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Question 18.

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Did referral patterns change
after ABI Resources complained,

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and if so, what independent
explanation and records...?

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The 2023 report raises
a concern, not a

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finding.

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People served:

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A beneficiary may have
informed-choice, accessible-notice,

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hearing, and qualified-provider
protections, subject to program

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limits.

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David Medeiros:

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Reporting possible steering
can be protected speech or

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statutory activity only if
each required element is

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proved.

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ABI Resources:

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Beneficiary choice does not
give ABI a constitutional

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right to referrals,
volume, renewal, or a state

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contract.

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Constitutional claims
need state action;

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beneficiary choice does not
guarantee ABI referrals or

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a contract.

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Classify the issue
before choosing a remedy.

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Preserve the full referral
ledger, provider options shown,

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reasons, dates,
decision-makers, and outcomes.

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Apply Constitution, statute,
regulation, contract, then record.