As of March 2021, 340 Certified Community Behavioral Health Clinics (CCBHCs) were in operation across 40 U.S. States, Guam, and the District of Columbia. About 93% of CCBHCs provide services outside of the physical clinic space.

The CCBHC demonstration program was a provision of the federal, bipartisan Protecting Access to Medicare Act (PAMA) of 2014. The CCBHC model launched in 2017 with 66 clinics across eight demonstration states. Two more states joined the CCBHC demonstration in March 2020. Another 32 states have clinics that were awarded CCBHC expansion grants from the federal Substance Abuse and Mental Health Services Administration (SAMHSA).

In the 10 demonstration states, the state Medicaid program pays the CCBHCs a clinic-specific daily or monthly prospective payment to reimburse for the expected cost of the demonstration services. Since 2018, Congress has appropriated parallel grant funding that SAMHSA awards directly to local provider organizations to become CCBHC grantees, many of which are county-based mental health and addiction treatment provider organizations. In the expansion states, the grantees receive traditional Medicaid fee-for-service payments for state plan services, and the grant funding covers additional costs.

All CCBHCs, demonstration or grantees, provide a comprehensive range of evidence-based behavioral health services directly or through referral to designated collaborating organizations (DCOs). All CCBHC clinics must provide access to person- and family-centered services for individuals with serious mental illness or addiction, including opioid disorders; children and adolescents with serious emotional disturbance; and individuals with co-occurring disorders. CCBHCs provide the following nine core services:

1. Crisis services
2. Screening, assessment, and diagnosis; includes risk assessment
3. Person-centered treatment planning
4. Outpatient mental health and addiction treatment services
5. Primary care screening and monitoring of key indicators/health risk
6. Targeted case management
7. Psychiatric rehabilitation services
8. Peer support and family supports
9. Community-based mental health care for active-duty military members and veterans

About 93% of CCBHCs provide services outside of physical clinic space through formalized partnerships with non-health entities within a county or region. In the past 12 months, CCBHCs offered services in the following “other” locations:

• 78% provide services in consumer homes.
• 47% provide school-based services.
• 33% provide services in courts, police offices, and other justice-related facilities.
• 20% provide services on-site at community service organizations and other non-profit organization locations.
• 11% provide services in homeless shelters.

These findings were reported in “Certified Community Behavioral Health Clinics And County Governments, March 2021: A National Model Tailored For Local Mental Health And Substance Use Care” by the National Council for Behavioral Health and the National Association of Counties. The report outlines the tenets of the CCBHC model, which aligns federal funding with a care model founded on person-centered treatment, care coordination and integration, evidence-based practice, timely access to services (including 24/7 crisis response) and the flexibility to deliver support outside the four walls of the clinic. The authors discussed how counties can leverage the CCBHC model to address key policy priorities around mental health including: expanding access to addiction treatment and strengthening the local response to the opioid crisis, serving more people, and reducing wait times for treatment.

The full text of “Certified Community Behavioral Health Clinics And County Governments, March 2021: A National Model Tailored For Local Mental Health And Substance Use Care” was published April 6, 2021, by the National Council for Behavioral Health and the National Association of Counties. A free copy is available online at https://www.naco.org/sites/default/files/documents/032421_CCBHCs_CountyGovernments_v2.pdf (accessed April 16, 2021).

OPEN MINDS last reported on this topic in “SAMHSA Accepting Applications For CCBHC Expansion Grants,” which published on March 5, 2020. The article is available at https://openminds.com/market-intelligence/news/samhsa-accepting-applications-for-ccbhc-expansion-grants/.

For more information, contact: Rebecca Farley David, Senior Advisor, Public Policy & Special Initiatives, The National Council for Behavioral Health, 1400 K Street Northwest, #400, Washington, District of Columbia 20005; 202-684-3735; Email: rebeccad@thenationalcouncil.org; Website: https://www.thenationalcouncil.org/

Of the eight states participating in a time-limited demonstration to establish certified community behavioral health clinics (CCBHC), the evaluation data is mixed. The eight states participating in the CCBHC demonstration that started in mid-2017 were Minnesota, Missouri, Nevada, New Jersey, New York, Oklahoma, Oregon, and Pennsylvania. During fiscal years 2017 through 2019, the eight states reported about $1.2 billion in Medicaid CCBHC expenditures, with federal expenditures of about $900 million, and state expenditures of about $300 million.

Officials in five of the eight demonstration states—Minnesota, Missouri, New Jersey, New York, and Oregon—reported generally increased state spending on CCBHCs, which officials from these states attributed to an increased number of individuals receiving treatment, an increased array of services provided, or both. In contrast, officials from Nevada, Oklahoma, and Pennsylvania did not report that the demonstration resulted in greater state spending.

In addition, four of the eight states —Missouri, New York, Oklahoma, and Oregon—assessed potential cost savings from the demonstration resulting from reductions in the use of more expensive care, such as emergency department visits. Officials from Missouri, New York, and Oklahoma viewed the results of their assessments as suggestive of potential cost savings, while officials from Oregon did not.

1. Minnesota’s demonstration started July 1, 2017. Six CCBHCs participated.
2. Missouri’s demonstration started July 1, 2017. Fifteen CCBHCs participated.
3. Nevada’s demonstration started July 1, 2017. Three CCBHCs participated.
4. New Jersey’s demonstration started July 1, 2017. Seven CCBHCs participated.
5. New York’s demonstration started July 1, 2017. Thirteen CCBHCs participated.
6. Oklahoma’s demonstration started April 1, 2017. Three CCBHCs participated.
7. Oregon’s demonstration started April 1, 2017. Twelve CCBHCs participated.
8. Pennsylvania demonstration started July 1, 2017. Seven CCBHCs participated.

The CCBHC demonstration was a provision (Section 223) of the Protecting Access to Medicare Act, which was signed into law on April 1, 2014. The eight states participating in the CCBHC demonstration were among 24 that were awarded a one-year planning grant in October 2015 by the federal Substance Abuse and Mental Health Services Administration (SAMHSA). In the eight states, 66 provider organizations became CCBHCs, a new Medicaid provider organization type that was eligible to receive a daily or monthly fixed rate prospective payment in exchange for providing nine core outpatient, community-based behavioral health services for adults, children, and families. The core services could be delivered by the CCBHC entity directly or through formal partnerships with other provider organizations. The nine core CCBHC services are as follows:

1. Crisis mental health services, including 24-hour mobile crisis teams, emergency crisis intervention services, and crisis stabilization
2. Screening, assessment, and diagnosis, including risk assessment
3. Patient-centered treatment planning or similar processes, including risk assessment and crisis planning
4. Outpatient mental health and substance use services
5. Outpatient clinic primary care screening and monitoring of key health indicators and health risk
6. Targeted case management
7. Psychiatric rehabilitation services
8. Peer support and counselor services and family supports
9. Intensive, community-based mental health care for members of the armed forces and veterans, particularly those members and veterans located in rural areas, provided the care is consistent with minimum clinical mental health guidelines promulgated by the Veterans Health Administration, including clinical guidelines contained in the Uniform Mental Health Services Handbook of such Administration

These findings were reported in “Medicaid Behavioral Health: CMS Guidance Needed To Better Align Demonstration Payment Rates With Costs & Prevent Duplication” by the Government Accountability Office (GAO). The GAO described what states did to measure the effects of the CCBHC demonstration on quality of care, consumer health outcomes, and state spending on behavioral health services. The GAO also examined federal guidance on Medicaid CCBHC payments.

The GAO reviewed summary information and results from state assessments that states voluntarily undertook to examine the demonstration’s effects on state spending on behavioral health services. GAO also reviewed other relevant documentation describing state-related demonstration costs, spending, and planning, including information available on state and federal websites, such as budget documentation and state plan amendments. Between November 2020 and April 2021, GAO also interviewed officials from state Medicaid agencies, behavioral health agencies, or both from the eight demonstration states, as well as officials from three selected CCBHCs.

A link to the full text of “Medicaid Behavioral Health: CMS Guidance Needed To Better Align Demonstration Payment Rates With Costs & Prevent Duplication” may be found in the OPEN MINDS Circle Library at https://openminds.com/market-intelligence/resources/092321cmsmedicaidbhrates/.

OPEN MINDS last reported on this topic in “75 Behavioral Health Provider Organizations In 8 States Prepare For CCBHC Demonstrations,” which published on February 12, 2017. The article is available at https://openminds.com/market-intelligence/news/77-behavioral-health-provider-organizations-eight-states-participating-ccbhc-demonstration/.

For more information, contact: Carolyn L. Yocom, Director, U.S. Government Accountability Office, 441 G Street, Northwest, Room 7149, Washington, District of Columbia 20548; 202-512-7114; Email: yocomc@gao.gov; Website: http://www.gao.gov/

On October 1, 2021, the Michigan Department of Health and Human Services (MDHHS) program launched a two-year Certified Community Behavioral Health Clinics (CCBHC) Demonstration Program. MDHHS selected 13 provider organizations to become CCBHCs from the 14 named in its 2016 application, which included 11 Community Mental Health Services Programs (CMHSPs) and three non-profit behavioral health entities, together serving 18 Michigan counties. The 13 selected sites are eligible for full Medicaid reimbursement and a daily payment through the Medicaid prospective payment system (PPS), similar to that paid to federally qualified health centers.

Since 2018, 34 Michigan behavioral health provider entities have directly received $135 million in two-year CCBHC Expansion Grant awards from the U.S. Substance Abuse and Mental Health Services Administration (SAMHSA). The direct-to-grantee awards are intended to help immediately provide CCBHC services while preparing an entity for the state-based CCBHC program. Of the 34 sites funded by the SAMHSA grants, 10 sites are participating in the state’s CMS CCBHC demonstration. Until the CCBHC demonstration program started, the sites received Medicaid reimbursement for covered services and used federal grant or other funding to pay for non-Medicaid services.

The 13 organizations participating in the CCBHC demonstration receive a daily per-beneficiary/recipient, clinic-specific PPS rate based on the average expected daily cost to deliver core CCBHC services. The non-demonstration sites will continue with their previous reimbursement method. MDHHS anticipates roughly 100,000 Michigan residents will be served by the 13 sites (over 80% of which are estimated to be Medicaid beneficiaries). The 13 sites, and their PPS rates for the first demonstration year, are as follows:

1. Community Mental Health and Substance Abuse Services of St. Joseph County: $292.62
2. Community Mental Health Authority of Clinton, Eaton, and Ingham Counties: $373.07
3. Community Network Services (Oakland County): $342.23
4. Easter Seals (Oakland County): $327.63
5. HealthWest (Muskegon County): $383.02
6. Integrated Services of Kalamazoo (Kalamazoo County): $445.73
7. Macomb County Community Mental Health: $338.01
8. Saginaw County Community Mental Health Authority: $432.16
9. Clair County Community Mental Health Authority: $332.37
10. The Guidance Center (Wayne County): $478.53
11. The Right Door (Ionia County): $384.14
12. Washtenaw County Community Mental Health: $281.33
13. West Michigan Community Mental Health (Lake, Mason, and Oceana Counties): $357.85

The 13 CCBHCs serve Medicaid beneficiaries and consumers with other types of health insurance. The state’s Medicaid managed care plans for physical health are not required to contract with the CCBHCs. The state’s 10 regional prepaid inpatient health plans (PIHPs) that manage the public behavioral health system for Medicaid and publicly funded behavioral health specialty services and supports are required to contract with the CCBHCs. The PIHPs administer supports and services for persons with serious mental illness, serious emotional disturbance, intellectual/developmental disabilities, and drug addiction. The PIHPs also directly manage SAMHSA Substance Abuse Block Grant funding and local substance addiction. For the CCBHC demonstration, MDHHS provides a capitated payment to the applicable PIHPs for CCBHC services and the PIHPs pay the PPS to the CCBHC demonstration sites for qualifying services.

The pilot project was authorized by the U.S. Centers for Medicare & Medicaid Services (CMS) under Section 223 of the Protecting Access to Medicare Act of 2014. MDHHS originally applied to CMS in 2016 to become a CCBHC Demonstration state. That request was approved on August 5, 2020 by virtue of the Federal Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of 2020, adding Michigan and Kentucky to the CMS demonstration.

To see the latest on Michigan’s CCBHC demonstration, including information for both those servied, and for provider organizations, go to http://www.michigan.gov/CCBHC

A link to the full text of “MI CCBHC Demonstration — Final DY1 PPS-1 Rates by CCBHC Site” may be found in the OPEN MINDS Circle Library at https://openminds.com/market-intelligence/resources/100121miccbhcdemoppsrates/.

OPEN MINDS last reported on this topic in “Michigan & Kentucky Now Participating In CCBHC Demonstration,” which published on September 16, 2020. The article is available at https://openminds.com/market-intelligence/bulletins/michigan-kentucky-now-participating-in-ccbhc-demonstration/.

For more information, contact: Jon G. Villasurda Jr., MPH, State Assistant Administrator, Behavioral Health and Developmental Disabilities Administration, Michigan Department of Health and Human Services, 320 South Walnut Street, Elliot-Larsen Building, 5th Floor, Lansing, Michigan 48933; 517-230-9707; Email: villasurdaj@michigan.gov;  Website: http://www.michigan.gov/CCBHC

Editor’s note: the informational link for CCBHC updates was added on 11/15 per Mr. Villasurda.