Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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8/16/23  1:39 pm
Commenter: Rachel Evans

CM Qualifications, Degree, including grandfathering

The 1st version of this manual had an overly restrictive list of acceptable bachelor's degrees for TCM case managers. In this revision, the pendulum has swung all the way over to not requiring any specific degree, any degree will do.

There is a middle ground. I refer you to the DBHDS document, "Approved Degrees in Human Services and Related Fields" (ol approved degrees in human services 062017.pdf in the VA DBHDS Documents library) for a well thought out & reasonable approach to degree requirements. The document specifically addresses QMHPs (Qualified Mental Health Providers) in Virginia but survivors of brain injury require similar protections.

It makes no sense to allow someone with no experience and an unrelated degree to serve as support coordinators/gatekeepers to supports for this unique and challenging population. Under the proposed revised manual, an individual with a bachelor's in Theology or in Architecture, for example, could couple that with the 2 day direct care level QBISP certificate class and be considered a qualified brain injury case manager. This does a disservice to those it is intended to serve.

Please consider a staggered system similar to that seen in other services, where a case manager can be considered qualified under different combinations of degree + experience + certifications. This is especially important to honor the work of existing brain injury CMs, who may hold a CBIS certification and have years of experience but lack a degree & should have an avenue to be grandfathered in.

For example: a Qualified Brain Injury Case Manager must meet one of the following:

  • Bachelor's degree in a Human services related field + a CBIS or 3 years ABI experience
  • Registered nurse + a QBISP certificate & 3 years of ABI experience or a CBIS
  • CBIS + 10 years experience with survivors of brain injury (no degree required)


CommentID: 218756