Non-Solicitation Policy

Non-Solicitation & No Patient Steering Policy

Medicaid Meals Program – Vista Verde Homes

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.

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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

• 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.

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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

• Does not restrict individuals from seeking services elsewhere

All decisions regarding service selection remain solely with the individual or their authorized representative.

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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

• Are informed that eligibility and enrollment decisions are made by third-party organizations

Vista Verde Homes does not control, manage, or determine final program acceptance.

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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

• No referral fees, commissions, or performance-based incentives are accepted

Any funding received by Vista Verde Homes is used solely to support charitable operations and is not tied to individual program selections.

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5. Compensation Independence

Vista Verde Homes does not receive:

• Per-enrollment payments

• Per-referral commissions

• Outcome-based incentives

• Revenue-sharing tied to participant activity

Where grants or program support exist, they are structured to preserve neutrality and avoid conflicts of interest.

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6. Alignment With Regulatory Standards

This policy is designed to remain consistent with:

• CMS beneficiary communication and outreach guidance

• Federal Anti-Kickback Statute principles, as applicable to nonprofit educational activity

• Federal beneficiary inducement considerations

• State Medicaid consumer protection and marketing standards

• General nonprofit ethics and conflict-of-interest best practices

Vista Verde Homes maintains internal practices intended to prevent even the appearance of improper influence.

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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

• Respect participant autonomy and decision-making

Violations of neutrality expectations may result in termination of partnership or participation.

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8. Educational and Facilitative Role Only

Vista Verde Homes’ role is limited to:

• Community education

• Eligibility pre-screening (non-clinical)

• Resource navigation

• Referral assistance

Vista Verde Homes does not:

• Enroll individuals into insurance plans

• Determine benefits or coverage

• Provide medical or case management services

• Act as an agent of any payer, provider, or government entity

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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

• Avoids real or perceived conflicts of interest

All program communications are designed to support informed, voluntary participation.

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10. Contact for Compliance Questions
Vista Verde Homes
Medicaid Meals Program
Salt Lake County, Utah, United States
Email: info@medicaidmeals.com

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