The Peer Services Models are designed to be distinct from clinical services and part of the effectiveness of the model is this distinction.  In the requirement of these services being under the “prescription” and direct supervision of a licensed (or licensed type) clinician, the requirements have taken away from the purpose of service model.  There needs to be careful consideration of how the requirements can be modified to allow trained, experienced Peers to supervise and oversee the day-to-day services, while having a licensed (or licensed type) clinicians available for consultation, signing of and review plan and conducting training.

With the documentation, training, supervision requirements and supervisor credential requirements, the proposed rates does not make the service sustainable nor will it be available for those who would want to access to the services.  Below are a few specific concerns about the information in the draft manual.

•          The caseload assignment of a full time PRS shall not exceed 12-15 individuals at any one time and 30-40 individuals annually allowing for new case assignments as those on the existing caseload begin to self-manage with less support. The caseload assignment of a part-time PRS shall not exceed 6-9 individuals at any one time and 15 annually. The caseload assignment of a full time PRS shall not exceed 12-15 individuals at any one time and 30-40 individuals annually allowing for new case assignments as those on the existing caseload begin to self-manage with less support. The caseload assignment of a part-time PRS shall not exceed 6-9 individuals at any one time and 15 annually.

The requirement of limited open caseloads, makes sense.  However, it is not clear what the intent of annual limitation is working to achieve, how this benefits the individuals served and how this should be tracked.  This part should be eliminated.

·         Direct supervision of the PRS shall be provided as needed based on the level of urgency and intensity of service being provided. Supervisors shall maintain documentation of all supervisory sessions.

1. If the PRS has less than 12 months experience delivering Peer Support Services or Family Support Partners, they shall receive face-to-face, one-to-one supervisory meetings of sufficient length to address identified challenges for a minimum of 30 minutes, two times a month. The direct supervisor must be available at least by telephone while the PRS is on duty.                                                                                                     

2. If the PRS has been delivering Support Services or Family Support Partners over 12 months and fewer than 24 months they must receive monthly face-to-face, one-to-one supervision of sufficient length to address identified challenges for a minimum of 30 minutes. The direct supervisor must be available by phone for consult within 24 hours of service delivery if needed for challenging situations.

This is impractical.  The use of “the direct supervisor” in the above statements means that if “the direct supervisor” is out on vacation, sick, etc. the service cannot be provided.  This could have negative outcomes for those who want to be served and does not make this a sustainable service for providers.  Suggest that this is changed to requiring that the direct supervisor or someone with the required supervisor qualifications be on available.  Further, it is unclear of what is meant by “on duty”; having someone available for consultation would be a better way of ensuring appropriate support.

·         Peer Support Services or Family Support Partners may operate in the same building as other day services; however, there must be a distinct separation between services in staffing, program description, and physical space. Peer Support Services shall be an ancillary service and shall not impede, interrupt, or interfere with the provision of the primary service setting.

This goes against the idea of integrated person-centered support for individuals.  It seems the services would be the most effective, if available and integrated at CITAC centers and other locations where crisis services are provided.

I would like to note that I am in agreement with the comments entered by the VACSB Quality Leadership Committee.