My name is Hannah Morby, and I am the Program Director at Brain Injury Connections of the Shenandoah Valley (BICSV). I am writing to voice my objection to the proposed changes to the Provider Requirements of the Brain Injury Services Targeted Brain Injury Supplement.

With almost 20 years as a reputable brain injury service provider, the knowledge base and community network within Brain Injury Connections for individuals with brain injuries are extensive and already well-established. BICSV places a high value on the continued education regarding brain injury and its impact on survivors. This specialized education among our providers is required to be ongoing and is a driving force in our case management program. Not only do the providers of our services all have their Qualified Brain Injury Support Provider (QBISP) certification, but they also either have or are working towards completing their Certified Brain Injury Specialist (CBIS) certification as well. The CBIS certification is a much more in-depth certification process and requires over 500 hours of direct contact experience with individuals with brain injuries. BICSV’s commitment to helping service providers work towards their CBIS certification exemplifies our dedication to serving individuals with brain injuries in our community with the utmost knowledge and understanding.

Additionally, due to the existing verbiage of the Brain Injury Services Targeted Brain Injury Supplement, the benefit currently only covers those affected by severe traumatic brain injury. BICSV provides case management services to all brain injury diagnoses, not just TBIs. Changing the Provider Requirements to include other agencies could potentially create programs that would discriminate against certain acquired brain injury diagnoses.

In conclusion, the specialized education and pre-established brain injury case management services that already exist at Brain Injury Connections and other brain injury agencies are why the Brain Injury Services Targeted Brain Injury Supplement should not expand its Provider Requirements to include agencies licensed by the Department of Behavioral Health and Developmental Services (DBHDS).

Thank you for your time in reading my public comment.