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