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Medeiros's report asks whether
care-management actors exercised

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authority beyond approved
program boundaries.

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That is sharper than
calling every contractor

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a government actor.

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Constitutional claims usually
require conduct attributable to

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the state;

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funding, licensing, or
contracting alone is not

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enough.

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Yet Medicaid law can still leave the

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state responsible for its program.

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Under 2026 HCBS grievance
rules, contractors may

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administer complaints, but the
state retains responsibility.

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People served need
accessible, impartial review.

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Medeiros retains speech
and petition interests.

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ABI Resources may have
separate process or

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contract rights.

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Delegation agreements, waiver terms,
authorizations, billing, supervision,

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and the identity of the
decision-maker determine

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accountability.

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Function and proof—not labels—control.