National Council Sends Finalized CCBHC Comments to SAMHSA
The National Council submitted finalized comments earlier this week to the Substance Abuse and Mental Health Services Administration (SAMHSA) on draft certification criteria for Certified Community Behavioral Health Clinics (CCBHCs). SAMHSA extended the deadline for comments on the draft criteria for CCBHCs, the comprehensive mental health and substance use treatment providers authorized by legislation based on the Excellence in Mental Health Act. Thank you to all advocates who submitted comments before Wednesday’s deadline.
The National Council articulated a long list of concerns with the draft criteria, most notably:
- The criteria are overly prescriptive, creating a disincentive for state participation. While the National Council has long championed the creation of national standards for community behavioral health services, that must be balanced with the reality that CCBHCs are currently authorized only as a two year demonstration program.
- The service requirements are laid out in absence of a discussion of the Prospective Payment System, or cognizant of limitations in State Medicaid Plans. Payment by Medicaid for CCBHC services is limited to what is already allowable in a state’s Medicaid program. Despite this limitation, the criteria include many services and activities that are not commonly covered in Medicaid programs (e.g., outreach and engagement).
- The criteria hews too closely to services required for partial hospitalization services, and does not leave room for a level of care for people with mild-to-moderate behavioral health conditions.
- Directly approving accreditation by a national body or allowing states to deem would address many of the quality issues raised by SAMHSA through its draft criteria. Many of the statutory requirements for CCBHCs are already addressed through accreditation systems.
- The quality measures included are too extensive, often lack specificity, and are exceptionally labor intensive. The criteria include a list of 30 required measures and more than 60 optional measures, many which would require individual chart reviews and pulling of information from personnel records.
Many other leaders in the field echoed similar concerns and we are hopeful SAMHSA will revamp the criteria to allow for greater state participation. SAMHSA has expressed the goal of releasing finalized certification criteria in May, along with guidelines to states for developing the payment methodology and the RFA for state planning grants. $25 million will be made available to states to engage in planning to determine whether and how CCBHCs fit into their larger system reform. Stay tuned to Capitol Connector for more news and information regarding the implementation of the Excellence in Mental Health Act.
Again, thank you to all of the advocates who took the time to send comments to SAMHSA. Please read our full finalized comments here.