Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Previous Comment     Next Comment     Back to List of Comments
6/14/23  2:01 pm
Commenter: Amy Smith, BIAV

TCM Manual Comments

Definitions –

“brain injury”: Consider using a standard definition for traumatic brain injury such as from the CDC/NIH. If using the definition currently in the manual, remove “means a brain injury” from the first sentence. In the definitions section, this definition is given for brain injury, but later on in the manual it is given for traumatic brain injury. Keep language consistent.

“CBIS”: Certified Brain Injury Specialist (CBIS) certification is acquired through the Brain Injury Association of America’s Academy of Certified Brain Injury Specialists (ACBIS). Their website is Applicants must have 500 hours of currently verifiable direct contact experience with an individual or individuals with brain injury, and this experience can be paid employment and/or academic internship. Volunteer work and self-recovery does not qualify. Applicants must pass a certification examination in addition to their direct contact experience. The certification is valid for one year, requires an annual renewal, and the yearly continuing education requirement is 10 CEs.

“Family”: in some cases, family members can become paid caregivers for individuals with brain injury. They should not be excluded from services.

“MPAI-4”: Include the names of the subscales – Ability, Adjustment, and Participation indexes

“QBISP”: this is not a certification, it is a certificate program which awards a certificate to an individual who completes a 2 day training course. Additionally, having a specific Virginia statewide qualification and training method would be useful instead of using the QBISP. The Brain Injury Association of Virginia has curriculum expertise and could be contracted to create an appropriate alternative training program.

Brain Injury Services Case Manager Staff Qualifications –

Consider expanding the qualifications/credentials needed to serve as a CM. This is a very narrow list of acceptable bachelor’s degrees and should be extended to include all human services fields. Also, those who have considerable experience working with PWBI (such as those who have their CBIS and thus 500 hours of direct contact experience) but no bachelor’s degree are currently excluded. Equivalent brain injury experience should be allowed, such as with those who are current BI case managers.

QBISP and CBIS are not comparable qualifications. QBISP may be acceptable as an initial training while a CM is gaining brain injury experience, but I believe that a more rigorous certification like CBIS should be gained within 6-12 months of employment as a CM.

BIS Case Management Eligibility Determination –

Intake process: include that case manager can help an individual to get a documented diagnosis through neuropsychological evaluation, which can be paid for by Medicaid to gain access to services.

MPAI-4: This tool is not a screening, it is an assessment. Additionally, it is not an appropriate tool for someone with severe cognitive impairment as they will not be able to participate in the assessment. How will those who have severe TBI gain access to CM services if they cannot participate in the MPAI-4?

CommentID: 217249