The CSB supports the inclusion of Clubhouse Services as part of the behavioral health continuum and appreciates the emphasis on recovery-oriented care.

Model Fidelity and Accreditation
Clubhouse programs must align with international standards emphasizing voluntary participation and community engagement. Accreditation timelines should be extended to 36 months to allow program development.

 Workforce and Capacity
Staffing models must reflect the non-clinical nature of Clubhouse services. Overly prescriptive requirements may limit scalability and reduce access.

 Caseload and Engagement Capacity
The Clubhouse model depends on meaningful member engagement. Excessive requirements may reduce staff availability and limit participation capacity.

 Coordination with Other Services
Clubhouse services should operate alongside clinical services when appropriate. Flexibility is essential.

 Crisis System Alignment
Clubhouse programs are not crisis providers. Requirements should not delay or interfere with referral to 988 or Mobile Crisis, as doing so may create safety risks.

 Documentation and Administrative Burden
Documentation requirements should reflect participation and recovery, not clinical treatment standards.

 Implementation and System Impact
Implementation will require coordination across systems, staff training, and EHR alignment. A 12–24 month phased rollout is recommended.

 Conclusion
The CSB recommends maintaining fidelity to the Clubhouse model, extending accreditation timelines, ensuring flexibility, and aligning policies with existing crisis systems to support safe and effective implementation.