Excluding Members Who Receive ACT Services: Restricting Clubhouse access for ACT recipients is concerning. ACT is clinical and therapeutic, while Clubhouse services are non-clinical and rehabilitative. They serve different purposes and often complement each other. Exclusion removes essential support for members who benefit from both.
No "Staff Only" spaces: Staff only spaces are needed for privacy, security, and risk management purposes.
LMHPs to review documentation: It is an administrative burden to require LMHPs to review documentation of non-licensed staff every 30 days. This will be a burden for those programs who have difficulty staffing LMHPs.
Accreditation: It is an administrative and monetary burden to require accreditation from either Clubhouse International or CARF.
Contraindication with the Clubhouse Standard of Membership Without Time Limits: The foundational Clubhouse standard states that membership is voluntary and without time limits; however, DMAS/MCO requirements appear to impose time-limited enrollment and reauthorization expectations. This conflicts with the core principles of continuity, belonging, and long-term community support.
24/7 crisis coverage that does not extend to CSB emergency services programs: The idea that Clubhouse staff will have to provide crisis responses to members as opposed to deferring to the internal emergency services staff of a CSB is an added staffing burden. CSBs should be able to use internal supports, like our emergency services staff, in these situations.
Overlap and Confusion with Case Management Services: Several required service components appear to duplicate activities already covered under Case Management, creating ambiguity about what is distinct or reimbursable within the Clubhouse model.
Advisory Board requirement is duplicative for CSBs: CSBs already report to a Board of Directors who oversee financial, legal, and operational matters. Requiring a separate advisory board for the Clubhouse program would duplicate efforts and potentially create conflicting guidance. Flexibility should be granted to allow existing governance structures (i.e., CSB Board of Directors) to fulfill this role.
