In April, the Substance Abuse and Mental Health Services Administration (SAMHSA) invited public comment on their National Model Standards for Peer Support Certification. The Policy Center for Maternal Mental Health (the “Policy Center”) submitted the following comments, highlighting the need to address state peer training, certification, and reimbursement for peers providing mental health services, as many states have only focused on peers providing support for substance use.
The Policy Center has been leading research and implementation efforts surrounding the use of state-certified peer support specialists for maternal mental health (MMH). Our efforts to extend the use of the certified peer support model to the field of maternal mental health aim to address current barriers to care, including mental health care provider shortages, stigma/shame, and the need for culturally competent care, while doing so in a cost-effective manner. The certified peer support model can enhance the resources and quality of treatment available to both treating providers and mothers at risk for and suffering from maternal mental health disorders.
In April, SAMHSA invited public comment on their National Model Standards for Peer Support Certification. These standards were created to promote the universal adoption, recognition, and integration of peer support across the healthcare continuum. SAMHSA outlined the following proposed eleven key standards for peer support certification:
- Authenticity and Lived Experience: Prospective certified mental health/substance use peer workers should be able to self-attest their personal experience related to a mental health and/or substance use condition and describe strategies utilized to address associated challenges.
- Training: Training should require 35-55 hours, and people with lived experience should play a lead role in the design of training.
- Examinations: SAMHSA outlined key criteria for peer support certification by analyzing state certification examinations. These criteria focused on content, accommodations, development and revision, and format.
- Formal Education: Prospective certified peer workers should be able to demonstrate general literacy and fluency in the language in which they will be providing services.
- Work Experience: Requirements range from 0 to 120 hours of volunteer or paid work experience. Prospective peer support workers should receive a list of approved organizations offering paid experiences for those seeking certification.
- Background Checks: Background checks should be conducted by the hiring organization and should not be a part of the certification process.
- Recovery: Recovery pathway-specific requirements are excluded from verification requirements because pathway-specific recommendations should meet the needs of the populations they serve.
- Diversity, Equity, Inclusion, and Accessibility: Training should include content on cultural competency, anti-racism, discrimination, and implicit bias, and should be designed by under-represented populations. Programs should target recruitment and promote pathways to certification for diverse populations.
- Ethics: Ensure all prospective certified peers adhere to a Peer Worker Code of Ethics.
- Costs and Fees: State certifications should find resources to subsidize all costs or fees or offer scholarships for those with limited resources.
- Peer Supervision: Peer-employing organizations should incorporate core elements from the 5 Pillars of Peer Support Supervision.
It’s important to note that though the federal government is sharing these model standards for state peer support certification, all 50 states already have a certification process in place. We have, however, identified gaps most notably:
- Not all states have training and/or certification in place for peers delivering mental health services (many only train and/or certify for peers delivering substance use support). It’s important for states to have training and certification in place for peers providing mental health services to populations suffering from serious mental illness (SMI) and non-SMI, such as those suffering from depression and anxiety.
- Not all state Medicaid programs reimburse peers providing mental health care (some only reimburse for substance use peer support services)
- Most private insurers aren’t credentialing or reimbursing peer support specialists, essentially leaving those with private insurance without coverage of peer support.
In response to the National Model Standards for Peer Support Certification, the Policy Center recommends the following:
- A more robust approach to facilitating and encouraging reciprocity of certification between states, with a recognition of the important role of virtual peer support. Maternal mental health peer support has found success on a virtual platform due to the demand to meet mothers where they are, as mental health issues have been further exacerbated during the pandemic. It is critical to implement actionable plans to create reciprocity between states to further facilitate peer support virtually across state lines, particularly for states with the highest HRSA mental health provider shortage areas.
- Consider the need for establishing and developing a more systemic infrastructure to help organizations navigate the hiring, billing, and reimbursement process of peer services. Currently, the reimbursement process can be quite complicated for individuals or groups that are new to peer support, including becoming a Medicaid provider, billing, and reimbursement. This is a significant barrier to entry for hiring peers among sophisticated healthcare providers and for individual peers alike. This is also a barrier for community-based organizations that generally don’t have the experience or funding to establish reimbursement protocols on their own.
The Policy Center is grateful for the opportunity to provide feedback on this National Model Standard of Peer Support.
