Caliber Virginia appreciates the opportunity to provide feedback on the proposed Mental Health Clubhouse Services as part of the Commonwealth’s Right Help, Right Now behavioral health redesign initiative. We recognize the value of psychosocial rehabilitation and community integration models and support the inclusion of diverse service options within Virginia’s behavioral health system.

However, we have several concerns regarding the structure and implementation of the proposed Clubhouse model and its potential impact on service delivery, workforce stability, and access to care.

First, the Clubhouse model represents a significant shift away from traditional, higher-intensity rehabilitative services. The emphasis on group-based, work-ordered day programming and a staff-to-member ratio of up to 1:20 may reduce the level of individualized support available to members. Many individuals currently served through high-touch, community-based services require consistent, hands-on interventions to maintain stability. A reduction in individualized attention may increase the risk of disengagement, decompensation, and utilization of higher levels of care.

Second, the staffing and leadership requirements may present challenges for provider sustainability. The requirement for a full-time Program Director with specialized training, along with ongoing Licensed Mental Health Professional (LMHP) involvement, introduces additional staffing costs. Given current workforce shortages, particularly among licensed professionals, these requirements may limit the number of providers able to successfully implement this model.

Third, the proposed documentation and operational requirements represent a notable increase in administrative burden. The introduction of daily attendance logs, weekly progress notes, structured service planning timelines, supervision requirements, and ongoing accreditation processes will require significant administrative oversight. While accountability is important, these expectations may divert resources away from direct service delivery if not supported by appropriate reimbursement structures.

Additionally, the requirement to obtain and maintain Clubhouse International accreditation introduces both financial and operational challenges. Smaller and community-based providers may face barriers in meeting accreditation timelines and requirements, which could reduce provider participation and limit geographic access to services.

We also note the importance of ensuring that the Clubhouse model is implemented in a way that supports equitable access. Individuals in underserved communities may face barriers to consistent participation in structured, location-based programming due to transportation, employment, and family obligations. Flexibility within the model will be critical to ensure these individuals are not unintentionally excluded.

Recommendations:

Caliber Virginia respectfully recommends the following:

• Maintain flexibility in staffing ratios to allow for increased individualized support when clinically appropriate
• Align reimbursement with administrative, supervision, and accreditation requirements
• Provide phased implementation timelines to support provider readiness and workforce development
• Offer flexibility in program structure to accommodate individuals with barriers to daily participation
• Consider alternative pathways for accreditation or extended timelines for smaller providers

Caliber Virginia remains committed to working collaboratively with DMAS to ensure that the implementation of Mental Health Clubhouse Services enhances access to care while maintaining service quality, workforce stability, and provider sustainability across the Commonwealth.