Thank you for allowing us the opportunity to offer recommendations to this policy. We have reviewed all policy changes and have the following recommendations.

3.1 Clubhouse Staff Requirements

The policy states a full-time Program Director with the Clubhouse International training who holds a current, active, and unrestricted Virginia registration or license from the Department of Health Professions. Recommend that it offers flexibility that it be from program leadership and not specifically the Director of the program.

3.3 Staff Training Requirements

The policy states all staff are required to receive training as required by Clubhouse International and all newly DMAS enrolled Clubhouses shall send a team to an authorized Clubhouse International training based within the first 12-18 months of operation, and staff are expected to participate in training or specialized tracks as a condition of maintaining accreditation in good standing. The rate of reimbursement does not support staff training requirements. Recommend that this be further reviewed considering the initial 2-week duration of training and staff turnover.

3.4 Licensing and Enrollment Requirements

The policy states that providers shall submit with their DMAS enrollment application evidence of their initiation of the accreditation process or their formal accreditation with Clubhouse International. However, if the service requires external accreditation for "Clubhouse International", there should be consideration for alignment with DBHDS licensing requirements to reduce administration burden for annual reviews.

3.6 Clubhouse Operation Requirements

The policy states the Clubhouse shall have an independent board of directors, or affiliated with a sponsoring agency, shall have a separate advisory board comprised of individuals uniquely positioned to provide financial, legal, legislative, employment development, consumer and community support and advocacy for the Clubhouse. However, an independent board of directors' requirement is a difficult requirement for CSBs who have existing board of directors. Recommend that you consider an advisory council comprised of program leadership and members.

4.2 Service Planning

The policy states at a minimum, the ISP shall be signed within 30 days of admission and 15 days of an ISP review by the Program Director or LMHP/LMHP-type performing the assessments. The Clubhouse International Model is not a clinical service, therefore, recommend allowing the staff providing the service to sign it instead of the Program Director or LMHP.

4.4 Crisis Support

The policy states when a member is present at the Clubhouse during program hours and a crisis occurs, the Clubhouse shall provide immediate, on-site crisis support. At least one staff qualified to provide crisis support shall be available in-person during program hours to respond to member crisis without delay. Recommend clarifying individualized service plan requirements and what qualifies a person to provide crisis support.

8.3 LMHP Review

The policy states that an LMHP must review the documentation of all non-LMHP staff at least every 30 calendar days. However, this is not a clinical service and recommend it be sufficient for the staff providing the service to review and sign the documentation every 30 calendar days.