Please find our concerns and needed clarifications on the Mental Health Clubhouse Services (Clubhouse). Thank you.

Concerns:

-Limits on certain service lines and housing situations impacting qualification to participate with the service when The Clubhouse Model is defined as open to any person experiencing mental illness (Assertive Community Treatment and Sponsored Residential limits will impact approximately 1/3 of those currently attending.) These individuals will lose social supports currently in place.

-Limits on qualifying diagnoses without letter from physician could potentially impact approximately ½ of those currently attending. Would it be possible to consider expanding eligible diagnoses to those listed in definition of serious mental illness as well as those with significant trauma history without requiring documentation from physician?

-Navigating various regulations/requirements (DMAS, CCBHC, Licensure, Agency, Authorizations, etc.) in addition to International Clubhouse accreditation standards when regulations don’t fully align.

-Barriers with developing supported/independent employment and housing resources in a rural area with limited funding and transportation.

-International Clubhouse training requirements and how this relates to staff position changes (turnover, transitioning positions, etc.). If there are turnovers, is the expectation that new staff get the training. This is very costly ongoing.

-Staffing concerns related to acquiring/retaining employees with the additional expectation of weekend/holiday/evening program, disruptions to routine to accommodate additional programming, and how this will impact the budget (for example compensating for holiday pay, having on-call staffing if needed, facility expenses for additional days)

-Concerns regarding when consensus-based decision may not be appropriate and may require alternative decisional making processes (such as behavioral issues, following program rules/expectations, functional/cognitive limitations); how to navigate consensus-based decision if no agreement and this results in conflict.

-Privacy concerns related to outreach and discussing other client concerns in a group setting.

-Shifting focus to employment/housing will impact those who currently access the program for additional wellness skill development. This shift in focus will change the current structure and focuses on what may be important for an individual when other skill development may be more important to the individual.

Clarification:

-More information related to separate advisory board and expectations for this.

-What qualifies as the at least 2 required activities that allows for billing (for example: access to community/employment/educational resources, educational groups on psychosocial topics-interpersonal skill development, individual interventions, mental health management, physical health/wellness education, assisting with tasks at center, art activities, volunteerism related to special events/activities)

-Information related to frequency of holiday, evening, and weekend programming. Capacity limits for special programs and how to determine who is able to attend.

-Social activities outside of work ordered day will impact those who are not able to attend on weekends/evenings/holidays and would like to participate in social aspects of the program to further develop interpersonal skills as part of the daily program structure. Are social activities not allowed to be counted outside of weekend and evening hours?

-What is the expectation as far as housing needs in comparison to what would typically be coordinated with other service providers?

-How much focus is being placed on employment/housing versus additional mental health management aspects.

-Is there specific curriculum to support with guiding RSB activities or is this developed by the program members/staff?

-What is the expectation for employment outcomes and does skill development at the program meet this criterion (such as volunteering for tasks, assisting with food preparation/clean-up, etc.).

-What is considered reimbursable as far as off-site employment skills training at community business worksites?

-Can a staff who didn’t perform a specific intervention still document in a group program where multiple staff are interacting with members throughout the day if the staff documenting is on-site.

-Crisis plans-will this need to be specific to the program, or can this be developed with the treatment team and applied at the program?