There doesn't seem to be anything in the draft manual about grievances and or human rights violations. This is super important, especially since the conflict free case management guidance has been so inconsistent. Existing "firewalls " and "safeguards " to prevent conflicts of interest under Virginia ID and DD waivers do not go far enough in protecting rights and choice for Virginians with disabilities. There should be a way for people to report rights violations,  HCBS rules violations,  conflict violations,  etcetera, like a grievance procedure or human rights board.