3.3 Staff Training Requirements The rate of reimbursement does not support staff training requirements, therefore this needs to be further reviewed considering the initial 2-week duration of training and staff turnover.

Please provide clarification on the frequency of staff training requirements, i.e. annual.

7.2 Service Authorization Period and Unit Allocation The need for stability is not addressed for individuals.

9.1 Mental Health Clubhouse Services Billing Code Rate does not support the various cost requirements including, but not limited to accreditation, staff training, and facility costs.