"NeuroRestorative" is a brand name, not a legal entity. The company that holds contracts, employs staff, bills insurance, and assumes legal obligations in Maine is Mentor ABI, LLC — a Delaware limited liability company. ABI stands for Acquired Brain Injury. This entity is confirmed in the SEC-filed Exhibit 21.1 (Subsidiaries of the Registrant) of Civitas Solutions, Inc. (CIK: 0001608638), filed December 13, 2018.
Civitas Solutions was formerly called The MENTOR Network. In 2019, it was taken private by two private equity firms — Centerbridge Partners and Vistria Group — and subsequently rebranded as Sevita Health. The company now operates as one of the largest private Medicaid-funded disability services providers in the United States, with approximately 45,000 employees and nearly all revenue derived from federal and state health programs.
Because Mentor ABI, LLC is incorporated in Delaware but operates in Maine, it is required under Maine law to register as a foreign LLC with the Maine Secretary of State. That registration can be searched at apps3.web.maine.gov/nei-sos-icrs/ICRS (search "Mentor ABI"). The registered agent is almost certainly CT Corporation System, which handles state registrations for all Civitas/Sevita entities. This search requires manual access due to CAPTCHAs and cannot be performed remotely.
Every public budget reference to this entity uses the brand name "NeuroRestorative" or the phrase "state agency client." No School Committee agenda, budget workshop presentation, or ED279 disclosure identifies the entity by its legal name, Mentor ABI, LLC, or discloses its Delaware incorporation, its private equity ownership, or the four-layer corporate chain above it.
Mentor ABI, LLC does not own the house at 9 Rivers Edge Drive, Gorham. The property is owned by J & J Realty Trust Partnership LLC, registered at 285 Washington Street, Braintree, Massachusetts 02184. Its principal is John Connolly, vice president at SUCCESS! Real Estate in Braintree. The LLC purchased the property on November 3, 2017 for $365,000.
Braintree, MA is adjacent to Dedham, MA — the location of NeuroRestorative's corporate office at 980 Washington Street, Suite 306. This is a standard private equity group home ownership structure: a separate real estate investor acquires the property, and the care operator leases it. As a consequence, some portion of the revenue GSD pays to Mentor ABI, LLC and the reimbursements NR receives from MaineCare ultimately pass through to a private Massachusetts real estate trust in the form of rent. This arrangement has never been disclosed in any GSD public budget document.
| Property Detail | Record |
|---|---|
| Address | 9 Rivers Edge Drive, Gorham, ME 04038 |
| Legal owner | J & J Realty Trust Partnership LLC |
| Owner address | 285 Washington Street, Braintree, MA 02184 |
| Principal | John Connolly — SUCCESS! Real Estate, Braintree, MA |
| Purchase date | November 3, 2017 |
| Purchase price | $365,000 |
| Gorham assessor account | #007020 RE · Map/Lot 0049-0020-0001 |
| Physical description | 3-bedroom, 2.5-bath ranch, built 2008, 2.58 acres on the Little River |
| Maine DHHS licensed capacity | 5 beds |
The most significant undisclosed element of the GSD–NR financial relationship is a billing mechanism that automatically reduces GSD's annual state funding every time Mentor ABI, LLC submits a MaineCare claim for a Gorham student. This mechanism operates as follows:
The result is that GSD bears part of the cost of NR's MaineCare billing from its own operating budget. When NR's billing increases, GSD's subsidy check shrinks by a corresponding amount. The district receives no notification, has no vote, and has no documented process for managing this exposure.
| Metric | FY2023 | FY2024 | Year-over-Year Change |
|---|---|---|---|
| NR total MaineCare billing | $60,230 | $115,979 | +$55,749 (+93%) |
| Estimated state share (37%) | $22,285 | $42,912 | +$20,627 |
| Additional GSD subsidy loss in FY24 | — | — | ~$20,600 taken from GPA check |
No public budget workshop, School Committee presentation, or budget narrative document has ever identified this mechanism or quantified its effect on Gorham's budget.
The Gorham FY2025 budget document (adopted May 2024) states: "A data specialist was added, as well as a Maine Care Billing Specialist which will help create an additional revenue stream."
The framing treats MaineCare billing as a net revenue gain. It does not disclose the Seed recovery mechanism — that for every dollar billed, approximately 37 cents is automatically reclaimed from GSD's General Purpose Aid. Local taxpayers fund the specialist's salary. Federal taxpayers fund the federal match (~63%). State taxpayers fund the state match (~37%) — which is then clawed back from GSD's own subsidy check. The net fiscal benefit to GSD is therefore the federal share only, and this calculation has never been presented to the public.
In FY2023, GSD began its own MaineCare School-Based billing program. By FY2026, GSD is billing MaineCare at an annualized rate approximately equal to NR's billing for the same fiscal year and the same student population. Both entities are submitting claims for services delivered to residents of 9 Rivers Edge Drive who are enrolled as Gorham students.
MaineCare rules require providers to implement coordination of benefits — a documented system to ensure the same service is not billed twice by two different parties. No such controls have been disclosed publicly in any GSD budget document, School Committee presentation, or administrative policy statement.
| Year | NR / Private Provider Billing | GSD Own Billing | Note |
|---|---|---|---|
| FY2018 | $4,279 | — | |
| FY2019 | $15,958 | — | |
| FY2020 | $32,583 | — | |
| FY2021 | $51,984 | — | |
| FY2022 | $53,506 | — | |
| FY2023 | $60,230 | $1,722 | GSD billing begins |
| FY2024 | $115,979 | $0 | +93% spike — no public explanation |
| FY2025 (3 qtrs) | $27,934 | — | Partial year reported |
| FY2026 (annualized) | ~$115,000 | ~$115,000 | Both entities billing simultaneously |
NR's billing falls under MaineCare Benefits Manual Section 18 — the 1915(c) Home and Community Based Services Waiver for Adults with Brain Injury (Waiver ID: ME.1082). This waiver covers adults 18 and older with acquired brain injury requiring nursing-facility-level care. Covered services include residential habilitation (24/7 staffing), community support, day habilitation, supported employment, and respite. When NR residents attend GSD programs, some of these service categories overlap with school-based MaineCare billing codes — creating the coordination risk.
GSD's administrative policies, School Committee materials, and public budget documents contain no reference to any system for monitoring overlap between GSD's MaineCare school-based billing and Mentor ABI, LLC's simultaneous Section 18 billing for the same students. This is a documented compliance requirement under Maine Office of MaineCare Services rules. Its absence from the public record is unexplained.
On July 8, 2025, Governor Mills signed LD 858 — "An Act to Ensure Behavioral and Mental Health Services Are Available to Students by Providing Grants to Schools That Contract for Those Services." The law creates a state grant program for behavioral and mental health services specifically for services not otherwise covered or reimbursable through MaineCare.
The risk: If a school contracts for services and bills MaineCare for those services, then also applies for an LD 858 grant for the same services, the district may receive reimbursement twice — once through MaineCare and once through the grant. This is not a theoretical risk; it is a structural feature of how the two programs interact. Whether Gorham or any Greater Sebago district has applied for LD 858 grants while simultaneously billing MaineCare for the same student services has not been disclosed publicly.
The public budget narrative presents the NR revenue wind-down as a single line item — a $455,000 revenue reduction. In fact, the GSD–NR financial relationship involves at least five distinct money flows, not all of which are accurately characterized in public budget documents.
| # | Money Flow | Direction | FY26 | FY27 | Publicly Disclosed? |
|---|---|---|---|---|---|
| 1 | NR pays GSD for educational services to residents | NR → GSD | $150,000 | $50,000 | Vague — "state agency client" |
| 2 | Maine DOE modular building reimbursement — Narragansett school (5-year DOE capital reimbursement; expires on its own schedule; unrelated to NR) | State → GSD | $254,918 | $0 | Misattributed to NR (see note below) |
| 3 | Child development services revenue (NR-linked) | State → GSD | $100,000 | $0 | Not explained |
| 4 | NR MaineCare billing — reduces GSD's GPA subsidy check | GSD loses $$ | ~$43,000 loss | TBD | Never disclosed |
| 5 | NR residents enrolled in GAE ESOL — $516/person tuition | NR → GSD/GAE | Small / unknown | Unknown | Never disclosed |
| Total NR-related revenue in budget documents (items 1–3) | $504,918 | $50,000 | Net cliff: ~$455K | ||
The $254,918 is a Maine DOE capital reimbursement for the modular building at Narragansett school — a standard five-year DOE reimbursement for portable/modular school building costs. It expired on its own five-year schedule and has no connection to NeuroRestorative or the NR wind-down. It is presented in FY27 budget documents in the same revenue table section as the NR-related revenue reductions, creating the false impression that NR generated $454,918 in annual revenue for GSD when the actual NR revenue impact is −$200,000 (direct NR payments −$100K + Child Development Services −$100K). The $254,918 difference represents a significant misattribution that overstates the value of the NR relationship to the district.
| Component | Amount per $100 Claimed | Source | Impact |
|---|---|---|---|
| Federal Medicaid match | ~$63–70 | Federal taxpayers | Paid to provider (NR or GSD) |
| MaineCare Seed (state share) | ~$30–37 | State taxpayers | Advanced by DOE — then clawed back from GSD's GPA check |
| Net to GSD from its own billing | ~$63–70 | Federal share only | State share returned to DOE; local taxpayers also fund billing specialist |
| Net to NR (private provider) per $100 | $100 | Combined federal + state | Full payment retained; state share cost borne by GSD through subsidy reduction |
Every dollar NR bills MaineCare is paid in full — to NR. GSD then loses the state's share (~37%) from its own subsidy check. GSD's own billing retains only the federal portion (~63%). Neither the brochure nor any public budget document presents this arithmetic.
Sevita Health / NeuroRestorative employs approximately 134 Maine staff supporting roughly 100 clients annually. Meanwhile, 222 Mainers remain on the brain injury waiver waitlist — unable to access services while the same parent company extracted $500 million in debt-funded dividends between 2019 and 2021 and loaded an additional $1.5 billion in new debt in late 2024. Maine taxpayer dollars flowing through MaineCare to Sevita pass through to debt service and investor returns for Centerbridge Partners (New York) and Vistria Group (Chicago).
Medicare enrollment records for Mentor ABI, LLC's Maine facilities list Brett I. Cohen as the authorized official, at the address 313 Congress Street, 6th Floor, Boston, MA 02210 — the corporate headquarters of The MENTOR Network/Civitas Solutions. Brett Cohen served as Chief Operating Officer of the entire national organization from 2015 until July 2023, when he departed to become CEO of Recovery Centers of America.
Federal Medicare rules require that enrollment records be updated when authorized officials change. As of the date of this report — more than two years after Cohen's departure — it appears these records have not been updated. An outdated authorized official on a Medicare enrollment record is a compliance issue that can affect claims processing and liability.
Separately, a search of the federal National Provider Identifier (NPI) registry returns zero results for "Mentor ABI" or "Mentor ABI, LLC" as a standalone entity. This indicates Mentor ABI bills Medicare and MaineCare under a parent organization's NPI number — most likely National Mentor Healthcare, LLC. This structure makes it difficult to isolate billing activity by individual facility or state-level subsidiary, and obscures accountability when billing disputes arise.
| Date | Action | Entity | Status |
|---|---|---|---|
| September 2025 | FTC enforcement action — antitrust violation (interlocking directorates). Three Sevita directors simultaneously served on the board of a direct competitor (Beacon Specialized Living, also owned by Vistria Group). All three resigned under FTC pressure. | Sevita Health / Vistria Group | Resolved — directors resigned |
| January 2025 – February 2026 | FTC lawsuit to block Sevita–BrightSpring merger. FTC prevailed. Merger was blocked. | Sevita Health / BrightSpring Health | FTC won; merger blocked |
| January 2026 | HHS-OIG audit found $45.6 million in improper MaineCare payments for autism and RCS services (Section 28) across Maine school districts. 100% error rate in sampled claims. Federal clawback of $28.7 million demanded. NeuroRestorative operates within the same MaineCare framework and some overlapping service categories. | Maine school-based MaineCare (Section 28) — same system NR bills under | Active — clawback demanded |
| 2024 | CMS fined NeuroRestorative facilities in Utah a total of $86,800 for care deficiencies. | NeuroRestorative (Utah) | Fines paid |
| 2024 | Massachusetts regulators found licensing deficiencies at NeuroRestorative facilities. | NeuroRestorative (Massachusetts) | Documented |
| 2023 | Florida regulators attempted to revoke NeuroRestorative's operating license. Matter resolved with $13,000 fine. | NeuroRestorative (Florida) | Resolved — fine paid |
| 2023 | California regulators cited NeuroRestorative for conditions constituting a "threat to health or safety." | NeuroRestorative (California) | Documented |
| Active | DOJ lawsuit against co-investor KKR for $650 million+ in antitrust penalties, related to the same market concentration concerns underlying the Sevita FTC actions. | KKR / Sevita ecosystem | Ongoing litigation |
| 2019 | U.S. Senate committee investigation into The MENTOR Network (now Sevita) for quality-of-care concerns in Iowa and Oregon group home settings. | National Mentor Holdings, Inc. | Concluded |
The September 2025 FTC enforcement action occurred during the period when GSD was preparing the FY27 budget and evaluating the financial impact of the NR wind-down. It has not been addressed in any public budget discussion or School Committee meeting on record. The pattern of multi-state regulatory actions — Florida, Utah, California, Massachusetts, and two separate federal antitrust proceedings — establishes a systemic record, not isolated incidents.
Superintendent Heather J. Perry, Ph.D. holds two simultaneous leadership roles with direct bearing on this investigation. Since 2015, she has served as Superintendent of the Gorham School Department. Since 2023, she has also served as Executive Director of the Greater Sebago Education Alliance (GSE) — a Regional Service Center established under Maine law for the administrative benefit of 12 school districts including Gorham, Westbrook, RSU 14 (Kennebunk), Portland, Scarborough, and South Portland.
Under Maine law, Regional Service Centers may be enrolled with the Maine Office of MaineCare Services as third-party billing agents for the districts they serve. The GSE's billing agent status means it can submit MaineCare claims on behalf of member districts — including Gorham — centralizing the billing function that GSD's own "MaineCare Billing Specialist" position (FY2025) was created to manage. Billing agents do not absorb the Seed clawback; the member school districts do.
| Role | Organization | Since | Relevance |
|---|---|---|---|
| Superintendent | Gorham School Department | 2015 | Controls GSD budget, contracts, and staff including the MaineCare Billing Specialist |
| Executive Director | Greater Sebago Education Alliance (RSC) | 2023 | Directs the RSC that acts as third-party MaineCare billing agent for 12 districts including Gorham |
| Chair, State-Wide Funding Committee | Maine School Superintendents Association (MSSA) | Active | Controls state-level policy on the school funding formula — the same formula that governs how Seed recoveries are calculated and applied |
Perry's national recognition — 2026 Maine Superintendent of the Year (October 2025) and National Finalist for the AASA National Superintendent of the Year (December 2025, first Maine superintendent to reach this level since 1988) — is attributed in part to "innovative" programs including workforce development partnerships with healthcare providers. The investigation does not question her professional achievements. It documents the structural conflicts created by the simultaneous accumulation of these roles and the absence of any public disclosure of those conflicts in GSD budget presentations.
"In cases where a Regional Service Center is created to streamline administrative duties but not to provide services to members, the Regional Service Center will be enrolled as a third-party billing agent for the participating schools and/or SAUs." — MaineCare in Education 2023 Guide
At 3 Brazier Lane, Kennebunk, ME 04043, NeuroRestorative shares a physical address with RiverRidge Center — a nursing facility operated by Genesis Healthcare that is currently in bankruptcy proceedings (2025–2026). This co-location creates a documented billing risk.
| Entity at 3 Brazier Lane | Status | Key History |
|---|---|---|
| RiverRidge Center (Genesis Healthcare) | In bankruptcy (2025–2026) | $53.6 million DOJ settlement for Medicare fraud (2017). Genesis Healthcare filed for bankruptcy. Ongoing litigation. |
| NeuroRestorative (Kennebunk) | Operating | Brain injury rehabilitation services at shared address. NR bills MaineCare (Section 18) for residents. |
The Centers for Medicare and Medicaid Services (CMS) inspection resulted in:
The billing risk at this shared location is direct: two providers (RiverRidge, billed under Medicare; NeuroRestorative, billed under MaineCare Section 18) occupying the same physical address, serving overlapping populations, with no publicly documented coordination-of-benefits controls between Medicare and MaineCare billing for residents at that address. This mirrors the dual-billing structure documented for Gorham students (Section 4 above), but at a facility with a confirmed federal "immediate jeopardy" finding.
Jen Jello holds two simultaneous positions that, taken together, represent a textbook case of regulatory capture:
| Role | Organization | Nature |
|---|---|---|
| State Director | NeuroRestorative Maine (a Sevita Health subsidiary) | Private — corporate leadership of Maine's largest private brain injury services provider. Bills MaineCare under Sections 18 and 102. |
| Co-Chair | Maine Acquired Brain Injury Advisory Council (ABIAC) | Public — state oversight body that advises DHHS on brain injury policy, funding levels, and regulatory direction for the very programs her employer operates. |
This is not a minor procedural concern. The ABIAC advises DHHS on funding levels for Sections 18 and 102 — the MaineCare service categories under which NeuroRestorative's Maine operations are reimbursed. The State Director of the entity being regulated is co-chairing the body that sets the regulatory and funding recommendations for that entity's reimbursement rates.
In that testimony, she cited "workforce instability" as the justification for rate increases. The testimony did not disclose that NeuroRestorative's parent company, Sevita Health, had extracted $500 million in debt-funded dividends from 2019 to 2021 and loaded $1.5 billion in new debt as recently as late 2024 — a direct contributor to any workforce instability by reducing funds available for front-line staff compensation. The dual role — corporate director lobbying for higher reimbursement while chairing the oversight body that recommends those rates — has never been disclosed in any GSD public budget document.
Maine DHHS Division of Licensing and Certification maintains public inspection records for all licensed residential care facilities. The NeuroRestorative Sebago facilities have confirmed Maine DHHS license numbers. The Gorham facility's license number has not been confirmed from publicly indexed sources.
| Facility | Address | Maine License # | Type |
|---|---|---|---|
| NeuroRestorative Sebago House | 986 Sebago Road, Sebago, ME 04029 | RCD2000 | Residential Care |
| NeuroRestorative Sebago Ranch | 988 Sebago Road, Sebago, ME 04029 | RCC2294 | Residential Care |
| NeuroRestorative Sebago Lodge | 1014 Sebago Road, Sebago, ME 04024 | RCD38602 | Residential Care |
| NeuroRestorative Gorham | 9 Rivers Edge Drive, Gorham, ME 04038 | Not yet confirmed from public sources | Residential Care |
Inspection reports, complaint records, deficiency citations, and enforcement actions for each of these facilities are public records accessible through the Maine DHHS Licensed Provider Search at gateway.maine.gov/dhhs-apps/aspen/. This portal requires browser-based access and cannot be queried remotely.
Residents at 9 Rivers Edge Drive who are learning English are enrolled in Gorham Adult Education's ESOL (English for Speakers of Other Languages) program at 106 Weeks Road, Gorham. Mentor ABI, LLC pays GAE approximately $516 per person per year for this enrollment. Given the 5-bed licensed capacity, the number of NR participants is small and the total annual revenue is modest — estimated at $1,000 to $2,500. The relationship has not been disclosed in any public budget document as a component of the GSD–NR financial arrangement.
Note: Gorham's separately growing multilingual enrollment in K-12 (58 → 67 → 90 projected students) reflects the district's broader refugee and immigrant community and is independent of the NR facility arrangement. The $540,975 FY27 multilingual budget increase reflects legitimate community need and should not be conflated with the adult education component of the NR relationship.
| What Was Not Disclosed | Why It Matters |
|---|---|
| The legal name of the contract counterparty | Voters cannot evaluate a contract they do not know the legal name of. "NeuroRestorative" is a brand; the legal entity with rights and obligations is Mentor ABI, LLC. |
| The MaineCare seed recovery mechanism | Every dollar NR bills MaineCare triggers a proportional automatic reduction in GSD's state funding. This has never been disclosed in any public budget presentation. |
| The FY2024 billing spike ($60K → $116K) | A 93% year-over-year increase in NR MaineCare billing with no public explanation cost GSD approximately $20,600 in additional subsidy reductions. |
| Dual MaineCare billing by both GSD and NR | Two entities billing for the same students at similar dollar amounts, with no disclosed coordination-of-benefits controls, is a Medicaid compliance risk. |
| The private equity ownership structure | The entity operating the Gorham house is owned by Centerbridge Partners and Vistria Group through four corporate layers. This affects financial stability, care incentives, and risk assessment. |
| The property ownership at 9 Rivers Edge Drive | GSD revenue and NR billing partially fund rent payments to a private Massachusetts real estate LLC, with no disclosure of this arrangement. |
| The FTC enforcement action (September 2025) | A federal antitrust action against the parent company during the budget development period was not disclosed or addressed in any public SC discussion. |
| The NR contract itself | No record of a School Committee vote authorizing the Mentor ABI, LLC contract has been found in the public record. Public school contracts of this financial magnitude are ordinarily subject to a public vote. |
| Superintendent Perry's dual role with the Greater Sebago Education Alliance | Perry simultaneously directs GSD's budget and serves as Executive Director of the RSC that acts as MaineCare billing agent for GSD and 11 other districts. She also chairs the state funding committee that governs the formula under which Seed recoveries are calculated. None of these relationships have been disclosed in any GSD budget presentation. |
| LD 858 grant-billing conflict | The July 2025 law provides grants specifically for behavioral health services "not otherwise covered by MaineCare." If GSD or its GSE billing network simultaneously bills MaineCare and applies for LD 858 grants for the same students, this creates a double-billing pathway. No public disclosure or conflict analysis has been presented. |
| Jen Jello's regulatory capture at the ABIAC | The State Director of Maine's largest private brain injury provider simultaneously co-chairs the state advisory body that recommends funding and regulatory policy for that same provider's MaineCare billing categories. She testified before the Legislature in February 2025 for rate increases in those categories without disclosing the $500M in dividends and $1.5B in new debt at her parent company. GSD has never disclosed this conflict in any budget discussion. |
| The Kennebunk co-location "immediate jeopardy" finding | A July 28, 2025 CMS inspection at the address shared by NeuroRestorative and a Genesis Healthcare nursing facility (currently in bankruptcy) found "immediate jeopardy to resident health or safety," $23,590 in fines, and 27 deficiency citations. This occurred while GSD was developing its FY27 budget referencing NR as a continuing relationship. It was not disclosed in any public budget discussion. |
The following public records requests are directed to the appropriate agencies. All records identified below are public under the Maine Freedom of Access Act, 1 M.R.S.A. §§ 400 et seq. Agencies are required to respond within five business days.
The budget refers to a "state agency client." Is the legal name of that entity Mentor ABI, LLC — a Delaware LLC owned by Centerbridge Partners and Vistria Group — and can you identify the School Committee meeting where this contract was voted on?
When Mentor ABI bills MaineCare for services to Gorham students, Maine DOE recovers the state's share from GSD's GPA subsidy check. Why has this mechanism never been disclosed in a public budget presentation, and what were the actual seed recovery amounts for FY2022, FY2023, and FY2024?
GSD is billing MaineCare and NR is billing MaineCare for the same student population at approximately equal dollar amounts simultaneously. What coordination-of-benefits controls are in place, and where are they documented?
Was the Mentor ABI, LLC contract competitively bid? If not, what sole-source justification is on file?
The FTC brought antitrust enforcement against Sevita Health in September 2025. Did GSD's administration or legal counsel review this action in connection with the NR contract before finalizing the FY27 budget?
Private provider MaineCare billing for Gorham students increased 93% in FY2024 with no public explanation. What caused that increase, and does the district know whether any FY2024 billings duplicated services GSD was also providing?
The property at 9 Rivers Edge Drive is owned by a Massachusetts real estate LLC unrelated to NeuroRestorative. Was this property ownership and lease structure disclosed to GSD before any agreement was signed, and was it reviewed by legal counsel?
Gorham Adult Education receives approximately $516 per person per year from NR for ESOL enrollment. How many NR residents are currently enrolled, and is this revenue expected to continue after the broader NR relationship concludes?
Superintendent Perry serves simultaneously as GSD Superintendent, Executive Director of the Greater Sebago Education Alliance Regional Service Center (which acts as a MaineCare third-party billing agent for GSD), and Chair of the MSSA State-Wide Funding Committee. Has this concentration of roles ever been disclosed to the School Committee in a conflict-of-interest filing? Has legal counsel reviewed it?
LD 858 (signed July 8, 2025) provides grants for behavioral health services "not otherwise covered or reimbursable through MaineCare." Has GSD or the Greater Sebago Education Alliance applied for any LD 858 grants for services that were also billed to MaineCare in the same fiscal year for the same students?
Jen Jello, State Director of NeuroRestorative Maine, serves as Co-Chair of the Maine ABIAC — the body that advises DHHS on funding and policy for MaineCare Sections 18 and 102, which are NeuroRestorative's billing categories. Has GSD's administration or legal counsel ever reviewed whether this structure affects the independence of the regulatory oversight governing NR's billing practices?
A July 28, 2025 CMS inspection at 3 Brazier Lane, Kennebunk — a location shared by NeuroRestorative and a Genesis Healthcare nursing facility (in bankruptcy) — found "immediate jeopardy to resident health or safety," $23,590 in fines, and 27 deficiency citations. Was GSD made aware of this finding? Did the administration review it in connection with the ongoing NR relationship described in the FY27 budget?
| Item | Fact | Source |
|---|---|---|
| Legal entity | Mentor ABI, LLC (Delaware) | SEC EDGAR · Civitas Exhibit 21.1 (2018) |
| Corporate HQ | 313 Congress Street, 6th Floor, Boston, MA 02210 | SEC EDGAR |
| NR corporate office | 980 Washington Street, Suite 306, Dedham, MA 02026 | CARF · Sevita locations |
| Ultimate owners (2019–present) | Centerbridge Partners + Vistria Group | SEC filings · FTC records |
| Parent company (2018 filing) | 119 subsidiaries listed under Civitas Solutions, Inc. | SEC Exhibit 21.1 |
| Gorham house address | 9 Rivers Edge Drive, Gorham, ME 04038 | Gorham assessor |
| Gorham house owner | J & J Realty Trust Partnership LLC — John Connolly, 285 Washington St, Braintree MA 02184 | Gorham assessor · Acct #007020 RE |
| Purchase date / price | November 3, 2017 · $365,000 | Gorham assessor |
| Licensed capacity | 5 beds (3 bedrooms) | Maine DHHS licensing |
| Sebago House license | #RCD2000 · 986 Sebago Road, Sebago | Maine DHHS |
| Sebago Ranch license | #RCC2294 · 988 Sebago Road, Sebago | Maine DHHS |
| Sebago Lodge license | #RCD38602 · 1014 Sebago Road, Sebago | Maine DHHS |
| Medicare authorized official on file | Brett I. Cohen (departed July 2023 — may be outdated) | CMS enrollment records |
| MaineCare billing section | Section 18 — Brain Injury HCBS Waiver (ME.1082) | Maine DHHS MaineCare Benefits Manual |
| FY2024 private provider billing | $115,979 (+93% from FY2023) | Maine DOE Seed Reports |
| Estimated FY2024 GSD seed recovery | ~$43,000 | Maine DOE seed mechanism (37% state share) |
| FY2027 revenue cliff | ~$455,000 | GSD FY27 budget documents |
| GAE ESOL per-person rate from NR | $516/year | GSD budget documents |
| GSD contract publicly disclosed | No — no SC agenda, minutes, or vote found in public record | Public record review |
| Contract competitively bid | Unknown — no procurement record found in public record | Public record review |
| Supt. Perry — dual role | GSD Superintendent (2015–) + GSE Executive Director (2023–) + MSSA Funding Committee Chair | MSSA · GSE · AASA press releases |
| GSE billing agent status | Regional Service Center acting as MaineCare third-party billing agent for 12 districts including Gorham | MaineCare in Education 2023 Guide · Maine RSC statute |
| LD 858 | Signed July 8, 2025 — grants for behavioral health services "not otherwise covered by MaineCare" — double-billing conflict risk | Maine Legislature |
| Jen Jello — dual role | State Director, NeuroRestorative Maine (Sevita) AND Co-Chair, Maine ABIAC | Maine Legislature testimony archive · DHHS ABIAC records |
| Jen Jello — legislative testimony | February 12, 2025 — lobbied for MaineCare rate increases for Sections 18 and 102 (NR's billing categories) | Maine Legislature testimony archive |
| Kennebunk co-location address | 3 Brazier Lane, Kennebunk, ME 04043 — NeuroRestorative + RiverRidge Center (Genesis Healthcare, in bankruptcy) | CMS · DOJ · U.S. Bankruptcy Court |
| Kennebunk CMS inspection | July 28, 2025 — "immediate jeopardy," $23,590 fine, 27 deficiencies | CMS inspection records |
| Genesis Healthcare DOJ settlement | $53.6 million (2017) for Medicare fraud | DOJ |
| Sevita — new debt (late 2024) | $1.5 billion in new debt loaded, in addition to $500M dividends 2019–2021 | Corporate financial disclosures |
| DOJ / KKR antitrust lawsuit | $650M+ antitrust penalties sought — related to same market concentration as Sevita FTC actions | DOJ |
| HHS-OIG audit (January 2026) | $45.6M improper MaineCare payments — Section 28; 100% error rate; $28.7M clawback demanded | HHS-OIG |
| Maine brain injury waiver waitlist | 222 Mainers waiting for services NR provides — while parent extracts dividends | Maine DHHS |