Agencies | Governor
Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services


All comments for this forum
Back to List of Comments
5/15/19  6:28 pm
Commenter: Cristy Corbin

Peer Recovery Support Services Supplement feedback

To whom it may concern:

Pg. 4, second paragraph, second to last sentence:  is the word "consumer" the most appropriate word? Maybe change to " those with the lived experience of navigating mental health and substance use services..."

Pg. 4, second, third and fourth paragraphs: the term "Peer Support Services" is referenced; should this be "peer recovery support"?

Pg. 5, paragraph two & three:  the terms "mental illness" and "mental health conditions" are referenced where previously the term "mental health disorder" was referenced.  For consistency, should this state "mental health disorder"?

Pg. 7, first sentence:  should the word "health" be added to read "mental health and/or substance..."

Pg. 8, first paragraph:  is the second date referenced, "April 1, 2018" correct?  Third paragraph:  the term "rehabilitative" to me, implies a clinical outcome.  I would suggest removing that term.  The term "youth" would be appropriate in this definition, not "individual" as we support parents/caregivers of children and youth, and it's referenced in the last sentence.

Pg. 10, first paragraph, last sentence:  replace "mental illness, addiction or both" with "mental health disorders, substance use disorders or both", to maintain consistency with wording.  Second paragraph, the term "rehabilitative" is used again.  Self-Advocacy: add "...caregiver, youth or individual..."  Supervision:  add "Family Support Partner"-not all FSPs are PRSs and we get supervision, too. This applies to the first sentence on Pg. 11, too.

Pg. 13, #3: you marked out the word "by", it should remain.  In the asterick paragraph:  should the full title be "Peer Recovery Support Services Supplement"?  This title is referenced in the last paragraph, too.

Pg. 15, first paragraph, second sentence: add "disorders" after mental health and change "abuse" to "use" after substance.  Fourth sentence:  change "condition" to "disorder"  Second paragraph:  A Family Support Partner does not need to be a PRS to render peer support services.  The first sentence is misleading.  In addition, an FSP is a parent/caregiver who has navigated the behavioral health system with their child.  At the time of employment as an FSP, their child may be an adult but their lived experiences were from the time their child was a minor.  If a "family member" has lived experience with a sibling, uncle, cousin, etc., they would fall under the description of a PRS, not an FSP.  To carry the title of an FSP, you must have the direct lived experience of navigating the system with your own child as we serve the parents of children and youth on their journey and we must be able to relate to them as a parent/caregiver.  Because we can work as an FSP without being a PRS, and can only bill Medicaid if we're registered, should that be noted somewhere in the beginning of this document?  The same goes for a PRS-we can be employed we just can't bill Medicaid until we meet all of these requirements.  The FSP role currently has two different funding streams in VA that does not include Medicaid.

Pg. 16, first paragraph:  add "FSP" everywhere "PRS" is referenced.  Paragraph two is contradictory to paragraph three.  Last paragraph:  I suggest changing the word "clinical" to "professional" as these services are peer based, not clinical; consider adding "youth and family" after "individual"; and consider not capitalizing the recovery, resiliency and wellness plan.

Pg. 17, second paragraph: add "MH Peer Support Services" and change the wording as suggested above for the last paragraph on pg. 16.

Bottom of pg. 21 & top of pg. 22:  When the supervisor "can" be from the agency who conducts the assessment, why does this need to be stated when you have the last sentence after #2 on page 22?  These two statements seem confusing to me.

Pg. 22, #2:  add "Peer Support Services" in the first sentence; last paragraph, commas are missing.

Pg. 23, second sentence:  the word "rehabilitative" seems clinical to me; third sentence: add "mental health disorders"; "Services assist the individual "to" develop..."; instead of the term "mentoring" consider "through sharing lived experiences to instill hope..."; last sentence: consider changing "illness or disorder" to "mental health or substance use disorder".  Second paragraph:  remove "team-based"; their doesn't necessarily need to be a team for the FSP to support the family; remove this statement:  "with complex needs who are involved with multiple systems"-the youth can be new to the system with minimal involvement OR consider adding "who may have complex needs..." and "who may be involved with multiple..."; (i) remove "a" after "similar"; (ii) is a false statement-to function as an FSP you must be the parent/caregiver who has lived experience of navigating the behavioral health system with their own child, as we serve parents/caregivers doing the same and we must relate to them in that capacity.  What's currently written in (ii) is part of the criteria for a PRS; the last sentence is applicable.

Pg. 23, last paragraph:  should "Recovery Resiliency and Wellness Plan" be capitalized?; should this state "month" instead of "week": "...provider for the week shall not exceed the frequency..."

Pg. 24, fourth bullet point:  in reference to "physical space"-could this be elaborated on to say "services shall be rendered in a separate space from other day services" or something to that affect?  In our building, we have limited space for all of the staff we have and our full time FSPs share office space with others.  We go to a private setting if we meet with a family in our building to maintain confidentiality.  The way this is worded could be restricting to an agency who does not have physical office space to devote to a peer support provider.  Last paragraph:  capitalize RRWP? (multiple times); #2: consider:  "Empowering the individual, youth and family...", "...symptom management, community resources, and...", " that the individual or youth..."

Pg. 25, #3:  "...understanding his or her illness..." should this state "understanding his or her substance use disorder or mental health and substance use disorders"?  Bottom of pg. 25 - top of pg. 26, #1-4: replace the term "individual" with "youth".

Pg. 26, #3:  "...understanding his or her illness..." should this state "understanding his or her mental health disorder or mental health and substance use disorders"?

Pg. 27, #1-4:  replace the term "individual" with "youth";  capitalize RRWP? (noted throughout); last sentence: consider adding "..individual's or family's record..."

Pg. 28 first paragraph:  add "...individual's or youth's..."; Assessment for Services: if this includes a parent making a referral for an FSP, could this part elaborate on how the parent would go about getting an assessment completed?  What if they aren't involved with the system yet and the FSP is their starting point; how would the assessment get completed?  Last paragraph:  consider changing "...clinical oversight..." to "...professional oversight...." as peer support services are not clinical; last sentence: add "...individual's or caregiver's..."

Pg. 29, first paragraph:   "qualitied", should be "qualified";  5th sentence: "individual’s" should be changed to "youth's"; 10th sentence: "...individual's or caregiver's..."; third paragraph: "...outlined in this Peer Services Manual Supplement..." should read "...Peer Recovery Support Services Supplement..."; "...individual’s goals and objectives..." add "...individual's or caregiver's..."; fourth paragraph:  "...individual’s goals and objectives..." add "...individual's or caregiver's..."; last paragraph: consider changing "...clinical..." to "professional";  "...the individual and family or..." should "and family" be removed from this statement?

Pg. 30, first paragraph:  "...the individual’s medical record." add "...individual's or youth's..."; (i): "...individual's recovery..." add "...individual's or caregiver's..."; (ii):  "... individual to actively..." add "...individual or caregiver..."; (iii):  "... individual's medical..." add "...individual's or youth's medical..."; Progress Notes- add an "s" to Family Support Partner; second paragraph: add "...or caregiver..." after "...individual..."; Care Coordination Doc:  "...the individual’s status..." add "...individual's or caregiver's..."; "... in the individual’s record..." add "...individual's or youth's..."; "... individual present..." add "...individual or caregiver..."; last statement: add "...or youth's..." after the word "individual's".

Pg. 32, first paragraph: "... Partners Service..." remove "service" for consistency; third paragraph: "... each individual’s..." add "...individual's or youth's..."; paragraph 6: add "...or caregiver..." after "...individual...".

Pg. 33, first paragraph: consider removing "family" as the sibling will always be a part of the family and targeted youth; third paragraph: is the description of a traumtic brain injury correct?  My understanding is it is not developed organically as Dementia or Alzheimer's are.  It is the result of a trauma to the brain; this would include a stroke, however, should this be clarified/differentiated?

Pg. 34, second paragraph:  should this state with whom we should be registered?  "... Partners shall be registered and..."; third paragraph:  "...Peer Services claims..." add "...Peer Support Services..."; the second bullet point and last bullet point are the same.

I continue to be appreciative of the efforts Virignia is making to professionalize peer support services.  Thank you for allowing me the opportunity to provide feedback on this very important document.


Cristy Corbin, CPRS




6/7/19  7:42 am
Commenter: Fairfax-Falls Church CSB

Peer Recovery Support Services Supplement
This draft appropriately separates the functions of Supervision and Clinical oversight for Peer Recovery Specialists. This is a cost effective strategy, will continue to assure quality services, and will allow programs to be more flexible in how they structure organizations. Importantly, Peer Recovery Specialists with supervisor training and the appropriate years of experience will now qualify to supervise other Peer Recovery Specialists. This capacity is crucial to maintaining a qualified peer workforce with a career ladder, and to providing peer-focused supervision. •Adjust the diagrams for Supervision and Clinical Oversight to reflect the separate functions of Professional Supervision and Clinical Oversight. The Direct Supervisor no longer necessarily connects to the practitioner providing the clinical oversight. That is only one option. •This draft specifies the PRS must have “a current certification by a certifying body approved by DBHDS.” This closes a loophole previously where a PRS could let their certification lapse and maintain registration to provide PRS services. • Define “Caseload” . This may be a straightforward matter to interpret in an outpatient program. However, a PRS may provide very time-limited services in an Emergency Services or similar context where they may not be assigned “cases,” per se. In addition, in many settings, Peer Specialists may provide services to a client not on their “caseload,” for example running support groups. In these groups, some participants may be assigned to a different PRS’s caseload. A definition of “caseload” would answer these questions. • Add to the list of persons who may make a referral for services a peer supporter . If a community partner can make a referral, that would seem to include a peer supporter. However, this should be specified.

6/7/19  5:02 pm
Commenter: Angela Scott, M.Ed.,L.P.C. Supervisor Office of Peer Supports-NRVCS

Peer Supports

We have been working to develop Peer Supports Services for about 2 years locally at our CSB and in our Region 3 of Va. Extensive regulations and extreme low reimbursement rates are the barrier to developing this important service in the Va CSB system. Our agency Director has been very supportive in developing this service. It has been  an  agency team effort. Hiring and training staff Peer staff, and making positions available in program budgets is a challenge in light of the lack of sufficient reimbursement to sustain an entry level fulltime Peer salary and appropriate benefits.  Grants can help start Peer Positions, but without the funding, programs will not be able to design and build the positions within their systems.  It is an important and life saving service that is complimentary to traditional outpatient and also to less traditional community based services.  It is effective in Drug Courts, Medication Assisted Treatment, Mobile and Residential Crisis and inpatient and intensive aftercare service continuums.  The reimbursement rates and regulations can be very discouraging to Behavioral Healthcare Administrators who are working to make financial and staff ends met.   We  believe that we can overcome some of the other related roadblocks like Barrier crimes, Peer Training and supervision and Peer staff retention and advancement...but we must have hope for program administrators to fund Peer Positions.  Please increase funding and simplify regulations so CSBs and others can provide this invaluable complimentary grass roots recovery service. 


6/8/19  12:00 am
Commenter: Keith Richardson


Who handles the cms codes for billing