June 16, 2023

Meredith Lee, Policy, Regulations, and Manuals Supervisor

PRME Division, DMAS

600 E. Broad Street, Suite 1300

Richmond, VA 23219

RE: Public Comments - Draft Provider Manual Supplement: Brain Injury Services

Dear Ms. Lee,

The disAbilty Law Center of Virginia (dLCV) applauds DMAS's historic investment in traumatic brain injury (TBI) services and appreciates the opportunity to share our comments about the draft provider manual supplement for this cohort. dLCV has long administered Virginia's Protection and Advocacy for TBI program, zealously protecting and promoting brain injury survivors' legal, human, and civil rights. We are proposing a few additions to the draft manual’s provider participation requirements section.  

As many commenters have already noted, the provider manual must be updated to include more explicit provider requirements around client rights, complaint options, and case manager reporting responsibilities. Case managers should receive sufficient training in these areas before commencing service provision and regular re-training from there on out.

Similarly, we feel strongly that case managers should receive specialized training in Social Security disability benefits - including training related to helping clients obtain and maintain benefits. Supplemental Security Income (SSI), Social Security Disability Insurance (SSDI), and Disabled Adult Child (DAC) benefits are critical income sources often needed by individuals with severe TBI to live in the community and maintain access to home and community based services (HCBS).

To ensure the best outcomes possible, case managers should also receive specialized training in Virginia's existing HCBS waivers (CCC Plus and Developmental Disability) and community-based crisis services (such as mobile crisis response and REACH) for which their clients may be eligible.

If you have any questions about our public comments, please contact dLCV's Director of Compliance and Quality Assurance, Robert Gray, at Robert.Gray@dlcv.org.

Sincerely,

Colleen Miller, Esq.

Executive Director