I have reviewed the TCM BI Draft and have the below feedback-
CBIS is a certification that requires annual renewal, not renewal every three years.
I would recommend the consideration of revising the definition of TBI to match the definition provided by the Brain Injury Association of America, which defines TBI as "an alteration in brain function, or other evidence of brain pathology, caused by an external force. Traumatic impact injuries can be defined as closed (or non-penetrating) or open (penetrating)," since they are the lead agency in brain injury for the United States and the CBIS accreditation that is being required is handled and overseen by them.
Under the "Documentation Requirements" section- item #8 stating a 90 day face-to-face requirement contradicts what is stated as a 60-day face-to-face requirement earlier in the draft under "Covered Services" page 10 and "Person-Centered Planning" on page 13.
Consideration to changing "Plan of Care" (POC) to Individualized Service Plan (ISP). This term is considered more person-centered even in it's wording and is the terminology that is used by CARF, which is also an accreditation requirement listed in this draft.