Summary of Concerns Regarding Proposed Clubhouse Service Requirements

Exclusion of Members Who Receive ACT Services

•  Clubhouse participation is being restricted for individuals who also receive ACT services. 
• This is highly concerning, as many members benefit from both supports simultaneously.
• ACT is explicitly therapeutic and clinical, while Clubhouse is non-clinical and rehabilitative; the two services are fundamentally different and often complementary.
• Excluding ACT recipients removes access for a population already thriving in the Clubhouse setting.

Contradiction Regarding On-Site/Off-Site Support at Community Business Worksites

• The document states that Clubhouses may provide on-site and off-site support at community business worksites.
• However, it later states that "staff presence in the workplace to assist with supervision or teaching of routine work duties is not reimbursed."
• These statements conflict: supported employment inherently requires staff presence, guidance, and teaching.
• This contradiction creates uncertainty and makes implementation nearly impossible.

Diagnostic Criteria and "Related Disorders"

• The use of the term "related disorders" is unclear and undefined.
• It is unknown whether this category includes common and highly prevalent conditions such as Anxiety Disorders, Depression or PTSD.
• Requiring additional physician documentation for authorization - especially when diagnoses are already established - seems excessive and may delay access to needed services.

Contradiction with Clubhouse Standard: Membership Without Time Limits

• The foundational Clubhouse standard states that membership is voluntary and without time limits.
• However, MCO requirements appear to impose time-limited enrollment or periodic reauthorization expectations.
• This conflicts with the international Clubhouse model and undermines core principles of continuity, belonging, and long-term community support.

Non-Billable Time and "Observation Without Intervention"

• The rule that "observation without intervention is not billable" would prevent billing for members who:
  • attend but do not actively engage,
  • rest,
  • keep to themselves,
  • have days of low energy or low participation.
• Many members rely on the Clubhouse as a safe, stabilizing, therapeutic (though non-clinical) environment, even when not actively producing work.
• This requirement would unintentionally exclude the very individuals who need the Clubhouse most.

Non-Billable In-House Educational Opportunities

• The proposed guidelines categorize in-house educational programming as non-billable.
• This contradicts official Clubhouse standards (e.g., Standard 25), which emphasize member access to in-house and community-based educational opportunities.
• Education is a key component of rehabilitation and recovery within the Clubhouse model.

Restriction on Concurrent Clubhouse and Community Stabilization Services

• Members are prohibited from receiving both Clubhouse and Community Stabilization services.
• This exclusion may prevent individual from receiving stabilizing supports that help them recover from crises and transition back into routine participation.