This situation requires careful consideration. The general guidance for Medicaid waiver providers is to be very cautious about accepting donations from clients or their families, as this can create a conflict of interest and raise concerns about financial exploitation or Medicaid program integrity.

Key points:
– **Individual staff should never accept personal gifts or money** from clients or their families under any circumstances.
– If a client genuinely wishes to make a donation to the **provider organization** (not to an individual), the provider should:
1. Consult with legal counsel before accepting.
2. Ensure the donation is entirely voluntary and in no way connected to service delivery, scheduling, or staffing decisions.
3. Disclose the donation to the organization’s board of directors and review the conflict-of-interest policy.
4. Document the circumstances thoroughly.
– Some providers noted they have a policy of declining all gifts and donations from clients to eliminate any appearance of impropriety.
– Contact DHS/DDS for guidance if a specific situation arises — having a written agency policy on gifts and donations in place before the situation occurs is strongly recommended.