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Nina Marshall

, National Council for Behavioral Health

SAMHSA Releases Draft Excellence Act Certification Criteria: Responses Due Monday

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Last week, the Substance Abuse and Mental Health Services Administration (SAMHSA) released draft certification criteria for Certified Community Behavioral Health Clinics (CCBHCs), the comprehensive mental health and substance use disorder providers authorized by legislation based on the Excellence in Mental Health Act. The open comment period for the 71 pages of criteria is two weeks, and comments are due this coming Monday, February 16.

The National Council has a long list of concerns with the criteria as currently drafted. We are still developing our formal comments (which we will make publically available for others to review and adapt for their own submission), but chief among our concerns are:

  • The criteria are overly prescriptive, creating a disincentive for state participation. While the National Council has long championed 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. SAMHSA has the statutory authority to be more flexible in its criteria, while still meeting the goal of raising the standard of care.
  • 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 which are not commonly covered in Medicaid programs (e.g., outreach and engagement).
  • 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 over 60 optional measures, many of which would require individual chart reviews and pulling of information from personnel records.

Stay tuned to Capitol Connector for our more detailed comments, including a template for you to adapt and submit on your own behalf. The public comment period ends this coming Monday, and we strongly encourage you to weigh in on this important opportunity for building a stronger behavioral health system.