STEIN, J.
Petitioner, a not-for-profit corporation, is a provider for the Consumer Directed Personal Assistance Program handling, among other things, payroll for persons with chronic illnesses or physical disabilities—the consumer. Petitioner also acts as a fiscal intermediary between the consumer and the Medicaid program. Petitioner's revenues are derived from Medicaid payments in connection with the Consumer Directed Personal Assistance Program, which are...
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