It is concerning that the draft Clubhouse regulations exclude Assertive Community Treatment for individuals receiving Clubhouse services. SAMHSA's National Outcome Measures (NOMs) include social connectedness as a key indicator of recovery, assessing how individuals are connected to their communities. Many individuals who meet criteria for ACT services require intensive case management support precisely because they struggle with community integration and social isolation—the very issues that Clubhouse is designed to address. For these individuals, the structured social environment of Clubhouse provides essential opportunities to build meaningful connections and develop recovery-supporting relationships. Excluding ACT recipients from Clubhouse services removes a critical recovery support for some of the most vulnerable individuals in the system.

Recommendation: Retain the current structure that allows individuals to receive ACT and PSR/Clubhouse concurrently, with strict guidance to avoid overlapping billing.