Prescreener training required to become a Virginia Preadmission Screener Clinican is quite rigourus  and has been standardized for years.  I have a QMHP Bachelor's level VCPASC that has been doing the work for over 30 years consecutively.  Billing should be permissable without requiring "invivo" observation.  Indirect supervision is already built into the entire Emergency Services Department, as a result of the standardized protocols established by DBHDS.