Excluding Members Who Receive ACT Services: Restricting Clubhouse access for ACT recipients is concerning. ACT is clinical and therapeutic, while Clubhouse services are non-clinical and rehabilitative. They serve different purposes and often complement each other. Exclusion removes essential support for members who benefit from both.

Conflicting Guidance on On-Site/Off-Site Support at Worksites: The document permits on-site/off-site support at community worksites but later states that staff presence for supervision or teaching is not reimbursable. Supported employment requires staff presence; this contradiction creates implementation barriers.

Undefined “Related Disorders” and Excessive Documentation: “Related disorders” is not defined, leaving unclear whether common conditions (e.g., anxiety, depression, PTSD) qualify. Requiring additional physician documentation despite established diagnoses is burdensome and may delay services.

Conflict with Clubhouse Standard of Membership Without Time Limits: Clubhouse standards require voluntary, time-unlimited membership. MCO expectations for time-limited enrollment or repeated reauthorization conflict with the international model and undermine continuity and long-term support.

Non-Billable “Observation Without Intervention”: Prohibiting billing for observation without intervention excludes members who attend quietly, rest, or have low-energy days. Clubhouse is a safe, stabilizing, non-clinical environment even when participation varies; this rule risks excluding those who need it most.

Non-Billable In-House Educational Activities: Making in-house education non-billable contradicts Clubhouse standards, which prioritize access to both in-house and community-based educational opportunities—central components of rehabilitation and recovery.

Restriction on Clubhouse + Community Stabilization: Prohibiting concurrent Clubhouse and Community Stabilization services prevents members from receiving critical supports during crises or transitions. Clubhouse participation itself is often stabilizing; restricting it is counterproductive.

The overall impact to these requirements narrows the access, contradicts established Clubhouse standards, and creates barriers for individuals with significant needs—those who rely on flexible, recovery-oriented, community-based supports.