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.