"BIS case managers must either hold at least a bachelor's degree in one of the following fields: social work, psychology, psychiatric rehabilitation, sociology, counseling, vocational rehabilitation, human services counseling OR be licensed by the Commonwealth as a registered nurse. BIS case managers must also be certified as a Qualified Brain Injury Services Provider (QBISP) or a Certified Brian Injury Specialist (CBIS) prior to independently delivering billable BIS case management services."

Please consider including a pathway for existing or future staff persons who do not have a Bachelor's degree but instead demonstrate both expertise and significant (2+ years) experience in case management (especially brain injury case management). 

Additionally, please consider allowing case management staff persons who are supervised by a CBIS and working toward either their QBIS or CBIS (to be attained within the next 12 months) to be considered as qualified providers for TCM CM. This will allow continuation of services if there is staff turnover and/or new hires as we expand services across Virginia.