Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
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11/20/25  9:19 am
Commenter: Rappahannock Area Community Services Board

Restrictions That May Limit Member Participation
 
  • Prohibiting clubhouse participation for individuals who are also enrolled in ACT is a major concern since it excludes a population that currently benefits from clubhouse involvement.
  • The statement that “observation without intervention is not billable” would prevent billing for members who attend but do not interact—such as those who rest, keep to themselves, or have low-engagement days—potentially excluding individuals who rely on the clubhouse as a safe, therapeutic environment.
  • The policy appears to conflict with the foundational clubhouse principle that membership is without time limits, while MCOs seem to push for time-limited enrollment.
CommentID: 237835