On page 6 under staff qualifications it says that " BIS case managers must 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 ".

These 2 certifications are not the same and it's wrong to act like they are. The draft provides inaccurate info & links, but a CBIS goes through the Academy of Certified Brain Injury Specialists at the Brain Injury Association of America & it's pretty rigorous- so rigorous that some people fail the test, or don't have enough contact hours with survivors, or don't keep up with ongoing continuing education requirements. It is a professional level certification and even if it can be difficult to get this population requires support coordination professionals that can demonstrate that they are legitimately qualified. 

The QBISP says right on its website that it is a direct care level qualification, developed as an alternative to the CBIS for direct care staff who will be working under supervision.  It says on the qbisp.training/courses website that the QBISP 2 day training course (12-16 hours, as compared to 500 contact hours for CBIS) "de-emphasizes fact memorization and emphasizes practical skill acquisition that we believe align with the duties that direct care level staff are required to perform".

A QBISP certification might be a great thing for Providers of waiver support services like residential/community integration/adult day support to require for direct care staff under supervision but it is not intended for professional staff/case management staff and it should not be used for BIS TCM just because it is easier to get quickly.

Survivors of brain injury need case managers with a thorough understanding of their unique needs. Not people who have gone to a 2 day direct care level training & are now considered experts. If you insist on allowing such a weak qualification for support coordination for survivors of brain injury then you should require a minimum level of contact hours and specifically require that people with only a QBISP operate only inder the supervision of a CBIS. 

In every other Medicaid reimbursed population there are stringent requirements for the professionals who provide case management/support coordination. Brain injury survivors have unique and challenging needs or else they wouldn't need specialized support. Let's make sure their support coordination providers have more Brain injury expertise than a 2 day direct care level class. Thank you.