The draft revision to the "Registered Peer Recovery Specialists (PRS)" section introduces a new caseload ceiling of 30 active members per full-time PRS, along with an expanded definition of "active member" that includes individuals receiving peer support as a component of other Behavioral Health services (e.g., ACT, MH-PHP, MH-IOP, Community Stabilization, RCSU), and a new provision for PRN encounters in emergency departments and mobile crisis/23-hour crisis stabilization settings.

Immediately following this new framework, the draft retains the existing sentence stating that "the caseload assignment of a full time PRS shall not exceed 15 members at any one time" and that "the caseload assignment of a part-time PRS shall not exceed 9 members at any one time," unchanged from the current manual.

As drafted, it is unclear how the 30-member ceiling and the 15-member (or 9-member, part-time) ceiling are intended to operate together. Specifically:

• Does the 30-member limit supersede the 15-member limit, such that 15/9 should be removed from the manual as outdated language?
• Alternatively, do the two limits apply to different categories of caseload — for example, does 15/9 apply only to a PRS's standalone Peer Support Services/Family Support Partners caseload, while 30 applies to the broader "active member" count that also includes members receiving embedded peer support through other Behavioral Health services?
• If both limits remain in effect, which limit governs when a PRS's standalone caseload alone would exceed 15, or when the combined active-member count would exceed 30 but the standalone caseload remains under 15?

We recommend that DMAS clarify this section explicitly — either by removing the superseded limit, or by adding language that specifies which limit applies to which category of members — so that providers can determine actual, enforceable caseload requirements from the manual text alone.

Section reference: "Registered Peer Recovery Specialists (PRS)" — Provider Enrollment section, pages 7–8 of the draft (undated/TBD revision).