When the Massachusetts Department of Mental Health received a mix of both statewide, group, and individually written letters about the new Adult Community Clinical Services (ACCS) model and peer roles, they listened. For the first time ever, they stated that administration of medication was not to be seen as part of a peer role, and neither was management of a representative payee relationship, and so on. When it came to documentation, they were a bit vaguer, but still said something very important. Here’s exactly what they said:
“Documentation completed by a Certified Peer Specialist is to be done in accordance with CPS training standards.”
Although many would have preferred a more definitive “Peer Specialists shouldn’t participate in documentation” as was called for by the majority of people in peer roles across the state, this was nonetheless an important gain. It was important because while it doesn’t in and of itself prohibit documentation on individuals in ACCS by people working in Peer Specialist roles, it does certainly suggest that the Certified Peer Specialist training has the power to set standards that say just that.
In fact, the Massachusetts Certified Peer Specialist (CPS) training is clear on the matter. First, CPS addresses the issue in an indirect way through its Code of Ethics (COE). The COE emphasizes respect for privacy, self-determination, and advocating with rather than for anyone being supported. While someone working or otherwise existing outside of the CPS peer-to-peer framework may not see it as obvious, these principles do in fact suggest that is not okay for someone in a peer role to take the responsibility for being the voice that reports back to the clinical team, especially in any routine manner. Privacy and self-determination are priorities in the relationship, as is supporting someone to find or get back their own voice and speak for themselves. The CPS Core Competencies also includes being “In But Not Of” the system. This also reinforces the idea that someone working in a peer role is indeed working within the system, but that they should not be operating according to its internal systems, documentation being just one example.
Now, in order to understand all of that, one may need to have already gone through the training and had opportunity to discuss all the ins and outs and implications. However, for those who have less experience or access to the training itself, there is also a CPS module specifically on documentation. Here are the module’s learning objectives:
- Identify at least two reasons why documentation compromises the CPS role
- List three values reflected in the CPS Code of Ethics that CPSs can use to advocate for not documenting
- Review at least three different ways that a CPS can document meetings with a person they support in a harm-reduction manner when advocacy for not documenting has been unsuccessful
Some have attempted to suggest that the third objective (harm-reduction strategies for documentation) serves as an “okay” from the CPS training for Peer Specialists to document. That is not correct. Harm reduction strategies are meant only for people who are being forced by an employer to go against their Code of Ethics, and to do as little harm as possible while being so forced until the issue can be corrected. It is NOT meant as a pass to providers to keep justifying documentation. However, in spite of the implied prohibition of routine note taking in the Code of Ethics, and the more open prohibition suggested in the Documentation module learning objectives for the CPS training, some continue to argue that documentation is not expressly prohibited by the CPS training as a routine practice. For those individuals, we would refer you to the body of the CPS module on Documentation where it lists out “Reasons NOT to Document”. In that section, the module identifies nearly a dozen reasons not to document including the following:
“[Documentation] violates the Certified Peer Specialist Code of Ethics, particularly the ethics of confidentiality, self-determination, and mutuality.”
This is not a vague statement. It tells us clearly and without hesitation that the CPS training and Code of Ethics do not support documentation. Therefore, any provider organization that requires or allows people in peer roles to participate in routine documentation systems is acting in violation of both the Massachusetts Certified Peer Specialist Code of Ethics and training, and—as a result— it would appear they are also acting in violation of any Adult Clinical Community Service (ACCS) contracts they may hold with the state’s Department of Mental Health.
The question should no longer be whether or not people in peer roles should be documenting. Rather, we should be asking ourselves: “What potential challenges are we left with when we accept that people in peer roles don’t do routine documentation, and how do we overcome them?”
Other resources that support no documentation for peer roles: