I have the following concerns that in line with other comments that have been made regarding these changes:

Prescreenings by QMHP- not independently billable despite education and training

Certified Pre-screeners have extensive training prior to becoming certified that include education, hands-on training, and observation.  This certification is standardized across the state.  Pre-screeners should be able to bill for their services without having direct observation from a LMHP/LMHP-R.  If not able to bill independently, I agree with recommendation to allowing indirect supervision of activities, meaning review and sign off on prescreening by LMHP/LMHP-R.

Supervisors of Peer Recovery Specialists- required training

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. 

These trainings are not readily available.  Without the training being offered continuously and remotely,  it will delay being able to provide peer services.  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.