Non-Solicitation & Non-Steering Policy

Medicaid Meals Program – Vista Verde Homes 501(c)(3) nonprofit | EIN: 99-1152633 | Salt Lake County, Utah, United States Effective Date: January 2026 | Last Updated: June 2026

Vista Verde Homes is a 501(c)(3) nonprofit organization that operates as a neutral community resource navigator. The organization is committed to maintaining independence, transparency, and consumer choice in all outreach, education, and referral activities. Vista Verde Homes does not engage in patient steering, inducement, or solicitation practices intended to influence an individual's selection of any specific provider, plan, vendor, or service.

1. Neutral Referral Standard

Vista Verde Homes provides information about available community, public, nonprofit, and healthcare-adjacent programs solely to assist individuals in understanding potential options. All referrals are non-exclusive, informational in nature, based on publicly available or partner-supplied program details, and provided without preference for any specific organization. Vista Verde Homes does not rank, prioritize, or promote one provider over another for financial or strategic gain. Vista Verde Homes makes no direct referrals to end vendors; where individuals are connected to programs, the individual chooses their own provider or vendor — for example, through the authorized Social Care Network or its portal.

2. No Steering or Undue Influence

In carrying out its charitable mission, Vista Verde Homes does not direct, pressure, persuade, or otherwise influence individuals to select any particular healthcare provider, meal program, managed care organization, insurance product, or service agency; does not use scripts, messaging, or outreach tactics designed to limit consumer choice; does not present any organization as the "required," "preferred," or "default" provider; and does not restrict individuals from seeking services elsewhere. All decisions regarding service selection remain solely with the individual or their authorized representative.

3. Freedom of Choice

Individuals interacting with Vista Verde Homes retain full and unrestricted freedom to select any provider or program, may decline referrals or discontinue participation at any time, are encouraged to evaluate multiple options when available, and are informed that eligibility and enrollment decisions are made by third-party organizations. Our Medicaid eligibility navigation is provided free of charge to individuals. Vista Verde Homes does not control, manage, or determine final program acceptance.

4. No Inducements or Financial Influence

Vista Verde Homes strictly prohibits the use of incentives that could be interpreted as influencing participation. Accordingly: no gifts, rewards, or compensation are offered in exchange for enrollment; no financial benefit is provided for choosing any specific organization; no payments are received that are contingent upon enrollment, utilization, or outcomes; and no referral fees, commissions, or performance-based incentives are accepted. Any funding received by Vista Verde Homes is used to support its charitable operations and is not tied to individual program selections.

5. Compensation Independence

Vista Verde Homes does not receive per-enrollment payments, per-referral commissions, outcome-based incentives, or revenue-sharing tied to participant activity. It does not accept payment from food vendors or other providers of federally reimbursable items or services.

The Organization is funded through charitable sources and through a fixed fee paid by managed care plans, Social Care Networks, or other authorized entities for bona fide marketing, outreach, education, and navigation services. This fee is for services rendered, is set in advance, is consistent with fair market value, and is not based on the volume or value of referrals, enrollments, utilization, or any item or service reimbursable by a federal health care program.

6. Alignment With Regulatory Standards

This policy is designed to remain consistent with: CMS beneficiary-communication and outreach guidance; the federal Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)) and federal beneficiary-inducement principles; applicable state anti-kickback and fee-splitting laws (including New York Education Law § 6530(19), California Business & Professions Code § 650, Florida's Patient Brokering Act, the Texas Occupations Code, and Massachusetts G.L. Ch. 175H); state Medicaid consumer-protection and marketing standards; and general nonprofit ethics and conflict-of-interest best practices. Vista Verde Homes maintains internal practices intended to prevent even the appearance of improper influence.

7. Staff, Volunteer, and Partner Expectations

All staff, volunteers, contractors, and community partners interacting with program participants are expected to present information in a neutral and factual manner; avoid recommending specific providers unless explicitly requested for informational purposes; disclose that Vista Verde Homes is not affiliated with any single provider; and respect participant autonomy and decision-making. Compensation is never tied to referral volume or value. Violations of neutrality expectations may result in termination of partnership or participation.

8. Educational and Facilitative Role Only

Vista Verde Homes' role is limited to community education, non-clinical eligibility pre-screening, resource navigation, and referral assistance. Vista Verde Homes does not enroll individuals into insurance plans, determine benefits or coverage, provide medical or case management services, or act as an agent of any payer, provider, or government entity.

9. Commitment to Ethical Community Outreach

Vista Verde Homes is committed to conducting outreach in a manner that preserves public trust, protects vulnerable populations, promotes informed decision-making, ensures equal access to information, and avoids real or perceived conflicts of interest. All program communications are designed to support informed, voluntary participation.

10. Contact for Compliance Questions

Vista Verde Homes — Medicaid Meals Program Salt Lake County, Utah, United States Email: info@medicaidmeals.org