WEBVTT

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Question 90.

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Were referral logs, emails, plans,
directory versions, clinical

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notes, billing records, leases,
ownership files, and audit...?

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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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Covered grievance systems must be
accessible, impartial, documented,

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and free from threatened
or actual retaliation.

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David Medeiros:

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Speech, petition, whistleblower,
public-record, and

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disability-retaliation theories each
have different actors and elements.

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ABI Resources:

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ABI may petition and
preserve evidence;

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contract retaliation and
constitutional retaliation are related

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but not interchangeable.

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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 complaint intake, routing,
preservation, decision-makers, case

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files, responses, timing,
referrals, and adverse actions.

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