We agree with the many other commenters who have pointed out that some of the requirements in these regulations are contradictory to the Clubhouse International model.  These include the de facto time limit on membership created by the 240 unit/year maximum, the limits on some employment and educational supports, and the language regarding “observation without intervention.” Additionally, the language around allowable and nonallowable employment supports is confusing and requires clarification for what supports are allowed at the program and in the community. The discrepancies between the CI model and this set of regulations is only an issue because of the requirement to obtain accreditation and therefore design a program that is compatible with that model.

Overall, we find the proposed staffing requirements and the burden of accreditation to be disproportionate with the proposed reimbursement rate and annual maximum allowable units. As many have said, adding new service requirements with a lower reimbursement ceiling than is currently available  with PSR makes this program an unattractive alternative to the current PSR model.  Particularly since the proposed model excludes participation in, what we view, as complementary and non-duplicative services like ACT and ASAM 2.1. Ultimately, we recommend that DMAS wait to redesign this program until such a time that they can adequately fund the model they are proposing.