On page 7 of this revision it states that, "BIS case managers must also be certified as a Qualified Brain Injury Services Provider (QBISP) or a Certified Brain Injury Specialist (CBIS) prior to independently delivering billable BIS case management services."

It is wrong of DMAS to continue to treat the QBISP and the CBIS as equivalent qualifications. The QBISP is a CERTIFICATE and the CBIS is a CERTIFICATION and that is not expressed accurately on page 7.

Per DMAS' definition on page 5 of the manual under "Definitions", a "Qualified Brain Injury Support Provider (QBISP) means a certificate in a training program through the @Neurobehavioral Training Institute that promotes practical education for direct care staff that is supported by daily supervision to enhance care for persons with behavioral challenges. Training information can be found here: https://qbisp.training/." The bolding is mine, to emphasize that in DMAS' own definition this is clearly a direct care level certificate intended to be supported by daily supervision. The TCM Support Coordinator is not a direct care position and there is no provision for the required daily supervision in the manual. 

Not only is the QBISP not intended for clinical/CM staff or any staff without daily supervision, it is also difficult to locate training. DARS told us that it is $10,000 + expenses to bring in the required out of state trainers, and there are currently no training sites in Virginia. If Virginia agencies spend the money to become QBISP trainers, they still have to pay a fee to the QBISP folks for every person trained and the trainer must complete a minimum of 4 trainings per year, which is prohibitive for smaller providers such as those in rural regions of the Commonwealth.

The CBIS, on the other hand, is defined by DMAS in Definitions in this manual, as ""Certified Brain Injury Specialist" (CBIS) means a certification through the Academy of Certified Brain Injury Specialists that includes 500 hours of direct work with individuals, giving staff ample experience in the core disciplines of behavior, speech, cognitive challenges, physical therapy, and community reintegration. Certification is valid per CBIS requirements, requiring staff to renew their status and stay current with treatment issues and protocols in the process. For more information see https://www.biausa.org/professionals/acbis.". Please note that the CBIS is valid for one year and requires documented submission of brain injury specific continuing education each year (10 units).

The QBISP certificate and the CBIS certification are not equivalent and should not be presented as such. The CBIS is a more rigorous professional level certification requiring direct experience and the QBISP is a direct care level certificate intended to be used under daily supervision.

With that said, Virginia needs something in between the two, given the challenges of staff turnover. The CBIS requires staff to pass a difficult exam and have 500 hours of direct experience with ABI survivors - it is not something a new hire can quickly or easily acquire. The QBISP can be acquired way more quickly, in only 2 days if training can be located, but the 'direct care level under daily supervision' aspect means it is a rather weak requirement for an ABI professional.

One solution would be to allow the QBISP + 3 years of direct ABI experience (or similar) to be considered qualifying. Another would be to establish a supervisory qualification system, as seen in other waivers, where a QBISP (or perhaps a person without a QBISP but with 5 or 10 years direct ABI experience) to operate & provide TCM under the supervision of a qualified ABI supervising case manager. The supervisor would be required to hold a CBIS certification and/or possibly a more advanced degree and would provide oversight.

This manual's case manager qualifications requirements raise the specter of an employee with no experience with survivors of brain injury, a degree in macroeconomics, and a 2 day direct care level training being let loose to provide specialized brain injury case management that is actually not specialized at all due to the flimsiness of their qualifications. We do not allow this with other unique populations and should not allow this with ABI survivors.