General:

Please include “CARF-Accredited Community Integration Services” in addition to Clubhouse Services throughout the draft and not only within the current accreditation section. Throughout the draft, “clubhouse services” and “Clubhouse International” accreditation is referenced as the primary standard. Adding CARF terminology throughout the draft could provide clarity and consistency while maintaining a high standard of service (currently this is only listed in the accreditation section). Regularly mentioning “clubhouse services” may be confusing to those who are providing CARF-accredited services.

Please allow room in the draft for programs that wish to continue providing CARF-accredited services AND IPS simultaneously as opposed to some potential conflicts of the transitional employment standards consistent with the Clubhouse International model.

Also, requesting that a “licensed clinical supervisor” be considered when referencing “Clinical Director” or “Program Director.”

Section-specific comments:

1. Definitions

“Member” - Please consider having definitions include CARF accreditation terms and not only referencing “Clubhouse” services/accreditation.

2. Service Definition/Critical Features

Paragraph 2 regarding physical space:

Please consider allowing additional collaborative services to be permitted within the same building. Please expand to permit private spaces to adhere to HIPAA compliant activities with members and families when a provider does not have any “staff only spaces” but has designated offices where confidential interventions can occur.

3. Required Service Components

3.2.4 Please consider allowance of a licensed supervisor to be authorized to oversee the ISP process.

3.3.7. HAMHDS currently facilitates periodic outings containing small groups from the overall census under the CARF accredited Community Integration services. Please consider allowing for the current processes to suffice for the coverage mentioned in the draft.

 4. Provider Qualification Requirements

 4.1.2. What staff training alternatives are available for CARF accredited Community Integration Services?

 4.1.4. Is this referring to staff’s caseload or the ratio of members to available staff on any given day? Additionally, does this include the Clinical/Program Director in that ratio?

 4.2.1. Is CARF accreditation acceptable for this new license requirement?

 4.3. What requirements for Clubhouse Services must CARF accredited programs follow, in addition to the CARF’s Community Integration standards?

Due to the significant benefits of services as they’re currently being provided, HAMHDS is advocating for any program to have the option to gain CARF accreditation as an alternative after the 1/1/26 date, within the 4-year period.

 4.4.2  Does the CSB Board of Directors, which serves as the advisory board, suffice for the requirement mentioned in the draft?

 6. Exclusions and Service Limitations

6.0.1 Please allow the CARF manual to also be the standard for compliance for Medicaid billing.

6.10.a.ii, iii,iv,v,x Individuals receiving the mentioned services need support and assistance during the day and benefit from CARF accredited Community Integration Services (Clubhouse services as mentioned in the document). Please allow the following services to be authorized simultaneously with CARF accredited Community Integration Services: Addiction and Recovery and Treatment Services (ARTS) Levels: ASAM 2.1-3.7, Assertive Community Treatment, Coordinated Specialty Care, Community Stabilization, and Therapeutic Group Home (TGH) services. Please include Community Integration for the excluded populations to assist with recovery. It is reasonable to assume that excluding such populations would lead to a significant increase in hospitalizations, incarcerations, and housing instability.

 8. Additional Documentation Requirements and Utilization Review

8.4 Reviewing all staff notes every 30 days with a co-signature is burdensome as staff are adequately trained to write progress notes and these included in chart reviews. Requesting the level of oversight from licensed staff to be sufficient.

Thank you for the opportunity to provide comments on this draft service description. HAMHDS is always willing to provide additional information on how services are currently being provided to better communicate the effectiveness and high standards of CARF accredited services.