The CPST draft requires LMHP and QMHP staff but does not include Peer Recovery Specialists (PRS) or Certified Substance Abuse Counselors (CSAC). In contrast, Appendix G explicitly authorizes “telemedicine assisted assessment by a QMHP-A, QMHP-C, CSAC with synchronous audio and visual support from a remote LMHP.”

Virginia law recognizes PRS under 12VAC35-105-20 and requires PRS supervisors to complete DBHDS-approved training. Excluding PRS and CSACs from CPST contradicts the state’s investment in peer and substance use services, undermines workforce development under the Right Help, Right Now initiative, and may conflict with 42 CFR §438.12 (Any Willing Provider), which prohibits arbitrary exclusion of qualified providers.