Thank you for the opportunity to submit public comment on the proposed policy changes related to the Clubhouse service model. As PSR services transition under this new framework, I am concerned that the scope and intensity of the proposed requirements will result in additional PSR program closures across Virginia. Many programs are already closing or planning to close due to the financial burden, staffing demands, and administrative complexity associated with this transition. Without adjustments to ensure feasibility and sustainability, these changes risk significantly reducing access to critical recovery supports for individuals served through PSR and Clubhouse programs statewide.
I agree with many of the comments already made in this forum. Thank you for the review and consideration of the following points:
The policy would benefit from greater clarification regarding the role of the LMHP. If the expectation is that an LMHP must review and sign all documentation, including daily notes, this requirement would necessitate a full-time, on-site LMHP rather than a part-time role. The time required for this level of review is significant and exceeds documentation standards set by Clubhouse International.
Please clarify the frequency and scope of the required two-week staff training. Additionally, guidance is needed on how programs should manage staff turnover if an employee completes the training but leaves before transferring knowledge to other staff.
Clarification is requested regarding the distinction between the annual comprehensive needs assessment and the authorization process. It is unclear how these differ and whether they could be consolidated. Additional guidance is needed to align requirements outlined in Sections 4 and 7.
Staff who are qualified to complete Individual Service Plans (e.g., QMHPs) should be permitted to sign the ISP alongside the member. Please remove the requirement for ISP review and signature by an LMHP or Program Director.
Section 4.3.13 should clarify that social skill development activities may occur during all program hours, not exclusively during evening, weekend, or holiday programming.
Further clarification is needed regarding what qualifies as the ability to provide crisis support. I also support the concerns and recommendations related to crisis support planning raised in comments submitted by HopeLink.
The continued stay criteria appear to conflict with Clubhouse International Standard 2 of Membership, which emphasizes member choice and voluntary participation. Clubhouse standards explicitly state that there are no contracts, schedules, or rules intended to enforce member participation.
Please reconsider the additional documentation requirements outlined in Section 8. Currently, a monthly note is required; adding a weekly note significantly increases administrative burden. If the intent is for the weekly note to replace the monthly note, this should be clearly stated. Additionally, the weekly note appears redundant of daily notes, and the requirement for an attendance table duplicates information already captured in daily logs.
Overall, the LMHP review and signature requirements outlined in the current draft represent an excessive administrative burden, particularly when combined with the LMHP’s other clinical and supervisory responsibilities.