Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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6/16/23  8:58 am
Commenter: Kathy Stumm - Family Member and Legal Guardian of TBI Survivor

Conflict of Interest provisions need precise language and clarification

This issue has not been clearly resolved in the draft manual.  Over the course of the work on the BI Waiver and TCM for BI survivors by the DMAS convened Steering Committee, we have heard at least two very different interpretations of what the “Conflict of Interest” rules mean for providers of services.

The first interpretation was DMAS telling providers they had to “choose a lane” and that providers could only provide targeted case management services OR other services such as day programs or club house programs, but NOT BOTH.  

The more recent interpretation has been DMAS telling providers that they CAN provide both case management services AND other services such as day programs/club house programs SO LONG AS THE PROVIDER DOES NOT PROVIDE BOTH TYPES OF SERVICES TO THE SAME INDIVIDUAL.

 These are two very different interpretations and DMAS needs to put in writing very clearly which one of these is correct.

Lastly, as a family member I continue to advocate to the let the TBI survivor be the decision maker for who they want tor receive both TCM and other services from.  It is a nightmare to start over with a new provider . It is helpful to receive TCM from the same provider as other services so long as it is the TBI survivor’s choice.

CommentID: 217274