My name is Ashley Dunlap and I am a case manager with Brain Injury Connections of the Shenandoah Valley where I have over 6 years of experience providing care to those with acquired and traumatic brain injuries. I am writing to voice my objection to the proposed changes to the Provider Requirements of the Brain Injury Services Targeted Brain Injury Supplement.

Brain injury survivors face a unique set of challenges that require specialized knowledge in areas such as cognitive rehabilitation, functions of brain development, and neuropsychological support.  I have worked closely with individuals and their families to help identify supports in the community based on their current needs. Due to the experience I have gained in this role, I am able to bridge the gap of much needed services and supports often lacking with other community providers. There are many instances in which individuals are referred to me from local CSBs, as soon as the diagnosis ‘brain injury’ is found in their records, regardless of what their need may be. Instead of encompassing a person-centered approach with the individual to help meet their needs at the time of services, they are met with additional barriers to care as the brain injury portion will defer them from services with DBHDS agencies. Often times, the brain injury portion of their injury is not the most urgent need of care, causing a return referral for behavioral health assistance as their current needs reflect behavioral care versus brain injury care. This has been a trend of accessing services with local CSB professionals due to the inexperience with brain injury education. BICSV continues to provide outreach education to our community partners to enhance services, rather then present potential barriers to needed care and assistance.

While professionals licensed by the DBHDS play a critical role in supporting individuals with behavioral health needs, it is crucial that we distinguish their expertise from the specialized care required for individuals with brain injuries. By incorporating provider requirements to not be accredited by CARF, there are risks of diluting the quality of care for individuals who require comprehensive attention from experts trained in brain injury education. Brain injury survivors benefit from a multidisciplinary approach with professionals who are trained to understand the complexities of brain injury recovery. Professionals at local CSBs often do not have the specialized knowledge necessary to address the full spectrum of needs these individuals experience, such as cognitive difficulties, motor function impairments and other neurologic symptoms.

Additionally, involving local CSBs in TCM may unintentionally blue the lines between person centered care and psychiatric care, potentially leading to confusion, delays in appropriate treatment or allocation of resources away from experts with the necessary expertise in brain injury case management.

I strongly urge the decision-makers to reconsider the inclusion of agencies licensed by DBHDS in targeted case management services for brain injury survivors. Resources should be directed towards ensuring that individuals with brain injuries receive care from professionals with relevant experience and expertise in brain injury case management services. BICSV values the CSBs in our community and would like to continue a partnership, but the proposed change would limit services individuals could receive. BICSV provides case management services to all acquired brain injury survivors, not just traumatic injuries. BICSV has nearly 20 years of experience as a reputable brain injury service provider, in which the knowledge base and community network within BICSV has served hundreds of individuals to meet their goals of enhancing their independence within their homes and communities.