Here are my concerns/thoughts so far:

-The description of the activities listed in the “Required Service Components” seem like they overlap with Case Management, ES, and Skill Building.

-RSB activities listed (section 3.3) include on site and off site support at a community business worksite, and then later in the document it says that “staff presence in the workplace  to assist with supervision or teaching of routine work duties is not reimbursed". This seems contradictory

-The note requirements seem to be more in line with the way Residential/skill building does the notes, which will be a big change from how they are now, where we write monthly progress notes that are more generalized on how they are making progress

- Very concerned about not being able to serve clients who also have ACT. Sometimes they need both. ACT is therapeutic, and clubhouse is not intended to be so. 

-With the requirements dictated by this and the CPST, the intake assessments must be way more thorough than they are right now. If we have to create authorizations within one day (currently we have a week window), and have the assessments completed prior to enrollment, rather than as part of our enrollment process, we will need them to be incredibly detailed. This also puts a higher burden on the intake therapists to have detailed knowledge of the clubhouse program in order to understand how to word the assessments.

-“Any observation without an intervention is not a billable activity” Does this mean that we cannot bill for someone who comes to the program and doesn’t interact directly with staff? Sometimes, when dealing with SMI, a person is making progress just by showing up. Currently our program has 85 members, running around 30 ish people a day. How are we supposed to fit two specific billable activities in for every person in 8 hours? Clubhouses are supposed to be member run. Does this mean that if a member is doing things on their own without staff support that we cannot bill?

-Maximum member to staff ratio of one staff for 15 members- we are already pushing it with 7 staff and 85 members. We would not be able to increase our membership without increasing staff. However, these policies seem to be pushing for a smaller program in general. It would be very difficult to bill for all 30 ish people in one day if we can only bill for direct interactions, not just observations.

- Diagnostic Criteria: What are “related disorders”? Does that include Anxiety, Depression, and PTSD? Requiring the extra physician documentation to be included in the authorization seems excessive.

- The included chart on page 7 is confusing. Is this just an example? Right now we can bill max 360 units per six month period, but the example shows only 240 units a year.

- Section 9: It states that one unit of service is one day. Currently we get 3 units per one day per person.

- The very first clubhouse standard is that membership is without time limits, and yet it appears that the MCO’s want to limit the time a person is enrolled. This is contradictory.

-There is a standard ( standard 25) that supports in house education opportunities, and yet that is on the list of non- billable activities.