The draft states:

"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."

Can it be considered that a Case manager can provide TCM while under the supervision of a CBIS or QBIS while they await eligibility for certification?  If there is turnover in a case management position, there will be no one to continue TCM services to existing clients if new staff are expected to have one of these certifications which will cause a gap in services to our clients.  CBIS requires significant contact hours and currently there are not enough QBIS training options to have a staff complete the certification upon orientation- the in person requirement for training for QBISP makes that particularly challenging. 

Additionally, opening up eligibility to any bachelor's degree is a wonderful edit but significant years of experience with a CBIS should also be considered as a qualified provider.