After reading the new regulations for clubhouse services there are several areas of concern. 

-According to Clubhouse International it is once a member always a member.  This does not align with MCO’s that have already been denying services stating that Clubhouse is not a lifelong services.

-CI puts an emphasis on Employment and training/support opportunities for employment, yet one of the non-reimbursable activities is Staff presence in the workplace to assist with supervision or teaching of routine work duties.  How is that not reimbursable if that is the primary focus of CI?

-CI also puts an emphasis on Education, but onsite Education support is not a reimbursable activity.  This seems to contradict one of CI’s basic foundations. 

-“Any observation without an intervention is not a billable activity.  Sometimes observing and allowing the individual to problem solve themselves is the intervention.  How is that not reimbursable?

-CI does not focus on symptom management/education but this would be essential for members wanting to gain employment as managing symptoms would be a key component of maintaining the employment.