AHCS appreciates the opportunity to provide feedback on the proposed Mental Health Clubhouse Services. Below are several concerns regarding the proposed Clubhouse Model. 

3.1 Staff requirements 

• The staffing and leadership requirements may present challenges to sustainability. The requirement for a full-time program director with specialized training in conjunction with a LMHP, increases additional financial burden. With LMHP workforce shortages, these requirements may limit some from implementing a sustainable model. 
• Staff to member ratio shall be one staff to 20 members or fewer during program hours. This will reduce the individualized supports with emphasis on group-based programming. 
• The required staff training required by the Clubhouse International Model - will funding be available? What is the expectation for the training - all staff, program director, & how often etc. The rate of reimbursement does not support staff training requirements, please consider rate of reimbursement review.

3.4 Licensing and Enrollment Requirements

• If PSR requires external accreditation for the Clubhouse International Model, consideration for alignment with DBHDS licensing requirements to reduce the administration burden for annual reviews. 

3.6 Clubhouse Operation Requirements

• The requirement for an independent board of directors may be a difficult requirement for CSB's who already have an existing Board of Directors. Please consider an advisory council of program leadership and members in place of the independent board of directors. 
• Clarification is needed for holidays accepted by the  Clubhouse International Model, most CSB's have existing holidays embedded in their operations.