devilfish once bubbled...
On of them was inflating his bc to the point of the overfllow valve burping. He looked exhaused.
The first step would be to make sure they were positively buoyant and floating face up.
Why were they overfilling the BC, were they over weighted and struggling to get positive or over inflated and fighting it? Did they have back inflation or jacket style BC? Were they in a wet suit or drysuit?
Unless there was some contraindication, I would dump their weights to get them positive.
Then check for breathing!
Are they breathing? If so is the regulator in their mouth? If so do they have ample air supply?
If theyre breathing, calmly tow them to shore while someone monitors their breathing.
If the reg is in their mouth, as long as theyre breathing, leave it there, it lets air in and keeps water out!
If their mask is on, leave it on, it keeps water out!
Only 200 feet from shore Id leave the BC/SCUBA on. Taking it off spends precious time and the tank valve makes a great towing hook allowing you to keep them face up. I find it hard to tow a diver without a BC/SCUBA when I have mine on.
If theyre not breathing, I would get them to shore as fast as possible. I know thats not the PADI rescue line but if nothing else the training convinced me that CPR in the water is not practical. I can swim pretty fast, even towing a second diver, for only 200 feet. With another diver to help I think we would be at shore in less than a minute.