On behalf of the Alexandria Community Services Board I submit the following comments:

Given the nationwide lack of available psychiatrist, we propose adding language to the Intensive Community Treatment (ICT) service and Program of Assertive Community Treatment (PACT) service definitions to allow for a Nurse Practitioner.  Specifically, where both definitions itemize the staffing of the teams we recommend “… a full- or part-time psychiatrist or a Nurse Practioner (NP)”

This wording would allow more flexibility in meeting the needs of individuals in the community.

We also would like to recommend adding the definition of the “Registered Peer Recovery Specialist”.  The definition should match the peer recovery specialist definition contained in 12VAC35-250-10. Definitions.  The definition as written is:  means a person who by education and experience is professionally qualified to provide collaborative services to assist individuals in achieving sustained recovery form the effects of mental illness, addition, or both.

The omission of this definition may lead to confusion regarding what standard within the Licensure guidelines best fit the peer recovery specialist.  The only comparable definition listed is the “Qualified Paraprofessional in Mental Health (QPPMH)" which requires education or a minimum of experience of providing services to individuals with a  mental illness. The peer recovery specialist lived life experiences with a serious mental illness is the criteria that we need.  The registration process with the Board of Professional Counselors ensures the minimum threshold of standardized education is obtained by the peer recovery specialist.  We want to ensure that the regulations clearly support the lived life experiences which peer recovery specialist bring to the support team without causing an undue burden of direct work experience in addition to the lived life experiences.

We appreciate your consideration of our recommendations.