Staff Requirements:

1. A full-time Program Director with Clubhouse International training as described in section 3.3 who holds a current, active, and unrestricted Virginia registration or license from the Department of Health Professions that qualifies them as a QMHP, LMHP, LMHP-R, LMHP-RP, or LMHP-S.
2. A Licensed Mental Health Professional (LMHP) who holds a current, active, and unrestricted Virginia license from the Department of Health Professions that qualifies them as a LMHP, with Clubhouse International training as described in Section 3.3. The LMHP does not need to be a full-time employee and shall be available on call or as needed. The LMHP shall have the ability to provide in-person services and support to members and staff.

There is no clarfication on if these can be the same people, or if they have to be different people. This will be challengeing with the shortage of licensed providers. 

Staff Training Requirements

1. All staff are required to receive training as required by Clubhouse International.
2. All newly DMAS enrolled Clubhouses shall send a team (including at least one member) to an authorized Clubhouse International training base within the first 12–18 months of operation, and staff are expected to participate in training or specialized tracks as a condition of maintaining accreditation in good standing.

Will there be supplemental funding provided to support these? They are all out of state and require significant time away from regular work and family duties. How long do we have before every staff must be trained? Does everyone need to be trained or just the program director? Is there an expectation of continued training every so many years or can one staff go and be done forever?

Crisis Planning: “When a member is not present at the Clubhouse, crisis support shall be guided by the member's individualized crisis plan. The plan shall be designed to be utilized in the member's community setting and shall specify actions the member, natural supports, and Clubhouse staff can take when the member is not on-site, including contact protocols, de-escalation strategies, and referral pathways to appropriate crisis services including but not limited to 911, 988, Emergency Room, CSB Emergency Services, 23-Hour Crisis Stabilization, and Residential Crisis Stabilization Unit”

Why are we responsible for things that happen outside of our program?

Will there be training on crisis planning provided? Is this training being left up to the CSB's or will there be state training?

“When a member is present at the Clubhouse during program hours and a crisis occurs, the Clubhouse shall provide immediate, on-site crisis support. At least one staff qualified to provide crisis support shall be available in-person during all program hours to respond to member crises without delay.”

What constitutes a qualified staff person in this scenario? The LMHP? What if they are out of the office? Do QMHPs count?

"Providers shall submit service authorization requests within one business day of admission for preservice service authorization requests and by the requested start date for concurrent stay requests. If submitted after the required time frame, the start date of authorization will be based on the date of receipt."

This is an incredibly short turn around, and what happens if the authorization is rejected? Do we then have to discharge the individual right after enrollment?

The individual's MCO/FFS service authorization contractor conducting the service authorization review may approve the requested service(s) or may recommend a more clinically appropriate service based on their review.

 This still gives too much power to the MCOs, and makes more work for the provider. Person centered programs are about what the client wants, not what the insurance says they need. 

All service authorizations shall be issued for a six (6) month period. Each authorization shall include 120 units of H2031.

Currently we usually request 360-468 units for someone who attends every day for 8 hours a day. This is a dramatic reduction in what we currently bill. We would loose money this way. 

Paperwork: Daily, Weekly, Monthly: The level of detail this is laying out is nearly imposible for us who have 30-35 members every day. Too much staff time will be taken up by this. And its very redundant. 

Sec 8.1 LMHP Review: What is the reasoning for making LMHP's have to sign off on all QMHP documentation? This takes away power from the QMHPs and adds additional administrative burden on the LMHPs. 

Current rate is $89. Per diem rate is $74. Our program, and I believe many others would loose significant revenue this way. Especially if we can only bill for specific activities and not for members in the building who are less active participants but just  need a quiet space to sit and think/reflect.