The proposed accreditation requirements present challenges due to both the timeline and the associated expense. Is Clubhouse International accreditation now mandatory? We previously received information from DMAS indicating that CSBs could choose between CARF and Clubhouse International accreditation.

Would this board be in addition to the CSB’s current board members? It is already difficult to recruit and maintain participation from existing NCSB board members. Developing a separate board, or requiring current members to attend additional meetings for the Clubhouse, would be burdensome and potentially problematic.

The requirement for an LMHP to review all documentation from non-licensed staff every 30 days is concerning. Staffing our current PSR programs is already difficult, and adding this responsibility would increase the demand for licensed staff. This could create additional burdens and detract from other critical job duties.

The restriction on “staff-only” spaces raises concerns. Staff need a secure, HIPAA-compliant area to write notes and complete required documentation. Eliminating these spaces could compromise confidentiality and compliance.

Excluding individuals who receive ACT services seems unnecessarily restrictive. Consumers could benefit from both services, as they address different needs. This exclusion would limit eligibility and force out consumers who are already participating in both. Overall, the proposed regulations narrow access by restricting who can attend. This contradicts current Clubhouse International standards and introduces time limits that undermine the model’s philosophy of voluntary, ongoing participation.

The rule that “observation without intervention is not billable” could negatively impact members who attend but choose not to interact on a given day. Many rely on the program as a safe space, and this restriction could limit their ability to participate.

The proposed staff-to-member ratio of 1:15 appears too low. It does not account for staff absences due to illness, leave, or breaks, nor does it allow for coverage when staff must step away. This ratio would also make it difficult to complete billable interventions and documentation for 15 members effectively.