CCBHCs, Designated Collaborating Organizations, and Care Coordination Partners
One of the key steps for CCBHC readiness requires forging new relationships, or strengthening and formalizing existing ones, with other providers and social service agencies in the community. The two types of community partnerships envisioned in the CCBHC demonstration are Designated Collaborating Organization (DCO) relationships and care coordination relationships.
Designated Collaborating Organizations (DCOs)
Recognizing that not all community behavioral health organizations may be equipped to provide all nine CCBHC services directly, the statute permits CCBHCs to contract with external providers for the provision of some services. Subsequent guidance from SAMHSA designated these entities as DCOs and established guidelines for the CCBHC-DCO relationship. Importantly, the CCBHC is clinically and financially responsible for the provision of services through a DCO. This means the CCBHC is the billing provider for the service and must ensure the DCO meets all relevant requirements in the statute and guidance. Relationships with DCOs are optional; if a CCBHC directly provides all nine required services, it is not required to establish a relationship with a DCO.
Care Coordination Partnerships
The statute also specified a variety of health and social service entities with which the CCBHC should establish care coordination partnerships. These partnerships are different from the CCBHC-DCO relationship in that they are referral relationships with each entity maintaining full clinical and financial responsibility for its own services. The CCBHC does not bill for services provided by its care coordination partners; however, it may include the costs of its own care coordination activities in its cost report for the purpose of establishing its payment rate. Relationships with care coordination partners are mandatory: CCBHCs are required to form these relationships with a number of specified entities (with the option for more required partners at state discretion).
What’s the difference between a care coordination partnership and a DCO relationship? Read our fact sheet here.
CCBHC Contracting and Community Partnerships Toolkit
The National Council partnered with Feldesman Tucker Leifer Fidell to create a comprehensive CCBHC Contracting and Community Partnerships Toolkit. This Toolkit includes:
- Sample Purchase of Services Agreement with DCO;
- DCO Agreement overview of legal requirements and checklist of recommended terms;
- Sample Care Coordination Agreement;
- Care Coordination Agreement overview of legal requirements and checklist of recommended terms;
- Description of required components of the CCBHC’s sliding fee discount policy, used to make services affordable for consumers
- Summary distinguishing DCO relationships from care coordination relationships;
- CCBHC fact sheet addressed to potential DCO partners;
- List of top 5 DCO and care coordination questions and answers;
- Negotiations tip sheet; and
- Discussion of how to quantify and document fair market value for DCO contracting.
Click here for a single pdf document including all sections of the toolkit.
In general, of the nine required CCBHC services, the CCBHC is required to furnish four directly: crisis behavioral health services, comprehensive behavioral health screening, assessment, and diagnosis, including risk assessments; person-centered and family-centered treatment planning; and comprehensive outpatient mental health and substance use disorder services. However, the CCBHC may contract with a DCO to provide crisis behavioral health services under certain conditions set forth in the SAMHSA guidance:
- Crisis behavioral health services may be provided via a “state-sanctioned alternative” acting as a DCO
- Ambulatory and medical detoxification in ASAM categories 3.2-WM and 3.7-WM may be provided via DCO
CCBHCs may furnish via DCO the remaining five required CCBHC services: outpatient clinic primary care screening and monitoring of key health indicators and health risk; targeted case management; psychiatric rehabilitation services; peer support and counselor services and family supports; and intensive community-based mental health care for members of the armed forces and veterans.
The CCBHC maintains clinical and financial responsibility for services rendered to CCBHC consumers via DCO.
Yes. A for-profit organization may function as a DCO. A CCBHC, on the other hand, is required to be a nonprofit or governmental entity.
Yes. In its Frequently Asked Questions, #18, SAMHSA states that this is permissible “as long as the clinic meets the CCBHC criteria and the relationship between the clinic and the other component of the non-profit meets the DCO requirements in the criteria. For example, if a large non-profit organization has only one clinic that is a CCBHC but the non-profit also operates a state-sanctioned, certified or licensed crisis behavioral health crisis system, the crisis system may be a DCO for the CCBHC as long as the requirements of that relationship are satisfied.”
The CCBHC is responsible for ensuring that DCO-related costs are included in the CCBHC’s Medicaid base period cost report. That cost report, in turn, is used to determine the CCBHC’s prospective payment system (PPS) payment rate. The CCBHC will pay the DCO a contracted per-visit rate for services provided. The rate should represent fair market value for the services purchased.
Because the CCBHC is financially responsible for DCO-provided services, it is the CCBHC, rather than the DCO, that bills Medicaid for CCBHC services furnished via DCO.
In order for a CCBHC to bill Medicaid for a CCBHC encounter rendered to a consumer, the encounter must be documented in the consumer’s CCBHC health record. Therefore, where a CCBHC service is furnished via DCO, the DCO will be required either to participate in a health information exchange through which health record entries can be shared, or to transmit the encounter data to the CCBHC.
CCBHCs will also be responsible for billing Medicaid managed care entities and payors other than Medicaid for CCBHC services. The encounter data reporting requirements that the CCBHC imposes on the DCO may vary according to payor.
Similarly, in order to fulfill the clinical and quality reporting requirements of SAMHSA’s Uniform Reporting System concerning all CCBHC services, including those furnished via DCO, a CCBHC will need access to wide-ranging data from the DCO. A CCBHC’s written agreement with the DCO should require the DCO maintain and timely submit to the CCBHC all required data, such as information on quality reporting and encounter data.
CCBHCs must maintain care coordination relationships with the following providers and social service entities:
- Federally qualified health centers (and as applicable, rural health clinics);
- Inpatient psychiatric facilities and substance use detoxification, post-detoxification step-down services, and residential programs;
- Other community or regional services, supports, and providers, including schools, child welfare agencies, and juvenile and criminal justice agencies and facilities, Indian Health Service youth regional treatment centers, State licensed and nationally accredited child placing agencies for therapeutic foster care service, and other social and human services;
- Department of Veterans Affairs medical centers, independent outpatient clinics, drop-in centers, and other facilities of the Department as defined in section 1801 of title 38, United States Code; and
- Inpatient acute care hospitals and hospital outpatient clinics.
Additionally, states may opt to require care coordination partnerships with additional entities based on the community needs assessment. These could include entities such as:
- Specialty providers of medications for treatment of opioid and alcohol dependence;
- Suicide/crisis hotlines and warmlines;
- Indian Health Service or other tribal programs;
- Homeless shelters;
- Housing agencies;
- Employment services systems;
- Services for older adults, such as Aging and Disability Resource Centers; and
- Other social and human services (e.g., domestic violence centers, pastoral services, grief counseling, Affordable Care Act navigators, food and transportation programs).
If an agreement cannot be established with any of the provider/social service organizations set forth in the statute or the SAMHSA guidance—or if the partnership cannot be established within the time frame of the demonstration project—justification must be provided to the state CCBHC certifying body, and contingency plans must be established. The state will make a determination whether the contingency plans are sufficient or require further efforts.
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