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