Virginia Regulatory Town Hall
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Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
Guidance Document Change: Brain Injury Case Management Supplement

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12/9/24  9:53 am
Commenter: Margaret Good, Brain injury Connections of the Shenandoah Valley

Protect Specialized Brain Injury Services: Oppose TCM Provider Changes
 

Hello!

My name is Margaret Good, and I serve as the Development Manager at Brain Injury Connections of the Shenandoah Valley (BICSV), a 501(c)(3) non-profit supporting individuals across eight counties in the Shenandoah Valley. I strongly oppose the proposed changes to the provider requirements for the Brain Injury Services Targeted Brain Injury Supplement.

For nearly 20 years, BICSV has been a dedicated advocate and service provider for brain injury patients. Our specialized focus on this population allows us to deliver person-centered case management tailored to the unique challenges faced by brain injury survivors. Our expertise is grounded in continuous education, training, and a deep understanding of brain injury’s impact on individuals and families.

The proposed expansion to include agencies licensed by the Department of Behavioral Health and Developmental Services (DBHDS) would undermine this specialized approach. While Community Service Boards (CSBs) are critical partners in addressing mental health, housing, and substance use, their resources are spread across a wide range of populations. Compared to BICSV, CSBs lack the concentrated expertise needed to address the specific needs of brain injury survivors fully.

This change risks turning a partnership into competition, which could weaken the support system that clients currently rely on. Moreover, BICSV’s case management program serves all individuals with brain injuries—both traumatic and acquired. Broadening provider requirements could lead to disparities, leaving some individuals, particularly those with acquired brain injuries, without adequate support.

Additionally, our specialized focus ensures that clients receive timely care with minimal wait times. CSBs, valuable as they are, often face longer waitlists, potentially creating gaps in critical services for brain injury survivors.

I urge you to maintain the current provider requirements, which ensure that brain injury survivors continue to receive the high-quality, specialized care they need and deserve. The partnership between BICSV and CSBs has been effective because of each organization’s distinct strengths. Let’s not jeopardize that by creating unnecessary overlap and competition.

Thank you for your attention to this matter and for prioritizing the well-being of brain injury survivors in Virginia.

Sincerely,
Margaret Good
Development Manager
Brain Injury Connections of the Shenandoah Valley

CommentID: 228959
 

12/16/24  2:10 pm
Commenter: Rachel Evans, No Limits Brain Injury Services

STBI TCM Changes
 

The proposed changes in the Guidance Document run counter to what was agreed upon by the Stakeholder Group at the outset of TCM for Severe TBI development. The group, including multiple represented state agencies, was in consensus that DBHDS would NOT be involved in licensure for TCM. There were reasons for this, and history with mental health system changes was discussed, but there was no argument or dissent: the team decided that providers would be CARF accredited organizations and DBHDS licensure would not be required. or even on the table.

A review of the minutes will note the absence of any movement, proposal or request to include DBHDS in the STBI TCM process. In fact, it was one of the very first points of agreement in the Stakeholder group. It simply does not appear as an issue or desired outcome anywhere in the development process, because it was agreed upon at the very start that this would not be a DBHDS licensed service. 

Unfortunately, the rollout of STBI TCM has been slow. There have been communication and onboarding issues and it has not been a particularly smooth process connecting the CARF accredited brain injury support professionals with the MCOs for billing and authorization. The numbers served thus far are very low.

Efforts are now being made to increase communication and mitigate issues. DMAS has taken an active and laudable role in getting STBI TCM back on track. However, in its desire to increase numbers served, DMAS has proposed the very thing the group agreed was not a good idea for this unique and challenging population: the introduction of DBHDS licensure as an alternative to CARF accreditation for providers.

I hope DMAS rethinks this. It was not a good idea at the outset and it is not a good idea now, and it is not the appropriate person-centered solution to the macro level issues involved in the STBI TCM rollout.

If DMAS declines to rethink this, there is a significant concern that must be addressed. The STBI TCM manual, despite requests during development, does not include any vigorous oversight, grievance process, or human rights protections. These elements are required in a CARF accredited organization. This population, by definition, has cognitive issues. They require clear and understandable and cognitively accessible policies and procedures. 

If they feel they are being treated without person centeredness, that they are being offered artificial "choices", or that they are being forced like square pegs into round holes, where does a survivor of severe TBI go? Who is their ombudsman, their human rights advocate? Is it the same Human Rights division and process as the one currently used for folks on the ID/DD waivers? If so, are they trained and ready to serve this population? Are they adequately staffed and prepared to begin protecting the rights of this unique population?

It was stated in a meeting on this topic not long ago that "case management is case management is case management". As in, it's all the same to us. It is NOT all the same!

Mental health case management has its own set of regulations, licensures and standards, as does ID/DD case management. Specialized brain injury case management does not involve applying a generic "case management" cookie cutter to supports for survivors of brain injury, or at least it shouldn't. This service was developed by a team of engaged stakeholders and the team agreed on provider requirements. 

I strongly encourage Virginia to follow the direction provided by the development team and to NOT add DBHDS licensure as an acceptable route to service provision. Work on the rollout difficulties and stay the course. If DBHDS licensure must be added, then increase other provider requirements and increase human rights/ombudsman protections. Ensure that this population receives the supports they need from professionals with verifiable experience and training in their needs, and ensure that there is an accessible human rights protection process in place.

Thank you for your time and consideration.

Rachel Evans, CBIS (Certified Brain Injury Specialist)

No Limits Eastern Shore Brain Injury Services

 

 

 

 

CommentID: 228991
 

12/16/24  2:42 pm
Commenter: Stacey Weakley

TCM for Brain Injury Services
 

My name is Stacey Weakley and I am deeply connected to Brain Injury Connections of the Shenandoah Valley (BICSV). I am writing to express my objection to the proposed changes to the Provider Requirements of the Brain Injury Services Targeted Brain Injury Supplement. These changes, which would expand eligibility to agencies licensed by the Department of Behavioral Health and Developmental Services (DBHDS), pose a significant risk to the specialized care that individuals with brain injuries depend on.

BICSV is a specialized organization dedicated exclusively to supporting individuals with brain injuries. Unlike Community Services Boards (CSBs), which must divide their attention and resources among multiple populations, BICSV’s singular focus allows it to deliver highly personalized, expert care to this vulnerable community. I have witnessed firsthand the impact BICSV has on individuals and families navigating the challenges of brain injuries.

BICSV has been an invaluable resource for the brain injury community for nearly 20 years, regularly helping individuals regain independence after brain injury by connecting them with essential resources and providing consistent case management. Their commitment to ongoing education and expertise in brain injury care drives their ability to deliver impactful and timely services.

BICSV’s case management program is tailored specifically for individuals with brain injuries. The program focuses on:

  • Providing timely and effective care with minimal wait times—a stark contrast to CSBs, which often struggle with lengthy waitlists and resource limitations.
  • Offering personalized support through a team deeply knowledgeable about brain injuries and their unique challenges.
  • Building a robust network of community resources over nearly 20 years of service.

This targeted, specialized approach ensures that individuals with brain injuries receive the comprehensive care they need without falling through the cracks of broader, less specialized systems.

I strongly object to the proposal to expand Provider Requirements to include agencies licensed by DBHDS. This change will dilute the quality and accessibility of care for individuals with brain injuries.

BICSV’s singular focus on brain injury ensures that:

  • Clients receive specialized and efficient care.
  • Services are inclusive of all brain injury diagnoses, unlike the restrictive criteria of the Targeted Brain Injury Supplement, which currently serves only severe TBIs.

Allowing broader DBHDS-licensed agencies to qualify as providers risks creating programs that may inadvertently discriminate against certain brain injury diagnoses. It would also introduce potential competition for limited resources, driving a wedge between BICSV and its vital community partners, like the CSBs, rather than fostering the collaboration that currently benefits our community.

BICSV has nearly two decades of experience as a reputable brain injury service provider, with an extensive knowledge base and well-established community networks. These are irreplaceable assets that should not be jeopardized by diluting provider qualifications. Expanding eligibility to DBHDS-licensed agencies risks eroding the specialized care that individuals with brain injuries depend on and could leave many without timely or appropriate support.

I urge you to reject the proposed changes and preserve the integrity of the Brain Injury Services Targeted Brain Injury Supplement by maintaining the current Provider Requirements. The expertise and dedication of specialized providers like BICSV are critical to ensuring that individuals with brain injuries receive the care they deserve.

Thank you for your time

CommentID: 228992
 

12/16/24  4:29 pm
Commenter: Ashley Dunlap, Brain Injury Connections of the Shenandoah Valley

Opposition to Proposed Changes to Targeted Case Management
 

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.

CommentID: 228993
 

12/17/24  12:57 am
Commenter: Lisa Bell, Brain Injury Connections of the Shenandoah Valley

Brain Injury Services
 

My name is Lisa Bell and I am a case manager with Brain Injury Connections of the Shenandoah Valley (BICSV).  I am writing to object to the suggested changes to the Provider Requirements of the Brain Injury Services Targeted Brain Injury Supplement.

As a case manager, I have specialized training and I work diligently with clients who have survived a brain injury.  BICSV offers that one-on-one specialized service that survivors need and that is one of the many reasons why BICSV is a benefit to the community.  I have seen their impact every time a client reaches another goal and the positivity that comes from being available almost immediately to offer service and support.

I object to the idea of expanding Provider Requirements that would include agencies licensed by the Department of Behavior Health and Developmental Services.  It would appear those agencies are and have been overwhelmed with the waitlist for services that they already provide.  By expanding Provider Requirements, the already existing waitlist would multiply creating unnecessary gaps.

Brain Injury Connections is a highly regarded and well respected organization with twenty years of experience providing care to the community.  With an existing knowledge base and community network already established, BICSV also certainly objects to these proposed changes.

 

CommentID: 228995
 

12/17/24  8:54 am
Commenter: Jodi Judge, Brain Injury Solutions

Concerns regarding revisions to BI TCM manual
 

Copious amounts of time were spent in work groups to ensure services offered to this population were not simply a carbon copy of other Medicaid cases management services. All populations have specialized needs and ways services need to be provided AND overseen. The brain injury population is no different. Those working in this specific field expressed great concern with the qualifications of providers to offer CM services because providers MUST have experience and knowledge of brain injury in order to provide these services in a manner in which this population needs and deserves. DBHDS is not the authority on brain injury and would not have the ability to oversee and ensure services are being provided in an appropriate manner. We understand there are concerns regarding the low number of individuals currently being served under these services however new programs and services take time to build up. Working out the problems with referrals, approvals, and authorization processes within the individual MCOs would be helpful to also increase access. Opening up services to providers who would be potentially inept to provide them poses great liability and risk to a population who already one of the most vulnerable.  

Jodi Judge, CBIS, MHS

Executive Director

Brain Injury Solutions

CommentID: 228997
 

12/17/24  10:00 am
Commenter: Hannah Morby, Brain Injury Connections of the Shenandoah Valley

Objection to the Proposed Changes to the Provider Requirements of the Brain Injury Services Targeted
 

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.

CommentID: 228998
 

12/17/24  10:18 am
Commenter: Anne Fitzgerald, Brain Injury Connections

Opposing TCM expansion
 

Greetings,

I am writing to register opposition to the proposed revision to Brain Injury Case Management Services to expand under DBHDS. While I appreciate the wish to expand services, this is not the correct course of action.

Currently, under DMAS, brain injury service providers are able to bill for targeted case management.   It is my understanding that there is a concern that not enough survivors are taking advantage of this, hence the wish to expand and include DBHDS agencies.  However, brain injury service providers are only allowed to bill for Traumatic Brain Injury, not Acquired Brain Injury (ABI).  And, the TBI needs to be considered severe, removing further the number of clients who qualify. Additionally, the rollout of TCM was long and communication was sparse. 

At Brain Injury Connections, more than half of our clients have ABI, not TBI, and their brain injuries are not severe enough to qualify for TCM.  Nevertheless, we treat all of our clients equally and provide the highest level of service, regardless of the severity and type of brain injury they sustained. Adding only STBI to DBHDS case management leaves the door open for discrimination of services and the potential for this vulnerable population to fall through the cracks.  

An additional concern is the delivery of services for this unique population. Brain injury service providers must undergo stringent accreditation every 3 years through CARF.  This review ensures that agencies are delivering individualized, person-centered care, focusing on goals that our clients wish to achieve. It is a specialized niche and our case managers are required to obtain QBISP and CBIS certifications. You would not send someone with heart disease to be treated by an ophthalmologist.  The same applies to brain injury.  

I respectfully request that you oppose this change and allow the brain injury specialists to continue being the sole provider of services to this unique population.  If you wish to expand TCM, perhaps open up to criteria to include ABI and moderate TBIs.  Additionally, the research has shown that even mild TBI has long term ramifications on mental health and therefore should not be overlooked (see: Association between traumatic brain injury and mental health care utilization: evidence from the Canadian Community Health Survey and Mental health disorders common following mild head injury). 

Thank you for your time and consideration.

Anne Fitzgerald

Executive Director, Brain Injury Connections of the Shenandoah Valley

 

 

CommentID: 228999
 

12/17/24  10:53 am
Commenter: Thomas Jorgensen, Bradford Staffing

Object to TCM Expansion
 

I am writing to object to the proposed revision to Brain Injury Case Management Services to expand under DBHDS. I do not believe this is the correct course of action.

There must be a concern for the delivery of services for this unique population. Brain injury service providers must undergo stringent accreditation every 3 years through CARF.  This review ensures that agencies are delivering individualized, person-centered care, focusing on what this population wishes to achieve. It is a specialized niche and Brain Injury case managers are required to obtain special certifications. You would not want to send someone totally unqualified to do any job, especially this one.  

I urge you to reject the proposed changes and preserve the integrity of the Brain Injury Services Targeted Brain Injury Supplement by maintaining the current Provider Requirements. The expertise and dedication of specialized providers like BICSV are critical to ensuring that individuals with brain injuries receive the care they deserve.

I have had my own brain injury scare, was out of commission for a year, and would only want the best possible to help me.

Respectfully submitted,

Thomas Jorgensen

Owner - Bradford Staffing

Board Member - BICSV

CommentID: 229000
 

12/17/24  12:39 pm
Commenter: Melinda Caldwell

Director of Programs
 

The proposed changes would impact the level of care that case management services provide to brain injury survivors.  Our staff is grounded in specialized brain injury training focusing on brain injury specific continuing education, certifications, and years of experience. This training allows us to serve this unique population and the challenges they face by providing tailored person centered services.  The addition of agencies and staff that do not have training or expertise in brain injury is a disservice to this population and their families.  I urge you to maintain the current provider requirements which ensures that brain injury survivors continue to receive the highest level of specialized care they need and deserve.

CommentID: 229003
 

12/18/24  2:08 pm
Commenter: Christy Savanick

objection to provider requirments of brain injury services targeted brain injury supplement
 

My name is Christy Savanick and I am a board member of the (BICSV) Brain Injury Connections of the Shenandoah Valley. I am writing to voice my objection to the proposed changes to the Provider Requirements of the Brain Injury Services Targeted Brain Injury Supplement. 

I very much oppose that the Brain Injury Services Targeted Brain Injury Supplement not expand their provider requirements to include agencies licensed by the Department of Behavior Health and Development Services.  Due to the existing verbiage of the Brain Injury Series Targeted Brain Injury Supplement, the program only covers those affected by severe traumatic brain injury. BICSV provides case management for all people who have a brain injury diagnosis, there are no discriminations.

As a recent board member of the BICSV I now have more understanding of how important it is to have case management specifically for people with brain injuries.  BICSV case management includes transportation to important doctor's appointments, finding adequate housing, support groups and many other things. Due to our agency being specialized with a singular scope of brain injury, we are able to deliver a quick turn around of care with minimal wait times for services.  Our case mangers have specialized training for brain injuries, which is extremely important due to each individual having a different and unique brains. We have almost 20 years as a reputable brain injury service provider and therefore can provide the best care for those who are suffering with a brain injury.

 

 

CommentID: 229031
 

12/18/24  2:23 pm
Commenter: Nikki Branch, Brain Injury Solutions

TCM changes
 

My name is Nikki Branch and I am a provider of brain injury services. I am writing to express my strong opposition to allowing agencies governed by DBHDS to provide case management services for survivors of brain injury. 

Survivors of brain injury represent a highly vulnerable population with unique and complex needs. Organizations accredited by CARF are best equipped to provide the specialized care required. The case managers at these agencies undergo specific training and receive ongoing education to stay current with the latest developments in brain injury care and support that individuals with brain injuries require. 

Allowing agencies with no expertise in brain injury to provide case management services could have a detrimental impact on this population. These agencies may not fully understand the intricacies of brain injury recovery, nor the specific needs of the individuals they serve. Such an approach risks the well-being of brain injury survivors and the type of care they receive. 

I also recognize that the number of individuals currently enrolled in the TCM program is relatively low. However, as with any new initiative, the establishment of a reputable and effective program requires time, effort, and attention to detail. It is essential to build a program that is both well-structured and capable of meeting the unique needs of this population, rather than rushing to implement a system that is not adequately prepared. The TCM program is new to both brain injury providers and the MCOs in Virginia, and there are still many questions to be answered. As referrals are made and assessments are completed, valuable insights will emerge that will help refine the process and improve service delivery. 

While DBHDS agencies may be more familiar with administrative aspects such as billing, they lack the specific training and experience necessary to provide the high-quality, specialized services required for individuals with brain injuries. It is critical that we prioritize the best interests of brain injury survivors by ensuring they receive care from organizations with the expertise and resources to address their needs. 

CommentID: 229033
 

12/18/24  2:34 pm
Commenter: Stephanie Forbes

Opposed to changes to Brain Injury Services Targeted Brain Injury Supplement
 

My name is Stephanie Forbes and I have served on the board of Brain Injury Connections of the Shenandoah Valley (BICSV) since 2020. Based on my observations and work with this non-profit, I believe it would be a mistake to change the provider requirements of the Brain Injury Services Targeted Brain Injury Supplement to include agencies licensed by DBHDS. While our case managers team up with the CSBs in our community to provide a well rounded team approach to client services, we worry the proposed change could delay services or potentially keep CSBs from working with our non-profit. CSBs routinely have wait lists with a detrimental gap in services whereas BICSV delivers a quick turn around of support for our clients and their families. In addition, BICSV provides services to ALL brain injury diagnoses, not just TBIs and our case managers are trained to cater their service delivery to each individual client's challenges as a result of their brain injury. The myriad of ways our case managers support and improve their client's lives is astounding. I often explain this non-profit is one you hope you never need but so thankful exists if someone you love ever does and it is because of the accreditation by CARF for TCM. If someone in your family suffers a brain injury, you would want their case manager specifically knowledgeable about the effect of brain injury which will not be the case if you include those licensed by DBHDS. Therefore, the Brain Injury Services Targeted Brain Injury Supplement should NOT expand their provider requirements to include agencies licensed by the DBHDS. Thank you for your informed consideration.

CommentID: 229035
 

12/18/24  5:50 pm
Commenter: Jason Young, Virginia Alliance of Brain Injury Services Providers

Opposition to loosening of provider requirements for Brain Injury TCM
 

  

I am writing on behalf of the Virginia Alliance of Brain Injury Services Providers (VABISP) to vigorously oppose the proposed changes to the provider requirements to be an approved Targeted Case Management provider.  VABISP’s membership is comprised of organizations that make-up the state defined safety net service system for brain injury.  Our member organizations provides statewide coverage of case management services and has a decades long service record of specialized services for persons with brain injury.   

The current provider requirements for TCM is an agency must be CARF accredited under the Employment and Community Services for Support Coordination standards manual.   This requirement was the consensus agreement of a nearly yearlong TBI work group led by DMAS and comprised of a wide variety of experts in the field of brain injury, family members/caregivers, state agencies and other vested parties that set-in place the standards for Targeted Case Management for Traumatic Brain Injury in 2023.   This requirement was agreed upon by this workgroup because this specific accreditation was seen as the best standard to ensure a high-quality provider network to deliver this new service.   This CARF accreditation is specifically designed for community-based providers of case management services. 

Less than a year later, this best practice provider requirement is being watered down to expand the provider requirements for providing this specialized service to a vulnerable population in 2 ways.   

  1.  Allowing any accredited CARF organization to become a TCM provider.  CARF offers accreditation under a wide array of standards manuals.   In addition to the Employment and Community Service standards manual, CARF also has accreditation manuals for Aging, Behavioral Health, Child and Youth Services, Opioid Treatment, Vision Rehabilitation among others.   Why would we want a provider accredited under Child and Youth Services or Opioid Treatment to be an approved provider for Targeted Case Management for Traumatic Brain Injury?  The accreditations under these standard manuals have nothing to do with providing brain injury case management and provides no assurance that the provider knows anything about brain injury or even case management.  
  2. Allowing licensure through DBHDS:  DBHDS is the lead state agency for behavioral health, development disabilities and substance abuse services.   Notably DBHDS is not the lead state agency for brain injury, that agency is DARS.   What specific expertise would having DBHDS licensure ensure that an agency would be qualified to provide brain injury case management services?  DBHDS licensure requirements were not developed with or for the brain injury population and just because a provider is licensed by DBHDS gives us no assurance that they have any expertise with serving persons with brain injury.     

As such, this expansion of provider requirements to be a TCM provider for Brain Injury Services Case Management needs to be rejected.   If these provider requirements are approved it will lead to unqualified providers entering the marketplace to provide services to a very specialized population of which we have no guarantee that these providers would have any expertise in serving.   

The reason DMAS is seeking to expand provider requirements is because of low initial service numbers being served through TCM.   This service was brought online January 1, 2024, less than a year ago.   There were significant delays in the onboarding process, the service authorization and referral process through and with the MCO’s.   This was a new service for the MCO’s and the entire brain injury provider community had to become approved Medicaid providers, so there was an immense learning curve for both the MCO’s authorizing services and the provider community seeking to provide them.    Our provider community has been working diligently with DMAS and MCO’s to resolve these issues and we are now seeing an uptick in referrals and admittance into this new service.   

Adding additional and potentially unqualified providers into the market now would likely slow down this progress being made between the state funded brain injury provider network and the MCO’s.

We urge you to reject these expanded provider requirements and keep in place the existing provider requirements approved less than 18 months ago by the specialized workgroup charged with setting up the rules and requirements to TCM for persons with traumatic brain injury. 

CommentID: 229042
 

12/18/24  6:39 pm
Commenter: Jessica Damico

Objection to the Proposed Changes
 

My name is Jess Damico and I am a client with Brain Injury Connections of the Shenandoah Valley. 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 Connections of the Shenandoah Valley is a very respected non-profit in our community. The people that work there are highly trained and complete ongoing education pertaining to all things “brain injury”. 

I am close with this non-profit as I have had a Severe Traumatic Brain Injury, which caused me to have three strokes at the age of 34. This happened to me two years ago. My case manager is great as she really takes the time to get to know EVERYONE personally. No two brain injuries are the same. Everyone is quite unique. 

Whenever I have an issue or need assistance, she knows exactly what to do or who to see. She will be on the phone for me for hours just to try and get an application pushed through for what I need. This is what she’s like with all of the clients of Brain Injury Connections of the Shenandoah Valley. 

Without them and their knowledge of brain injuries, I would feel so lost. But because of their support and understanding, they have truly helped me find the way. 

Brain Injury Connections of the Shenandoah Valley is beneficial to the brain injury community, because once again, they have that knowledge to “get it.” Each person is handled uniquely, and we meet twice a month and increase our own knowledge of brain injuries and how things like “neuroplasticity” work. Not only do they care for us separately, but they bring us together to broaden our own social network and be around people who have sustained injuries to their brain. 

When I first had my injury, I was broken, bald, badly bruised, and I could barely speak. I stayed home all of the time. When my case manager reached out to me, I was a little hesitant. But after some time with getting to know each other and with the case manager listening to what my needs were, I started to warm up a little. After a few months I finally went to an in-person support group where I could meet others with a brain injury. It took a couple of these sessions and then I became a chatterbox. They truly helped me come out of my shell. 

I feel as though I have been explaining a little of what the case manager does, but there’s so much more to add. When you have certain needs, such as needing transportation, needing assistance reading or writing, needing help with opening things with one working arm, even needing medical equipment; these case managers are on it trying to find things, or get you set up with a transportation service. They even help on the financial aspect of things; I won’t dive into this one, but they are right there. They work with you personally and go over goals you have and work with you to achieve those goals. They meet with us individually every month to see what our needs are, and they make it happen. They have a virtual meeting with the whole group and teach us a specific topic for that month, and this is helpful for those who don’t enjoy being around a lot of people or even for those who can’t drive. They have an in-person group meeting once a month and we either plant small gardens, make door signs, and do so many other things to help us use our imagination and think creatively. They are even there as an ear to talk to on the phone. Whatever your troubles are, they are right there. 

I want all of this to hit home with you and make it VERY clear that Brain Injury Connections of the Shenandoah Valley’s position is that the Brain Injury Services Targeted Brain Injury Supplement NOT expand their Provider Requirements to include agencies licensed by the Department of Behavioral Health and Developmental Services (DBHDS). You can read what this group has done for me and my family. I cannot think of any other agency who would take that time with each client. For those with a brain injury, being with someone who is licensed/certified in all things brain injury related, and a caring individual to add, is crucial for our overall well-being and recovery during the most critical time. 

Thank you.

Respectfully,

Jess Damico

CommentID: 229043
 

12/18/24  9:11 pm
Commenter: Tracy Weaver, Brain Injury Connections of the Shenandoah Valley

Opposition to expansion of provider requirements to include agencies licensed by DBHDS
 

My name is Tracy Weaver and I am on the Board of Trustees for Brain Injury Connections of the Shenandoah Valley. I am involved with this organization due to my own experience as a brain injury survivor and feel it is my duty to speak for those who can not speak for themselves but that have gone through a similar experience. I struggled finding the correct care and therapies after my brain injury and I am deeply encouraged by the work of BICSV to provide case management ONLY to people with Brain Injuries because it is important that survivors have case managers that understand the intricacies of this injury and the population they serve. The proposed changes would change this by mixing the case management for other injury types and brain injuries. The proposed case management also would be ONLY for people with traumatic brain injuries and would leave out those with acquired brain injuries, things like strokes and aneurysms. This is neglecting services to large portion of the brain injury community. The changes would also make agencies that currently cooperate with each other into competitors. This is truly not in the best interest of those with brain injuries as it is going to be hard for those competing for case management to cooperate for the best result for the patient. I can strongly say that I am against the change in these policies and that they are not in the best interest of the brain injury community. 

CommentID: 229045