The draft revision to the "Registered Peer Recovery Specialists (PRS)" section introduces a new caseload ceiling of 30 active members per full-time PRS, along with an expanded definition of "active member" that includes individuals receiving peer support as a component of other Behavioral Health services (e.g., ACT, MH-PHP, MH-IOP, Community Stabilization, RCSU), and a new provision for PRN encounters in emergency departments and mobile crisis/23-hour crisis stabilization settings.

Immediately following this new framework, the draft retains the existing sentence stating that "the caseload assignment of a full time PRS shall not exceed 15 members at any one time" and that "the caseload assignment of a part-time PRS shall not exceed 9 members at any one time," unchanged from the current manual.

As drafted, it is unclear how the 30-member ceiling and the 15-member (or 9-member, part-time) ceiling are intended to operate together. Specifically:

• Does the 30-member limit supersede the 15-member limit, such that 15/9 should be removed from the manual as outdated language?
• Alternatively, do the two limits apply to different categories of caseload — for example, does 15/9 apply only to a PRS's standalone Peer Support Services/Family Support Partners caseload, while 30 applies to the broader "active member" count that also includes members receiving embedded peer support through other Behavioral Health services?
• If both limits remain in effect, which limit governs when a PRS's standalone caseload alone would exceed 15, or when the combined active-member count would exceed 30 but the standalone caseload remains under 15?

We recommend that DMAS clarify this section explicitly — either by removing the superseded limit, or by adding language that specifies which limit applies to which category of members — so that providers can determine actual, enforceable caseload requirements from the manual text alone.

Section reference: "Registered Peer Recovery Specialists (PRS)" — Provider Enrollment section, pages 7–8 of the draft (undated/TBD revision).

The language pertaining to caseload capacity for Peer Recovery Specialists is overly complex and restrictive for 2 reasons:

1. While it seems that the language is attempting to provide guidance on what is considered an encounter vs. a case, its leaves significant gray area for interpretation and provides little in terms of value to support the PRS or their supervisor in making determinations about workload.  Suggest an edit to indicate that PRS, like many other classifications of staff, serve multiple roles, as such quality supervision related to the PRS’s capacity to provide care and the population that are serve should be well documented and used to determine caseload size.

2. There is a failure to consider a PRS that works multiple positions, or at least no mention of this consideration.  For example, it is unclear how a peer that works full time as a PRS on a ACT team and who is responsible for 30 individuals could work a parttime position with the same or a different provider delivery billable recovery services as a PRS.  Suggested edit to define that a PRS can provide care for a caseload of up to 30 individuals in a Full Time (40 hour) work week.