Dear Acting Director Roberts:

Strength In Peers respectfully submits the following recommendations related to the Town Hall posting of the draft Peer Recovery Support Services Supplement Provider Manual. 

• The manual should clearly specify that peer support services can be billed under an individual's NPI and license from the Virginia Certification Board for services provided by Peer Recovery Specialists who are employed or contracted by the same entity. The original manual limits peer support billing to organizations licensed by DBHDS. This policy significantly reduces opportunities to sustain and expand access to peer support services. In particular, allowing billing under individuals' licenses and NPIs increases opportunities for non-clinical, peer-run Recovery Community Organizations to partner with clinical providers to offer integrated services supported by Medicaid. Many nonprofit behavioral treatment providers, including free clinics, bill Medicaid under their individual providers' NPIs and these entities represent key possible partners for Recovery Community Organizations wishing to access Medicaid reimbursement. There also is no inherent loss of quality, oversight or capacity in allowing billing under individuals' licenses compared with organizations' licenses. 
• A key aspect of peer support services is that they meet people where they are. This includes conducting outreach to potential participants and providing transportation. These services should be billable because they significantly help individuals overcome barriers to behavioral health services. To adhere to medical necessity requirements, outreach activities could be billed retroactively for individuals who are later diagnosed and recommended for peer support services. Transportation provided by Peer Recovery Specialists also could be billed at its own rate or in a manner similar to Medicaid transportation benefits. 
• Given the emergence of telehealth, particularly within behavioral health, the manual should specify that peer support services provided via telehealth are billable. There should be no restrictions on the percentage of total peer support time that can be provided via telehealth. This will increase access to services in rural and other underserved communities, and in the event of another public health emergency that affect's people ability to access in-person care. 
• Supervision of Peer Recovery Specialists via video conference should be allowed. Face-to-face supervisor should not be the only allowable format for supervision. There is significant evidence that quality supervision, and all manner of effective communication, can occur via video conference. 
• Peer recovery services delivered in hospital emergency department and crisis settings should be allowed to establish brief goals for immediate post-crisis recovery engagement instead of a full Recovery, Resilience and Wellness Plan due to the nature of the situation and needs of participants in crisis. 
• Similarly, hospital emergency department and crisis settings do not lend themselves to the requirement that provider submit a registration to the member's MCO or FFS contractor prior to starting services. The manual should provide an exception for these situations. 
• Although the rates for peer support services were removed from the manual, it should be noted that the $26/hour reimbursement rate is exceptionally low when compared with peer support reimbursement rates in other states. The current rate also is woefully insufficient to cover the costs of peer support services. A higher rate would foster the growth and retention of the peer support workforce, integration of peer support into more mental and behavioral health treatment models, and quality of services. 

Strength In Peers is a nonprofit, peer-run Recovery Community Organization serving Harrisonburg City and Rockingham, Page and Shenandoah Counties. We offer peer-led, integrated recovery programs that combine peer support and clinical treatment provided by partners; comprehensive harm reduction; homeless street outreach and jail/prison in reach; and a Community Resource and Recovery Center. 

We are grateful for the opportunity to submit public comments and the Commonwealth's continued efforts to strengthen and grow peer recovery support. Please feel free to contact us if you have any questions regarding our recommendations.

Sincerely,

Nicky Fadley, Executive Director