I urge you to reconsider some of these non-authorized concurrent services, specifically but not limited to Coordinated Specialty Care. I understand that some of the CSC members are under 18, so developing a caveat that CSC members 18 and older would be eligible is a reasonable request. I believe  (and have seen in many member cases) that the CSC population is an exceptional category of individuals who benefit from the various Clubhouse (as it stands) programming. The CSC population in general present with difficulty in educational and vocational arenas including disruptions in school, dropouts,  as well as issues establishing and maintaining employment. Clubhouse International standards indicate supports and services for not only a work- ordered -day that would allow these young members to learn how to build a routine but also gain access to employment and educational supports all within house. Many of the CSC population are socially isolated, having withdrawn from many previous social life aspects because of their symptoms. Having access to a supported environment such as  a Clubhouse that offers social opportunities for reestablishing or forming new natural supports would only strengthen member recovery. Having both services (CI and CSC) would be a substantial support to aid our struggling youth in their long road of recovery.  Additionally, the disallowance of the other services such as ABA, ARTS, COMM STAB, FFT, MST, etc… , does not support the idea of long- term recovery and maintenance of serious mental illness. Many of our members will likely need and benefit from these types of service episodes throughout their lives.  It would be better for the members and payors to allow these services as needed in order to keep the member in a lower level of care, with the goal being to reduce the burden on hospitalizations and crisis services.  These services need to be on a continuum of care- ongoing, as needed and throughout the duration of the illness and not as separate isolated services. We know our members often need a variety of wrap around services to maintain community tenure, out of a hospital level of care.

Also, I believe in the CPST draft, it excluded Clubhouse programs. This would certainly be a disservice considering how little of actual face- to -face billable time a recipient of CPST will be receiving.  A member would likely have a great routine with a combination of both CPST and Clubhouse. Currently, there are many members who benefit from the group aspect of Clubhouse and the individual aspect of MHSS. These programs have worked extremely well for years together, and we’ve seen the things a member is attempting to learn in one service, they are able to then practice that skill in the other service until they can generalize it to their everyday life. This allows for opportunities for normalization of skill sets in variable environments.