Thank you for proving us the opportunity to offer recommendations to the proposed regulation changes. We have reviewed the changes and have the following recommendations: 

3.3 Training Requirements & 3.5 Provider Accreditation

The staff training requirements and provider accreditation cost do not match the rate of reimbursement. The additional cost and administrative burden is not budget neutral nor sustainable for Clubhouse programs to remain operational. 

4.2 Service Planning

The proposed regulation states at a minimum, the ISP shall be signed within 30 days of admission or 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 the ISP instead of the Program Director or LMHP. With the shortage of LMHP or LMHP-type, this is an unnecessary burden.

4.4 Crisis Support 

The proposed regulation 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 what qualifies a person to provide crisis support. 

8.3 LMHP Review

The proposed regulation states that an LMHP must review the documentation of all non-LMHP staff at least every 30 calendar days. However, Clubhouse 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. With the shortage of LMHP or LMHP-type, this is an unnecessary burden.