The burden of having to create an employment program (transitional and supported) in the CI model is out of the scope of and excessive for this program and the population. Many of the members within the program are either not capable due to disability or don’t desire to have full employment but do enjoy and benefit from the side-by-side work ordered-day tasks they are able to complete. Many of the CSB’s already have some type of employment programs that are offered to the members,  and having two separate employment programs within a CSB would create competition issues within already scare community resources. Furthermore, in these rural areas (which is most of Virginia) finding a suitable employer within four years who is willing to establish such a relationship is markedly unobtainable. Additionally, this model does not account for other barriers such as transportation.  As DMAS has repeatedly been made aware, our members’ main complaint is the lack of adequate, affordable, and readily available transportation. These issues are exacerbated in our rural communities. Most areas where Clubhouse’s would serve are rural and do not have access to public transportation that would be available for the hours of which members may be employed and with such limited staffing ratios, Clubhouse staff would be unable to ensure transportation.