1. Exclusion of Members Who Receive ACT Services

• Clubhouse participation is being restricted for individuals who also receive ACT services.
• This is highly concerning, as many members benefit from both supports simultaneously.
• ACT is explicitly therapeutic and clinical, while Clubhouse is non-clinical and rehabilitative; the two services are fundamentally different and often complementary.
• Excluding ACT recipients removes access for a population already thriving in the Clubhouse setting.

2. Contradiction Regarding On-Site/Off-Site Support at Community Business Worksites

• The document states that Clubhouses may provide on-site and off-site support at community business worksites.
• However, it later states that “staff presence in the workplace to assist with supervision or teaching of routine work duties is not reimbursed.”
• These statements conflict: supported employment inherently requires staff presence, guidance, and teaching.
• This contradiction creates uncertainty and makes implementation nearly impossible.

3. Diagnostic Criteria and “Related Disorders”

• The use of the term “related disorders” is unclear and undefined.
• It is unknown whether this category includes common and highly prevalent conditions such as Anxiety Disorders, Depression, or PTSD.
• Requiring additional physician documentation for authorization—especially when diagnoses are already established—seems excessive and may delay access to needed services.

4. Contradiction with Clubhouse Standard: Membership Without Time Limits

• The foundational Clubhouse standard states that membership is voluntary and without time limits.
• However, MCO requirements appear to impose time-limited enrollment or periodic reauthorization expectations.
• This conflicts with the international Clubhouse model and undermines core principles of continuity, belonging, and long-term community support.

5. Non-Billable Time and “Observation Without Intervention”

• The rule that “observation without intervention is not billable” would prevent billing for members who:
• attend but do not actively engage,
• rest,
• keep to themselves, or
• have days of low energy or low participation.
• Many members rely on the Clubhouse as a safe, stabilizing, therapeutic (though non-clinical) environment, even when not actively producing work.
• This requirement would unintentionally exclude the very individuals who need the Clubhouse most.

6. Non-Billable In-House Educational Opportunities

• The proposed guidelines categorize in-house educational programming as non-billable.
• This contradicts official Clubhouse standards (e.g., Standard 25), which emphasize member access to in-house and community-based educational opportunities.
• Education is a key component of rehabilitation and recovery within the Clubhouse model.

7. Restriction on Concurrent Clubhouse and Community Stabilization Services

• Members are prohibited from receiving both Clubhouse and Community Stabilization services.
• This exclusion may prevent individuals from receiving stabilizing supports that help them recover from crises and transition back into routine participation.
• For many, Clubhouse involvement is itself a stabilizing factor; restricting access during or after crises is counterproductive.

Overall Impact

Collectively, these proposed requirements risk narrowing access, contradicting established Clubhouse standards, and creating barriers for members who depend on flexible, recovery-oriented supports. They may inadvertently exclude individuals with the highest needs—those who benefit from the combination of community, structure, education, and rehabilitative engagement that Clubhouses provide.