I appreciate DMAS’ continued efforts through Right Help, Right Now to expand recovery focused, evidence based behavioral health services across Virginia. The development of Medicaid-funded Mental Health Clubhouses represents a meaningful step toward social connection, vocational skill building, and long-term community integration for individuals living with serious mental illness.

However, I am deeply concerned about the proposed exclusion of individuals receiving Assertive Community Treatment (ACT) from Clubhouse eligibility. This limitation is not aligned with clinical reality, community need, or the goals of the redesign initiative.

ACT serves Virginians with the highest level of psychiatric, medical, social, and functional impairment, often those most isolated, unemployed, unstably housed, or disconnected from supportive community roles. These are precisely the individuals who would benefit most from the structured work-ordered day, peer relationships, empowerment model, and vocational pathways that Clubhouses provide.

Excluding ACT members creates several unintended yet predictable consequences:

• It restricts access to rehabilitation and recovery, keeping ACT clients clinically stable but socially and vocationally stagnant.
• It increases long-term system costs, as individuals remain dependent on intensive services without opportunities to step down successfully.
• It undermines continuity of care, forcing ACT teams to choose between medical stabilization and psychosocial rehabilitation rather than integrating both.
• It places cities and local safety-net systems at risk, as lack of community connection increases risk for homelessness, incarceration, crisis utilization, and emergency service spending.
• It contradicts recovery-oriented treatment models, which prioritize autonomy, identity, purpose, and meaningful roles—core goals shared by both ACT and Clubhouse services.

Clubhouses are not duplicative of ACT, they are complementary. ACT is clinical, mobile, and medically focused. Clubhouses are member-driven, community based, and vocationally oriented. Together, they create a full continuum that increases the likelihood of sustainable independence, employment, and reduced reliance on publicly funded systems.

If the goal of Right Help, Right Now is not only stabilization but transformation, then Virginia should incentivize, not prohibit the pairing of ACT and Clubhouse participation for those who would benefit.

I respectfully urge DMAS to remove the categorical exclusion of ACT participants and allow clinical discretion, person centered planning, and managed care oversight to determine appropriateness. Doing so supports clients, strengthens communities, and represents a fiscally responsible investment in long-term recovery.

Thank you for the opportunity to comment and for your ongoing commitment to improving behavioral health services across the Commonwealth.