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.