Brain Injury Program Options

There are two different proposed options for Brain Injury Program: A and B. It may also be helpful to review the Choices for Care options. Please scroll down to view each of the options. You may comment on each of the options separately.

Brain Injury Program Option A

  • Case management for the Brain Injury Program (BIP) would be delivered by the same structure that is chosen for Choices for Care (CFC), if CFC Option B (AAA case management) or CFC Option C (HHA/AAA case management) are chosen.

    Brain Injury Program service providers no longer deliver case management.

    • These changes would allow current BIP providers to continue delivering direct services for people enrolled in the program.
    • There will be changes to case management services, but very few changes to direct services.
    • Case management providers would not be the same organizations as the providers delivering direct services, so there would not be any conflict of interest.
    • AAAs and HHAs would have to meet new requirements to develop knowledge and capacity to deliver case management to the BIP population.
  • ProsCons
    • There would be no conflict of interest. This option meets federal requirements.
    • AAA or HHA case manager would offer and support choices. They would help address problems/concerns with services and supports.
    • This limits changes to BIP direct service delivery.
    • This option builds upon other conflict-free case management infrastructure.
    • The small size of the BIP population may make it hard to develop enough case management capacity.
    • People will need to be supported to understand the changes in the system and the new roles and responsibilities of case managers and providers. They may need to develop new relationships with different providers.
    • Changes in the case management structure will be hard. It may disrupt things for some people and some providers.
    • AAAs and/or HHAs would need to develop knowledge and skills to serve the BIP population.
  • This table helps explain who would do different activities under this option. The six functions listed across the top are key HCBS activities related to case management.

    Roles:Eligibility and EnrollmentNeeds AssessmentPerson-Centered PlanningReferral and LinkingService/ Resource ApprovalService Monitoring & Ongoing Coordination
    StateComplete eligibility assessments


    Approve financial and clinical eligibility/ renewals


    (State approves people to get services)
    Maintain records

    Quality and compliance oversight

    (State keeps track of information about people’s needs. They make sure needs are getting assessed when they are supposed to)
    Quality and compliance oversight


    (State makes sure case managers are doing good person-centered planning)
    Quality and compliance oversight


    (State makes sure case managers are supporting access to services and choice)
    Service/ Resource Approval Approve CFC service plans


    Oversee utilization management


    (State approves service plans. State makes sure services are aligned with needs)
    Quality and compliance oversight


    (State makes sure case managers are doing a good job)
    AAA or HHA case mgmt.Coordinate and support intake paperwork for submission to AHS for approval


    (AAA or HHA case managers help people apply for services)
    Gather data and information, document the person’s needs


    Conduct functional needs assessments (for example, Independent Living Assessment)


    (AAA or HHA case managers collect information about the person’s needs. They use standard tools to help understand needs, like the Independent Living Assessment)
    Facilitate discovery, identify what is important to and for the person

    Identify goals and strategies

    Develop service and support plan

    (AAA or HHA case managers help people make decisions about their goals and how to meet them. They help the person choose their services and supports and who will provide them. They develop the plan
    Offer unbiased choices in services, supports and available resources

    Assist with access to services, enrolling with providers

    (AAA or HHA case managers help people understand choices about providers and supports. They help the person connect to providers and resources that are helpful to meet the person’s needs and goals)
    Submit service plans to state for approval


    (AAA or HHA case managers send plans to the State for approval)
    Ensure people are receiving services as needed and as planned


    Monitor progress


    Manage ongoing coordination


    (AAA or HHA case managers check in with the person regularly. They make sure things are going well and help solve problems when they are not. They bring teams together when needed to make things work better or make changes)
    Direct BIP providerRefer people to AAAs and/or DAIL for application


    (Providers tell people where to go to apply for services)
    Contribute information and data, observed risks or needs


    (Providers share what they know about the person
    As preferred by the person, participate as a contributor to the development of ideas, strategies and approaches to inform the plan


    (If a person wants providers to be part of their person-centered planning, the provider can be included)
    N/AN/ASupport/track progress to goals

    Communicate with case management and support team about changes, problems, needs

    Manage day-to-day coordination tasks as part of HCBS delivery

    (Providers document how services are helping people. They work with case management to solve problems. They do some coordination as part of direct service)

    *Note: The bolded areas in each section are plain language explanations of the function.

Brain Injury Program Option B

  • The State of Vermont would award up to two statewide contracts to deliver BIP case management paired with either Developmental Services or with Choices for Care (CFC Option A). Case management organization(s) would apply through a state-run competitive process that includes two programs (either BIP/DS or BIP/CFC).

    Brain Injury Program service providers would no longer deliver case management.

    • These changes would allow current BIP providers to continue delivering direct services for people enrolled in the program.
    • There will be changes to case management services, but very few changes to direct home and community-based services.
    • Case management providers would not be the same organizations as the providers delivering direct services, so there would not be any conflict of interest.
    • An independent case management provider may complete clinical and functional assessments. (Currently, the State completes initial BIP clinical assessments. HCBS providers complete ongoing clinical and functional assessments, but that is a conflict. Feedback on who should perform which BIP assessments is welcome.)
    • People seeking services would have a simple system to choose a case management provider and to access HCBS.
    • One to two case management organizations for the whole state could help to make sure everyone gets the same high quality case management services.
    • Existing providers could think about ways to work together. They could develop new statewide organization(s) to apply for the contracts, as long as the new organizations are free of conflicts.*

    * Federal conflict of interest standards are available here.
    Conflict of interest requirements are described in plain language here when you click on “What does Conflict-Free Case Management require?”

  • ProsCons
    • This option limits the changes to BIP direct service delivery.
    • There would be no conflict of interest. This option meets federal requirements.
    • An independent case manager would offer and support choices. They would help address problems/concerns with services and supports.
    • If two contracts are awarded, people will be able to choose from different case management organizations.
    • People would be able to easily understand the simple system for  choosing a case management provider and getting services.
    • Having only one or two case management organizations would offer more consistency and equity for people across the state.
    • A process where case management organizations compete for the contracts may help the organizations be more creative, sharing new ideas and better ways to do things.
    • Competitive contracts can help the state to make sure the case management providers do a good job and offer quality services.
    • Independent statewide case management provider(s) may be able to help with other important system functions including training, data management and reporting, and information technology systems.   A competitive procurement and contracting process allows the state to enhance performance accountability for the case management providers chosen, including a specific focus on BIP.
    • The small size of the BIP population may make it hard to develop enough case management capacity.
    • People will need to be supported to understand the changes in the system and the new roles and responsibilities of case managers and providers. They may need to develop new relationships with different providers.
    • Changes in the case management structure will be hard. It may disrupt things for some people and some providers.
    • There are not very many local Vermont organizations who may be ready and able to become a statewide case management provider.
    • A process where providers apply to the state and compete for the contracts (competitive procurement) takes time. There is a short timeline to meet the federal corrective action plan requirements. Pre-competition processes to learn about provider interest, understand stakeholder priorities, and to receive and accept feedback, will be limited.
    • The state role will change to manage competitive contract activities and oversight of case management. This may require some new staff or staff with some different skills.
  • This table helps explain who would do different activities under this option. The six functions listed across the top are key HCBS activities related to case management.

    Roles:Eligibility and EnrollmentNeeds AssessmentPerson-Centered PlanningReferral and LinkingService/ Resource ApprovalService Monitoring & Ongoing Coordination
    StateApprove financial and clinical eligibility/renewals


    (State approves people to get services)
    Maintain records

    Quality and compliance oversight

    (State keeps track of information about people’s needs. They make sure needs are getting assessed when they are supposed to)
    Quality and compliance oversight


    (State makes sure case managers are doing good person-centered planning)
    Quality and compliance oversight


    (State makes sure case managers are supporting access to services and choice)
    Approve CFC service plans


    Oversee utilization management


    (State approves service plans. State makes sure services are aligned with needs)
    Quality and compliance oversight


    (State makes sure case managers are doing a good job)
    Contracted case mgmt. entityCoordinate and support intake paperwork for submission to AHS for approval


    (Case managers help people apply for services)
    Gather data and information, document the person’s needs


    Conduct functional needs assessments (for example, Independent Living Assessment)


    (Case managers collect information about the person’s needs. They use standard tools to help understand needs, like the Independent Living Assessment)
    Facilitate discovery, identify what is important to and for the person

    Identify goals and strategies

    Develop service and support plan

    (Case managers help people make decisions about their goals and how to meet them. They help the person choose their services and supports and who will provide them. They develop the plan)
    Offer unbiased choices in services, supports and available resources

    Assist with access to services, enrolling with providers

    (Case managers help people understand choices about providers and supports. They help the person connect to providers and resources that are helpful to meet the person’s needs and goals)
    Submit service plans to state for approval


    (Case managers send plans to the State for approval)
    Ensure people are receiving services as needed and as planned


    Monitor progress


    Manage ongoing coordination


    (Case managers check in with the person regularly. They make sure things are going well and help solve problems when they are not. They bring teams together when needed to make things work better or make changes)
    Direct BIP providerRefer people to contracted case management entity


    (Providers tell people where to go to apply for services)
    Contribute information and data, observed risks or needs


    (Providers share what they know about the person
    As preferred by the person, participate as a contributor to the development of ideas, strategies and approaches to inform the plan


    (If a person wants providers to be part of their person-centered planning, the provider can be included)
    N/AN/ASupport/track progress to goals

    Communicate with case management and support team about changes, problems, needs

    Manage day-to-day coordination tasks as part of HCBS delivery

    (Providers document how services are helping people. They work with case management to solve problems. They do some coordination as part of direct service)

    *Note: The bolded areas in each section are plain language explanations of the function.

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