Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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6/12/23  10:56 am
Commenter: Debra Holloway, CBIS - Brain Injury Association of Virginia

TCM Provider Manual Comments


The definition of brain injury provided should be updated to the CDC definition: TBI is defined as a disruption in the normal function of the brain that can be caused by a bump, blow, or jolt to the head, or penetrating head injury.

Remove the statement - means a brain injury not needed.

Certified Brain Injury Specialist (CBIS): correct certification details: The certification is valid for one year and requires an annual renewal. The continuing education requirement is 10 CEs.

For more information:


Family: definition states unpaid people – there are scenarios where family members are paid to provide services such as attendant services, this is especially true to those that live in rural areas and cannot secure a provider.  These individuals should not be excluded from family/caregiver training.


Immediate family member: consider more inclusive language, domestic partner, and grandparent.


“Mayo Portland Adaptability Inventory (MPAI-4)”: means the Mayo-Portland Adaptability Inventory version 4 (MPAI-4) is a tool that measures functional outcomes for post-acute brain injury programs, based upon 29 functional measures in three clinical areas, including its three subscales (Ability Index, Adjustment Index, Participation Index).


“Qualified Brain Injury Support Provider (QBISP)”: The QBIS and CBIS options are not comparative requirements. The QBISP is an introductory training, we feel a more comprehensive curriculum is need for TCM providers. We acknowledge CBIS may be considered too high of a standard and it requires applicants have 500 hours of currently verifiable direct contact experience with an individual or individuals with brain injury. The Brain Injury Association of Virginia has curriculum expertise and could be contracted to create an appropriate alternative training program.


Provider Requirements

Case Management Agency Requirements

Pursuant to 42 CFR 441.301(c)(1)(vi), providers of HCBS for the individual, or those who have an interest in or are employed by a provider of HCBS for the individual, must not provide case management or develop the person-centered plan of care, except when the State demonstrates that the only willing and qualified entity to provide case management and/or develop person-centered plan of cares in a geographic area also provides HCBS.


In order to meet this requirement an individual that provides case management services must not be employed (directly, or as a contractor) by an entity that provides other HCBS services.

Furthermore, an individual or entity that provides case management/support coordination services must not have an interest (as defined in 42 CFR 411.354) in a provider of other HCBS services.

We feel clarification is needed for providers, in a meeting with DMAS it was communicated that an agency could provide both TCM and waiver services however they couldn't be the provider of both to the same individual.


Brain Injury Services Case Manager Staff Qualifications

Qualifications/Credentials: the list of bachelor's degrees should be expanded to include all relevant human service fields.

We feel the following should be added: Or equivalent brain injury experience. Current BI case managers should be grandfathered in to provide the service if they do not meet the qualification requirements described.


BIS Case Management Eligibility Determination

Assessment and Service Initiation Process: Additionally, the case manager must complete the Mayo-Portland Adaptive Index-4 screening to determine whether the member meets the required severity threshold for BIS case management service. We recommend the following be added: The MPAI 4 should be completed face-to-face with the professional staff, person with the TBI and their significant others. Consider the MPAI 4 is not an appropriate tool for someone with severe cognitive impalement.


Covered Services

Services will include: 5th bullet states face-to-face contact every 60 days, page 14 states:

At a minimum, the BIS case manager must review the plan of care every 90 days to determine whether service goals and objectives are being met, and whether any modifications to the plan of care are necessary. Both should state: every 60 days.


CommentID: 217187