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Nina Marshall

, National Council for Behavioral Health

SAMHSA Updates Criteria for CCBHC Certification

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Last week, the Substance Abuse and Mental health Services Administration (SAMHSA) gave behavioral health stakeholders a preview to its changes for the certification criteria for Certified Community Behavioral Health Centers (CCBHCs). The National Council is very encouraged by the changes that we heard discussed during last week’s listening session, and think they go a long way towards making this a meaningful and viable program. Some of the more significant changes we heard discussed include:

  • The new criteria allows for creation of “Designated Collaborating Organizations” which will be able to provide services on behalf of CCBHCs so long as they adhere to the same standards that CCBHCs are held to.
  • The new criteria offers more context regarding Medicaid payment, by caveating that services are required “to the extent possible within the Medicaid program.” The revised criteria also says that “there is no requirement for the state to amend its Medicaid state plan for any CCBHC service provided through this demonstration by a certified clinic. This applies to services currently authorized in the Medicaid state plan and to additional services made available through this demonstration.” Based on these two statements regarding payment, the National Council has asked for clarification that CCBHCs can provide “additional services” authorized by this demonstration and get paid for it, even if not in the Medicaid state plan. We also asked to that the PPS guidance make clear that all of the required services will be covered even if not delivered within the four walls of a clinic, and it can be used to support HIT infrastructure development.
  • There are far more reasonable timeframes for development of treatment plans, and the evaluation requirements are more aligned with a patient population that has wide-ranging behavioral health needs.
  • Board governance requirements have been changed so that 51% consumer and family representation is a goal for the end of the two-year demonstration period.

We understand that SAMHSA and CMS intend to release the final certification criteria, State Planning Grant applications, and payment guidance in May. More changes may be made between what we heard discussed last week and when the final criteria are released, but the National Council is hopeful that the different parts will align to maximize the ability of individual states to participate in this valuable demonstration program that will accelerate the development of high-quality, high-value health care services for behavioral health consumers across the country.