1. The Virginia Clubhouse model requires specific credentials for required service components (section 3).  Assessment may only be completed by LMPHs. Service planning and crisis supports may only be completed by LMHPs and QMHPs.  Peers are permitted to assign in the Rehabilitative Skill Building (RSP) and care coordination components of the work order day. Standard #10 of the Internal Standards for Clubhouse Programs state that all staff are generalists. How will this differentiation of staff role per Medicaid guidelines affect the program's ability to successfully become accredited in the future?

2. Can the role of peers be separated from the clubhouse model but allowed to be a service overlay in Virginia's clubhouses? That would allow programs to continue to provide more of the psychoeducational support that is missing in the new model. As an example, peers are not including the crisis support (3.4) section, but supporting members experiencing a crisis is within their scope of practice in the existing PSR model.

3. 4.1 clubhouse staff requirements—states the Program Director must have Clubhouse International Training. Which training and what is the expected timeframe for this training to be completed? Is this required prior to the opening of the Clubhouse?

4. 9. Clubhouse billing requirements: One unit of service is one day. Per diem is two required activities and one of which must be in person. What is defined as two activities?

5. 3.3 Rehabilitative Skill Building (RSB)

#7. Social skill development activities assist in communication-skill restoration and community integration. These activities occur during evening, weekend, and holiday programming organized by members and staff outside of the work-ordered day.

• What hours are permitted for "outside of the work-ordered day"? With 5 hours being the minimum operating hours for a work ordered day, does social skill programming begin after the 5 hour work ordered day or is there a specific timeframe that it can begin? Can social skill programming be part of the 5 hour minimum operating hours?
  • Do clubhouses need to be open for all holidays for accreditation?

6. 5.3 Discharge Criteria

#5 The member is no longer engaged in the service, despite multiple attempts on the part of the provider to apply reasonable engagement strategies.

• How many attempts or what length of time qualifies for discharge?