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Nina Marshall

, National Council for Behavioral Health

SAMHSA Holds Listening Session on CCBHC Certification Criteria

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Yesterday, SAMHSA held a listening session on certification criteria for Certified Community Behavioral Health Clinics (CCBHCs). Passed by Congress in March of this year, CCBHCs will provide a comprehensive range of mental health and substance use disorder services while being paid under a prospective payment system that will assure clinics have the financial resources to provide high quality care. Over 1700 people registered to attend the listening session, either in person or virtually, and nearly 150 registered to comment publicly.

As we continue to develop our own formal comments, the National Council was listening closely to what other stakeholders were prepared to offer. SAMHSA had divided up the day to cover six broad categories such as Quality and Other Reporting, Staffing, and Scope of Services. As would be expected with an open call for input, a wide range of recommendations were offered in such areas as inclusion of people with lived experience in the direct care workforce and as part of the governance structure, and measures around suicide screening and assessment. There was a strong state-based push to leave the federal guidelines broad and allow states substantial flexibility in defining the certification criteria. At the same time, there were calls for uniform application of certain evidence-based practices. I left the session pondering how to balance the need for high quality services with the practical implications of instituting a whole host of new outcome measures.

If you want to weigh in on these questions, the deadline for this opportunity is November 26. Stay tuned for next week’s Capitol Connector, in which we’ll release a template that you can adapt to submit your own comments. You’re also welcome to send your thoughts on the guiding questions directly to us at the National Council if you’d like us to take them into consideration as we finalize our comments.

However, this won’t be your last opportunity to participate. SAMHSA plans to release the criteria as draft for public comment sometime in “late Winter/early Spring,” with the final criteria slated to be released in “late Spring/early Summer,” along with the application for state planning grants. This will put the Department of Health and Human Services ahead of the statutorily required deadline of September 1, 2015.

It’s exciting to see the vision of the Excellence in Mental Health Act begin to unfold. In the (highly paraphrased) words of Paolo del Vecchio, SAMHSA’s Director of the Center for Mental Health Services, we have the opportunity through CCBHCs to raise the bar on quality, give people a better chance to get and stay well, and demonstrate that good community behavioral health is good for the nation’s health and pocketbook.