Fairfax-Falls Church CSB agrees and supports all other comments to the date.

12VAC35-105-1370 Treatment team and staffing plan.

e. ACT Peer specialists - one or more full-time equivalent peer recovery specialists who is or has been a recipient of mental health services for severe and persistent mental illness. The peer specialist shall be a certified peer recovery specialist (CPRS) or shall become certified in the first year of employment. The peer specialist shall be a fully integrated team member who provides peer support directly to individuals and provides leadership to other team members in understanding and supporting individuals' recovery goals.

d. Peer ICT peer specialists - one or more full-time equivalent QPPMH or QMHP-A who is or has been a recipient of mental health services for severe and persistent mental illness. The peer specialist shall be a fully integrated team member who provides peer support directly to individuals and provides leadership to other team members in understanding and supporting individuals' recovery goals.

These regulations require dual credentials as a peer and paraprofessional/professional. The state’s Registered Peer Recovery Specialist (RPRS) Credential is higher than the CPRS.

Comments:

These regulations require dual credentials as a peer and paraprofessional/professional. The state’s Registered Peer Recovery Specialist (RPRS) Credential is higher than the CPRS.

Recommend removing the QPPMH/QMHP, and CPRS requirements. Replace with the RPRS credential only. Recent legislation making its way through the general assembly requires RPRS for peers on mobile crisis teams. It would be inconsistent for PACT teams to require more peer  credentials than those required for peers on Mobile Crisis teams.

In addition, there is an inherent conflict in clinical/peer dual credentialing. One of the defining features of peer support services is they are “non-clinical.” Requiring a clinical credential for a peer specialist implies they are providing clinical rehabilitative services. In addition, due to workforce issues very few peer specialists can obtain both credentials. And, those who can will generally choose to work in a clinical role with higher pay.