While training for people who supervise Peer Recovery Specialists is certainly helpful, to add the requirement in this manual, that the very specific "DBHDS Peer Recovery Specialist Training" must be taken, will create additional barriers for peer support service delivery. 

I have not been able, as of a search today, to find where this specific training is being offered. Without it being offered continuously and remotely,  it will delay being able to provide peer services, and/or, put valuable RCSUs for example, immediately out of compliance when enacted. It also does not allow for time for onboard new supervisors and getting them trained when there is staff turnover. 

It seems outside the scope of this manual to require a very specific training, for the supervisors of those directly delivering services. Many programs have long time embedded peers and supervisors that are doing an excellent job and this adds to regulatory burden, especially if not immediately and easily available.

In addition, it is suggested that Peer Recovery Services regulations should be reviewed to make the delivery of Peer Recovery Services easier across the board. If a person is a Certified and Registered Peer Recovery Specialist, they could most simply, be qualified to  deliver group or individual peer services, the same as an LMHP can deliver individual and group counseling.