle View) To the Requester (TBI Survivor): Repeated appeals and clarifications required due to partial/inaccurate responses created additional cognitive load, memory strain, fatigue, and processing delays the very barriers the ADA requires accommodation for. To ABI Resources & Other Providers: Lack of official directory hinders fair competition, transparency in referral processes, and ability to serve consumers effectively. To Consumers & Families: Disabled individuals cannot easily compare qualified providers, undermining person-centered planning and choice in the ABI Waiver Program. Edge Cases: Even if DSS genuinely lacks the document, FOIA requires reasonable efforts to obtain records under agency control or oversight. Referring requesters to third-party application processes does not fulfill public-record obligations. Broader Implications (Why This Matters to the World) This FOIA thread documents systemic transparency failures in a federally funded Medicaid program serving brain-injury survivors. When a state agency claims it cannot provide its own directory of qualified providers while directing people to apply through a third party, it raises serious questions about accountability, equitable access, and compliance with FOIA and ADA. Public interest is high: Families need complete, official information to make life-changing decisions about care. Withholding or fragmenting this information (claiming “we don’t have it” while confirming two directories exist) erodes trust in government programs meant to support vulnerable populations. This pattern has real-world consequences: delayed or incorrect service matching, potential monopolization of referrals, and barriers for disabled self-advocates who already face cognitive and communication challenges. Recommendations Immediate release of both official ABI Waiver Program directories (agency and private provider lists) in accessible electronic format. Full disclosure of records on directory creation, maintenance, presentation, public access, and any restrictions. Clarification on why DSS claims no access to records it oversees. Confirmation of expedited processing under ADA and public-interest provisions. Preservation of all related records for oversight and potential federal review. All source emails, read receipts, attachments, and appeals from November 13, 2023 – January 3, 2024 are preserved and publicly available 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 1. Requester David Medeiros Title: Founder & Medicaid Acquired Brain Injury (ABI) Waiver Program Provider Organization: ABI Resources Address: 39 Kings Highway, Suite C, Gales Ferry, CT 06335 Website: www.CTbrainINJURY.com 2. Connecticut Department of Social Services (DSS) – FOIA Staff FOIA Officer (name not disclosed in any correspondence) Title: FOIA Officer Organization: Department of Social Services Email: FOIA.DSS@ct.gov Address: 55 Farmington Avenue, Hartford, CT 06105 General FOI Contact Email: foi@ct.gov 3. Allied Community Resources (ACR) – Contacts Referenced by DSS Valerie Giannelli Email: vgiannelli@alliedgroup.org Nicole Simmons Email: nsimmons@alliedgroup.org Marihonor Flag Email: mflagg@alliedgroup.org 4. Centers for Medicare & Medicaid Services (CMS) – FOIA Staff (From CMS response documents referenced in the thread) Emmett D. Nicholson Title: Director, Division of FOIA Analysis – C, Freedom of Information Group Organization: Centers for Medicare & Medicaid Services Address: 7500 Security Boulevard, Mail Stop C5-11-06, Baltimore, MD 21244-1850 Joseph Tripline Title: CMS FOIA Public Liaison Phone: (410) 786-5353 Fax: (443) 380-7260 Address: 7500 Security Boulevard, MS N2-20-16, Baltimore, MD 21244-1850 N'Mah Keita (Nmah Keita-Kumako) Title: Government Information Specialist, FIG / Division of FOIA Analysis – C Organization: Centers for Medicare & Medicaid Services Phone: 410-786-2101 Email: NMah.Keita-Kumako@cms.hhs.gov Desk: C4-11-04, 7500 Security Boulevard, Baltimore, MD 21244-1850 Permanent Public Record – David-Medeiros.com Accountability Archive Published: February 17, 2026 Author: David Medeiros, Brain-Injury & Stroke Survivor, Founder & Provider, ABI Resources – Medicaid