All through the document, brain injury is not defined well at all. Using a more recognized and consistent definition by brain injury providers is preferred, such as the definition from Brain Injury Association. It would also be helpful to show the definition of acquired brain injury and how it will differentiate between a traumatic brain injury for eligibility. The document treats any brain injuries not traumatic as secondary damage. This is NOT accurate and significant brain injuries due occur when they are not considered traumatic in definition. Traumatic only describes that there is some sort of impact to the brain, versus an acquired injury that does not occur with an impact or incident that is a direct result of the injury. A clear and comprehensive definition is needed for better understanding and informing those of why they may or may not be eligible for TCM.