Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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5/22/23  12:22 pm
Commenter: Anne McDonnell

Brain Injury Targeted Case Management Provider Manual Comments

1. “Brain Injury” means a brain injury for purposes of this program is defined as brain damage due to a blunt blow to the head; a penetrating head injury; crush injury resulting in compression to the brain; severe whiplash causing internal damage to the brain; or head injury secondary to an explosion." This is not a definition of TBI that’s used anywhere to my knowledge, and I do not understand why crush injury resulting in compression of the head is specially singled out for mention. Please consider using one of the standard, currently existing definitions, like that of the CDC: TBI is defined as a disruption in the normal function of the brain that can be caused by a bump, blow, or jolt to the head, or penetrating head injury.

2. “Case management” means a service that includes the following activities: Educating and counseling the individual to guide him Needs to change to them, or him or her, or something else

3. "Certification is valid for three years, requiring staff to renew their status and stay current with treatment issues and protocols in the process. For more information see..." 

The certification is only good for one year, and you should use the link to the actual program

rather than the one for the Center for Neuroskills, which is a private provider in California and Texas.

4 . "Functional Impairment” means impairments which are typically classified as difficulty completing (insert basic) activities of daily living (e.g., dressing, grooming, getting in and out of bed) and instrumental activities of daily living (e.g., preparing meals, managing finances, housework)."

5. “Under Managed Care Plan or Managed Care Organization (MCO)- "The Virginia Department of Medical Assistance Services (DMAS) is transitioning to Cardinal Care, a unifying brand encompassing all health coverage programs for Medicaid members. Cardinal Care will combine Virginia’s two existing managed care programs – Medallion 4.0 and Commonwealth Coordinated Care Plus (CCC Plus) – to create a single identity for all members receiving services through Medicaid health plan partners. The overarching brand and program alignment also includes fee-for-service Medicaid members, ensuring smoother transitions for individuals whose health care needs evolve over time” This not part of a definition.   It is a statement of process and will quickly be outdated.

6. “Mayo Portland Adaptability Inventory (MPAI-4)” means the Mayo-Portland Adaptability Inventory version 4 (MPAI-4) is a tool that measures functional outcomes for post-acute brain injury programs, based upon 29 functional measures in three clinical areas.

7. “Qualified Brain Injury Support Provider (QBISP)” means certification 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:”  The QBISP Provider Course was originally developed as an alternative curriculum to ACBIS; it does not provide a certification, but a certificate. The “Brain Injury Basics” on-line and self-paced certificate program, developed by the Brain Injury Association of Virginia, for brain injury providers in Virginia, should be included as an acceptable alternative.

 8. “BIS CM providers for MCO members must be contracted with the member’s assigned MCO.” Does this mean all of the BI CM programs have to contract with all the MCO’s?

 9. “Providers of case management must ensure that enrolled individuals have free choice of the available providers of support coordination/case management services and free choice of the providers of other medical care under the State Plan for Medical Assistance”. But the Conflict of Interest rule does in fact limit free choice if someone wanted to receive TCM through an existing provider that offers both Case Management and Clubhouse service.  Does this mean the CSB’s will have to choose between providing TCM and other services? 

10. “Additionally, the case manager must complete the Mayo-Portland Adaptive Index-4 screening to determine whether the member meets the required severity threshold for BIS case management service. Members who do not meet the DMAS definition of TBI criteria nor have physician documented TBI will not need to be assessed using the MPAI-4 and shall be referred to their MCO to receive coordination of care”. How do the programs get reimbursed for their time conducting the assessment, if at the end of it all, someone scores a 49?  This is huge time investment without any guardrails for reimbursement. And what exactly does the MCO level of care coordination consist of for someone with a moderate brain injury that impacts their ability to live independently?

CommentID: 217018