Certified Community Behavioral Health Clinic

Background

The Protecting Access to Medicare Act of 2014 was enacted in 2014. Section 223 of the Act provides for the creation and evaluation of a demonstration program to improve community mental health services. Section 223 authorized the U.S. Department of Health and Human Services to establish the federal CCBHC criteria for the demonstration program and for clinics to be certified by a state as a Certified Community Behavioral Health Clinic.

CCBHC Criteria and Services:

CCBHC’s are currently not yet defined or certified by the State of Indiana. However, SAMHSA’s criteria does describe the basic level of criteria and services that a CCBHC should operate. The CCBHC criteria falls into six key program areas:

1. Staffing – Staffing plans are developed and driven by first performing a local needs assessment to determine needs of the community served by the CCBHC. Each CCBHC develops a staffing plan from such needs assessments that inform the required the staffing levels, licensing, and training to support service delivery.
2. Availability and Accessibility of Services – CCBHCs have described standards for timely and meaningful access to services, outreach and engagement, 24/7 access to crisis services, treatment planning, and acceptance of all patients regardless of ability to pay or place of residence.
3. Care Coordination – CCBHCs are required to develop care coordination agreements across services and providers (e.g., Federally Qualified Health Centers, inpatient and acute care), defining accountable treatment team, health information technology, and care transition guidelines and practices.
4. Scope of Services – CCBHCs are required to provide nine required services. CCBHC services are to be provided in a manner that is person-centered, family-centered, and recovery-oriented care. The nine required services are to be provided directly by the CCBHC but may also be provided through a formal relationship by establishing partnering agencies as Designated Collaborating Organization.
   
   Required CCBHC Services:
   • Crisis Services
   • Treatment Planning
   • Screening, Assessment, Diagnosis & Risk Assessment
   • Outpatient Mental Health & Substance Use Services
   • Targeted Case Management
   • Outpatient Primary Care Screening and Monitoring
   • Community-Based Mental Health Care for Veterans
   • Peer, Family Support & Counselor Services
   • Psychiatric Rehabilitation Service
5. Quality and Other Reporting – CCBHCs have site specific required quality measures that must be collected and reported. CCBHCs must also develop a plan for quality improvement and tracking of other program requirements. In addition to site specific required quality measures, states that certify CCBHCs have state specific quality measures that must be collected and reported in addition to the site-specific measures.
6. Organizational Authority and Governance – CCBHCs are required to incorporate consumer representation in the governance of the CCBHC. CCBHCs certified by their state are required to have undergone the appropriate state accreditation process of CCBHCs.

Federal Program Distinctions:

There are two different federal programs that support CCBHCs, the CMS CCBHC Demonstration and the Substance Abuse and Mental Health Administration CCBHC Expansion Grant (discretionary grant awards).

• CMS CCBHC Demonstration – CCBHCs are funded by using a Prospective Payment System rate for qualifying services provided to Medicaid beneficiaries. States are responsible for oversight of the demonstration program which includes clinic certification, payment to the CCBHCs and development of PPS rates, and compliance with federal reporting requirements. Indiana has not yet joined the CMS CCBHC Demonstration. The CMS CCBHC Demonstration also provides a four year enhanced federal match for developed PPS rates approved in the demonstration.
• SAMHSA CCBHC Expansion Grants – CCBHC Expansion Awardees are funded for generally a grant period of two years, and funded directly by SAMHSA to their local clinic through self-attestation that the awarded clinic meets the baseline CCBHC criteria. States do not have any direct role in these grants. There have been 18 CMHC sites that have been awarded the CCBHC Expansion Grant.

How are CCBHC’s Funded?

CCBHC’s that are a part of the CMS CCBHC Demonstration are funded and supported by a prospective payment system or PPS, which provides a sustainable and flexible funding model to support the CCBHC.

The PPS model supports the cost of expanding services and increasing the number of clients they serve by addressing the costs of providing these services. PPS rates are developed and governed at the state level, through a cost reporting process. The cost report process begins by reviewing the staffing plans and community needs assessments of CCBHCs and is developed to incorporate the total annual allowable CCBHC cost.

CCBHC PPS rates are a Medicaid per-encounter rate that is set based on a cost report that documents a clinic’s allowable costs and qualifying patient encounters (either on a monthly or daily basis) over a year. The costs are divided by the number of qualifying encounters to arrive at a single rate which is paid to the clinic each time a monthly or daily encounter occurs, regardless of the number or intensity of services provided to a patient.

Resources:

National Council for Mental Wellbeing’s CCBHC Success Center: The CCBHC Success Center is the National Council’s hub for data, implementation support, and advocacy to support the Certified Community Behavioral Health Clinic initiative across the United States. On top of support and advocacy, the CCBHC Success Center also releases CCBHC Impact Reports on the progress made by CCBHCs, which may be viewed by clicking here.

DMHA’s Indiana CCBHC Report: As mandated by House Enrolled Act 1222, Section 14. IC 12-21-5-8 was added to the Indiana Code and mandated that DMHA establish a plan to expand the use of CCBHCs and submit it to the Indiana general assembly by November of 2022. The following link contains the Indiana CCBHC Report.