Política de alcance de Medicaid

Vista Verde Homes – Medicaid Meals Program 501(c)(3) nonprofit | EIN: 99-1152633 | Salt Lake County, Utah, United States Effective Date: January 18, 2025 | Last Updated: June 2026

1. Purpose

This policy establishes standards governing how Vista Verde Homes conducts community outreach, education, and communication related to publicly available programs, including Medicaid Meals. Its purpose is to ensure that all outreach is accurate, transparent, and educational; protects consumer choice; avoids inducement or improper influence; remains consistent with applicable federal and state Medicaid communication requirements and with telephone/email marketing laws; and preserves the organization's neutral, nonprofit role.

2. Organizational Role

Vista Verde Homes is a 501(c)(3) nonprofit organization that provides community education, non-clinical eligibility pre-screening, resource navigation, and referral assistance. Vista Verde Homes does not enroll individuals into Medicaid or Medicare, act as a broker/agent/plan representative, determine eligibility for government benefits, or provide medical or insurance services. All final determinations are made by the appropriate government agency or authorized provider. Where contracted, Vista Verde Homes may perform navigation and outreach services within Social Care Network or managed care arrangements.

3. Definition of Outreach vs. Marketing

Permitted outreach includes providing neutral information about available resources, explaining how to access services, offering assistance completing eligibility steps, and responding to questions. Prohibited activities include promoting one provider over another (for compensation or otherwise), encouraging enrollment into a specific plan, representing Vista Verde Homes as affiliated with a payer or insurer, and using pressure, urgency tactics, or misleading statements. Vista Verde Homes conducts outreach only.

4. Neutrality and Consumer Choice

All communications must present options fairly, avoid implying endorsement of any specific provider, emphasize that participation is voluntary, and encourage individuals to review multiple options when available. Individuals retain full freedom of choice at all times, and where connected to programs, the individual chooses their own provider or vendor.

5. Accuracy and Transparency Standards

All materials, scripts, websites, and verbal communications must be truthful and not misleading; clearly identify Vista Verde Homes as a nonprofit, non-governmental resource organization; state that eligibility and services are determined by third parties; and avoid exaggerated or guaranteed-outcome claims. Outdated or inaccurate materials must be corrected promptly.

6. Prohibition on Inducements

Vista Verde Homes strictly prohibits offering gifts, cash, or items of value in exchange for enrollment; providing incentives tied to program selection; and offering assistance contingent on choosing a specific provider. This aligns with federal anti-kickback and beneficiary-inducement principles.

7. Compensation, Funding & Financial Integrity

Vista Verde Homes:

• Does not receive commissions or fees for enrollments
• Does not accept referral fees, "per-lead," or "per-patient" fees
• Does not participate in revenue-sharing tied to participant utilization
• Does not receive outcome-based payments

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, set in advance, consistent with fair market value, and not based on the volume or value of referrals, leads, enrollments, or meals, or on any item or service reimbursable by a federal health care program.

8. Communication Channels

Outreach to the general public may occur through:

• Broadcast (radio, TV) and digital/social advertising
• Website content and educational events
• Community partnerships

Email (compliant with CAN-SPAM: accurate headers, a valid physical address, and a working unsubscribe link)

Telephone outreach to validated landline numbers

Text messaging (SMS) and cell-phone calls are made only to individuals who have opted in — for example, by texting a keyword or by submitting the interest form and providing their number for program contact. The Organization does not send cold or unsolicited SMS to individuals who have not opted in.

Where automated or AI-generated voice is used for calls, the Organization limits such calls to validated landlines (no cell numbers), identifies the Organization and a callback number, includes an opt-out, discloses the use of an AI voice where required by state law, and confirms compliance state-by-state.

All communications must be informational, consent-based where required, honor opt-out requests (including STOP for SMS), and comply with the TCPA, CAN-SPAM, and applicable state telemarketing, robocall, and AI-disclosure laws. (See our SMS/TCPA Policy.)

9. Use of Partner Information

When sharing partner program information, only factual details may be provided, no guarantees may be made, providers must be described neutrally, and multiple options should be presented when available. The Organization accepts no payment from providers or vendors for inclusion or referral.

10. Staff & Volunteer Conduct

All personnel must use approved messaging, avoid recommending specific providers, disclose nonprofit status, respect participant autonomy, and document interactions appropriately. Compensation is never tied to referral volume or value. Training on neutrality and consumer protection is conducted periodically.

11. Vulnerable Population Protections

Because outreach may involve seniors, low-income households, individuals with disabilities, and rural or underserved communities, staff must use plain language, avoid pressure tactics, allow time for informed decision-making, and encourage involvement of caregivers when appropriate.

12. Recordkeeping & Documentation

Vista Verde Homes may maintain records of outreach activities, educational materials used, consent (including SMS/contact opt-ins), referral interactions, and complaints or concerns. These records support audit readiness and program integrity.

13. Complaint Handling

If an individual reports misleading information, pressure to enroll, or provider favoritism, the organization will document the concern, review internally, correct messaging if necessary, and provide clarification to the individual.

14. Regulatory Alignment

This policy is designed to remain consistent with: CMS beneficiary-communication guidance; Medicaid managed care outreach standards; federal consumer-protection principles; the Telephone Consumer Protection Act (TCPA) and applicable state mini-TCPA / robocall and AI-disclosure laws; CAN-SPAM; nonprofit ethical outreach practices; and state Medicaid marketing restrictions where applicable.

15. Periodic Review

This policy is reviewed at least annually, when new state privacy, Medicaid, TCPA, or AI-disclosure rules emerge, and when the program expands into new service regions.

16. Contact for Compliance Questions

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