Proposed changes to regulations in Chapter IV and Chapter VI appear to contradict each other. Chapter IV, p. 26 appears to propose a change wherein groups must be capped at 10. However, in Chapter VI p. 16, this language is included but crossed out, indicating intention to remove this requirement.

If there is a recommendation to require a 10-person limit to group programming, I would like to recommend against adding a requirement to limit groups to no more than 10 participants for psychosocial rehabilitation. The addition of this requirement would lead to the need for significant staffing additions to support facilitation of several additional groups, which is difficult to justify at the Medicaid reimbursement rate for PSR services. It would also lead to a number of structural changes to programming which are not requested or desired by consumers. Regarding clinical appropriateness of this recommendation, capping a group at 10 is not beneficial for several reasons. When group attendance is capped at 10, it is almost guaranteed that some percentage of individuals enrolled in the group will not attend on a given day due to symptom or other internal or external barriers, leaving the actual real number of attendees in the group much lower than expected. When serving the SMI population in a group setting, medium to large-sized groups are typically more beneficial to allow for increased variability in perspective and individual experience, which promotes participants’ ability to learn from each other. Small groups tend to have lower energy which discourages individuals from sharing and engaging with each other. Larger groups allow more flexibility for consumers to engage and participate in the way that is most beneficial for them. Although smaller groups are beneficial for certain targeted skill-teaching topics such as cooking, most other psychoeducational topics that are best learned through discussion, role-play activities, and other media are better facilitated in a medium to large group setting. Although I cannot speak to clinical appropriateness of this recommendation to other types of group treatment, I can say with confidence that it is not appropriate for psychosocial rehabilitation.