-We have concerns regarding the transportation of individuals. We do not offer daily  transportation over holidays, weekends, etc. and we do not have readily available public transportation in our area. 

-The requirement to submit authorizations within one business day is an extremely tight turn around time, especially when we do not hear back from some MCO companies regarding an approval or denial in the 14 days that they currently have to respond. 

-The 24/7 crisis coverage that does not extend to our CSB emergency services program. The idea that QMHP staff will have to provide crisis response to members as opposed to deferring to the internal emergency services staff is an added layer that complicates the role of the QMHP within Clubhouse. We should be able to use internal supports like our emergency services staff in these situations. If we are not able to do this, we should be able to utilize peer support, with established guardrails in place. 

-The accreditation and training piece that is required is going to take time and money, which is going to be challenging considering how the billable rate for Clubhouse is being directly affected. 

-The revised hours of operation (including holidays) is unreasonable. We are limited from a staffing perspective and to expect staff to take time away from their families to provide Clubhouse services when historically we have been closed does not support good employee care or work/life balance. 

-The requirement to have a licensed staff review all notes monthly is an added administrative burden. 

-We would like clarity on what additional information will be required to submit from a physician when submitting authorizations? This will lead to additional time, making the one day turn around submission time extremely challenging.