After reviewing the draft regulations and the Clubhouse International guidelines, the following concerns are noted.
Definitions: Serious Mental Illness (Adults) – Clubhouse International standards define membership as “open to anyone with a history of mental illness, unless that person poses a significant and current threat to the general safety of the Clubhouse community.” This is not specific to an SMI diagnosis.
Service Definition/Critical Features: Members with serious mental illness is mentioned again but this is not a CI standard. *The clinical approach, i.e. assessment, discharge, etc., contradicts a lot of the Clubhouse standards throughout this document.
Required Service Components: Rehabilitative Skill Building (RSB)- include on-site and off-site support at a community business worksite, and then later in the document it says that “staff presence in the workplace to assist with supervision or teaching of routine work duties is not reimbursed” (can be found in section 6, number 9 on list of non-reimbursable activities.) This seems contradictory.
Provider Qualification Requirements: 4.4 Clubhouse Operation Requirements- CI indicates “work-ordered day” should be the same hours as the typical staff schedule (i.e. 9-5 or 8-4).
Exclusions and Service Limitations: 10. Members receiving Clubhouse may not be authorized to receive the following services: Assertive Community Treatment – this will be problematic as ACT services do not address the same needs.
Clubhouse Billing Requirements and Information: To bill the per diem unit, members must receive a minimum of two required activities on the day of services. Did I miss where the required activities were listed? I see it mentioned several times but not specific.
Other noted concerns and questions to be answered: “Any observation without an intervention is not a billable activity.” Does this mean that we cannot bill for someone who comes to the program and doesn’t interact?
The very first clubhouse standard is that membership is without time limits, and yet it appears that the MCOs want to limit the time a person is enrolled.
Standard 25 supports in house education opportunities, and yet that is on the list of non- billable activities.
Will NGRI individuals coming on passes from state hospital be affected?