The Universal Assessment Tool and Connecticut’s ABI Waiver System: Are We Truly Seeing the Whole Person?

Across Connecticut’s Home and Community-Based Services system, increasing attention is being placed on the implementation of standardized assessment processes designed to determine an individual’s level of need, eligibility, and service structure. Within the Acquired Brain Injury (ABI) Waiver program, the State’s use of the Universal Assessment Tool (UAT) and the CONNIE platform has been presented as a pathway toward greater consistency, accountability, and value-based outcomes. While standardization and quality measurement are important goals, many providers, advocates, families, and individuals with disabilities are raising serious concerns regarding whether these systems are adequately capturing the lived realities of individuals with complex neurological and cognitive disabilities.

Universal Assessment Tool (UAT) and the CONNIE

The concern is not necessarily with the concept of assessment itself. In fact, the Centers for Medicare & Medicaid Services (CMS) recognizes that functional assessments can support person-centered planning and quality improvement when implemented appropriately. CMS also acknowledges, however, that functional assessment tools are only one component of a comprehensive understanding of a person’s needs and quality of life.

The challenge emerges when highly complex human experiences are reduced into standardized scoring systems that may insufficiently account for cognition, trauma, executive dysfunction, emotional regulation, environmental variables, grief, identity loss, behavioral fatigue, and the nuanced “body-mind” relationship that exists for many brain injury survivors. Brain injury is not merely physical. It is neurological, emotional, psychological, relational, and deeply contextual. A survivor may present very differently in a one-time assessment environment than they do over the course of daily life.

Within Connecticut’s ABI system, there is growing concern that decisions surrounding service authorization, staffing structures, and future provider performance ratings may increasingly be tied to assessment outcomes developed by Care Managers who may have spent fewer than five face-to-face hours with an individual across the course of an entire year. While many Care Managers work diligently and compassionately, the structural limitations of the model itself raise legitimate questions. Can a truly person-centered understanding of a brain injury survivor’s needs be developed through intermittent contact and standardized questionnaires alone?

Disability justice advocates have long warned against systems that unintentionally prioritize administrative efficiency over authentic human understanding. The disability rights movement has consistently emphasized the importance of self-determination, individualized planning, and the recognition that disabled individuals are experts in their own lived experience.

CMS itself identifies person-centered planning as foundational to quality HCBS systems and notes that meaningful planning must align with an individual’s priorities, goals, functional needs, and quality-of-life outcomes. Yet researchers studying Medicaid HCBS systems across multiple states continue to identify substantial barriers to meaningful person-centered planning, including time constraints, inconsistent understanding of individuals’ lived experiences, and system pressures impacting care management practices.

For brain injury survivors specifically, these concerns become amplified. Executive dysfunction, reduced self-awareness, impaired insight, emotional dysregulation, sensory overload, trauma responses, and cognitive fatigue are often difficult to measure through standardized functional tools. Individuals may underreport struggles, overstate independence out of pride, misunderstand questions due to cognitive impairment, or present differently depending upon environmental stressors. Family systems, caregiver burnout, housing instability, transportation access, mental health history, and trauma exposure also profoundly influence functioning but may not be fully reflected within numerical scoring systems.

Additionally, providers across Connecticut are increasingly expressing concern that agencies may ultimately be evaluated through Value-Based Payment (VBP) metrics tied to “goal attainment” outcomes without sufficient recognition of whether the goals themselves were realistic, collaboratively developed, clinically informed, or appropriately funded within the plan of care. This creates a potentially dangerous disconnect. If agencies are expected to achieve highly individualized outcomes without corresponding flexibility in staffing structures, clinical supports, or service authorizations, providers may face negative ratings for factors outside of their control.

The ABI Waiver regulations themselves recognize the importance of specialized cognitive and behavioral interventions, including the use of intervention plans developed by Cognitive Behaviorists to identify individualized treatment goals and interventions. Yet many providers and families report ongoing concerns regarding fragmented communication, delayed access to intervention plans, and insufficient interdisciplinary collaboration across systems of care.

At its core, this conversation is about more than paperwork, assessment scores, or software platforms. It is about whether Connecticut’s disability systems are moving toward truly relational, trauma-informed, neurobehaviorally informed, and person-centered models — or whether we risk creating systems that unintentionally reduce human complexity into administrative categories.

The disability and social justice communities have consistently argued that meaningful support systems must be built with disabled individuals rather than simply for them. Assessment processes should incorporate longitudinal understanding, interdisciplinary perspectives, family and provider collaboration, and recognition that disability experiences fluctuate over time and context. Most importantly, they must preserve dignity, autonomy, and authentic voice.

Connecticut has an opportunity to lead in this space. But doing so will require ongoing dialogue with survivors, providers, clinicians, families, and advocates to ensure that assessment tools support human-centered care rather than replace it.

For individuals living with brain injury, the question remains profoundly simple: Does the system truly know the person behind the assessment?