In the PRS Supplement for the Recommendation for Services for ARTS and MH Peers it states, "the PRS will perform peer services under the oversight and clinical direction of the practitioner making the recommendation for services." In our agency and I think many others this is likely to be the Intake clinician and not the LMHP or Other qualified professional to supervise PRS work.  It would help to have the oversight by the program supervisor that meets the professional requirements and not necessarily the individual that made the recommendation as they may no longer be involved in the individuals care beyond recommendation.

On page 9, paragraph 1, line 3: mental h and/or substance use disorders.

This should read: mental health and/or substand use disorders.

Sorry, my comment should have read:

Page 9, paragraph 1, line 3 reads: mental h and/or substance use disorders.

It should read: mental health and/or substance use disorders.

I'd like to add that superisors of peer run centers are qualified to supervise peer support specialists. Many of us have been through the training for supervisors. For example, Motivational Interviewing workshops to help guide staff as well as taken Ethics training and know what is expected of Certified Peer Support Specialists (CPRS). Also, supervisors at peer run centers know what type of additional training CPRS's need to keep up their certification since most of us have been trained and certified anyway.  Other qualified professionals such as QMHP's can supervise PRS since they have had the education, experience or lived experience to justify their position. The peer run center I supervise is already connected to a CSB of the Middle Penninsula Northern Neck and the only one in the state connected to a CSB. Hopefully, we can be a model for other peer run centers.

1. On pg 2 Substance Use Care Coordianation (G9012).  The first line indicates it is only for OBOT, is it available for OTS as well.  Should be clarified in this section.
2. The medical necessity criteria allows for only moderate to severe diagnosis, however especially with the use of buprenorphine, we are finding individuals that meet the criteria for mild.  There should be some reimbursement for mild Substance Use Disorder.

Chapter IV, pages 22-23 under ISP Specific Requirements for ASAM Levels – ASAM Level 3.7, 3.5 – 3.1, 2.5 – 2.1 requires that a “Licensed Credentialed Addition Treatment Professional” shall develop/complete and document the initial ISP.   Licensed staff are a luxury in rural areas, we need to ability to use LMHP-E to perform this task in order to be in a position to provided needed services for our area.