I am concerned that we will see more PSR/Clubhouse programs close because of this draft policy and the ultimate impact will be felt by the vulnerable clients we are trying to serve.  In the smaller rural areas where services and workforce resources are already limited, the ability to move to a highly expensive model, the increased administrative burden- especially documentation,  and clinical oversight for what will be considered a non clinical service is more than challenging; it presents a real threat to our existence.   I hope DMAS finds it possible to re-evaluate the entire draft policy.