Thank you for the opportunity to provide public comment regarding the proposed changes to Psychosocial Rehabilitation Services and related service requirements. As an established Psychosocial Rehabilitation Services (PSR) program, we are deeply concerned about the significant negative impact these changes will have on our ability to serve members—many of whom have been stable and successful in our current model of care.
1. Excluding ACT and Coordinated Specialty Care clients is harmful.
Many of our members are ACT clients, and the proposed prohibition on serving ACT-enrolled individuals will not be beneficial in any way. This change would greatly reduce access to needed services and will likely result in members losing support they rely on. We are already seeing insurance denials stemming from this shift. Removing ACT clients from eligibility puts some of our most vulnerable members at risk of losing essential PSR services.
2. Our members are satisfied with our program and may be forced to leave, or may not fully participate in this new model.
As an existing PSR program, we have built a strong, supportive environment where members consistently report positive experiences. These proposed changes jeopardize that stability. Some members may no longer qualify under the new rules, despite benefiting significantly from the services they currently receive. We are concerned that this proposed model allows more opportunity for members to be present without engaging or participating. Under our current structure, we see meaningful progress because we actively and consistently encourage participation, offer structured activities, and engage members throughout the day.
If members are permitted to enroll but not participate, their outcomes will suffer, and programs like ours may appear ineffective despite our best efforts. We may also lose members who have thrived under the expectations and structure we currently provide.
3. Overlap and contradictions within the Required Service Components.
The activities listed under “Required Service Components” closely resemble Case Management, Emergency Services, and Skill Building functions, raising concerns about role clarity and reimbursement.
Additionally, Section 3.3 states that RSB activities include onsite and off-site support at a community business worksite, yet later indicates that staff presence in the workplace for supervision or teaching routine job duties is not reimbursable. This contradiction creates confusion about what is allowed.
4. Documentation expectations appear misaligned with current PSR practice.
The proposed note requirements resemble Residential or Skill Building documentation standards. This represents a major shift from PSR documentation and will require considerable workflow changes.
5. Increased intake and authorization demands are unrealistic.
Requiring full assessments prior to enrollment and authorizations completed within one day is not feasible without added staff. Currently, we have a week to submit authorizations, and assessments are completed as part of enrollment. The proposed changes would require far more intensive assessments upfront, placing strain on both staff and members.
6. “Observation without intervention” being non-billable is concerning.
Many PSR members attend for therapeutic structure and a safe space, even when they are not actively interacting. Some may spend time resting or stabilizing. If these quiet or observational periods are not billable, PSR programs will struggle to support individuals who benefit from a supportive milieu rather than constant engagement.
7. Member-to-staff ratio and billing limitations are unrealistic.
A 1:15 ratio is challenging in practice. These policies seem to push programs toward much smaller membership, reducing access.
If billing is limited only to direct interventions and not therapeutic presence, it becomes even more difficult to meet daily billing expectations.
8. Diagnostic criteria and required documentation need clarification.
The term “related disorders” is unclear—does it include Anxiety, Depression, or PTSD?
Requiring additional physician documentation for every authorization seems excessive and may delay or disrupt continuity of care.
9. Concerns about the financial burden associated with Clubhouse International.
If programs are expected to transition toward or align more closely with Clubhouse International standards, it is important to acknowledge the significant cost this places on agencies. Clubhouse International accreditation, training, travel, and required staffing structures can be expensive.
For many CSBs and community programs, these costs are not feasible within current reimbursement structures—especially if proposed billing reductions and unit limitations take effect. Expecting Clubhouse-level standards without providing the financial support to meet them is unrealistic and places programs at risk of losing sustainability.
10. The chart on page 7 and unit definitions are confusing and inconsistent.
Currently, we can bill up to 360 units per six-month period, but the example chart shows only 240 units per year. Section 9 also states that one unit equals one day, whereas we currently receive three units per day. These significant reductions would undermine program stability.
11. Time limits contradict foundational Clubhouse standards.
The first Clubhouse standard states that membership is without time limits, yet the proposed changes appear to move toward limiting a person’s length of enrollment. This contradicts the evidence-based model.
12. Education activities labeled as non-billable conflict with established standards.
Standard 25 supports in-house educational opportunities, yet these are listed as non-billable activities. This restriction would limit meaningful programming that supports recovery and skill development.
Conclusion
Overall, these proposed changes would reduce access to services, destabilize current members who are succeeding in our PSR program, introduce significant financial burdens, and contradict both the clinical needs of the population and the established Clubhouse model. We respectfully request reconsideration of these changes and clearer alignment with current PSR standards, funding realities, and the needs of the individuals we serve.