CLIENT ALERT: New Opportunities in the Certified Community Behavioral Health Clinic (CCBHC) Program Unveiled in March 2023

By , , | Published On: April 3, 2023

The month of March brought several significant new developments for the certified community behavioral health clinic (CCBHC) program.

CCBHCs are outpatient safety-net behavioral health providers that, among a variety of program requirements, furnish a wide array of covered services and have an obligation to serve all consumers regardless of ability to pay. The CCBHC model was originally included in 2014 legislation, the Protecting Access to Medicare Act (PAMA), which authorized the Department of Health and Human Services (HHS) to select eight states to operate a two-year CCBHC Medicaid demonstration program. Since then, through enactments of Congress, the CCBHC demonstration program has been expanded in scope and extended in duration several times. Additionally, separate from the CCBHC Medicaid demonstration, Congress authorized the Substance Use and Mental Health Services Administration (SAMHSA) to award grants (“CCBHC expansion grants”) to individual clinics building a CCBHC scope of service.

Recent noteworthy CCBHC policy changes include the following.

Planning Grants Awarded to 15 States to Compete for 2024 CCBHC Demonstration

The Medicaid CCBHC demonstration currently includes only eight States. As described in our July 5, 2022 blog post, the Bipartisan Safer Communities Act of 2022 required HHS to award planning grants to additional States to develop proposals so that HHS could select up to ten (10) additional states to operate a CCBHC demonstration, effective July 1, 2024. The law required HHS to repeat this process—selecting new cohorts of up to 10 CCBHC demonstration States—every two years until 2030.

On March 16, 2023, SAMHSA awarded planning grants to an additional 15 States to develop a CCBHC program. The States—Alabama, Delaware, Georgia, Iowa, Kansas, Maine, Mississippi, Montana, North Carolina, New Hampshire, New Mexico, Ohio, Rhode Island, Vermont, and West Virginia—will be eligible to apply for HHS selection to participate in the CCBHC Medicaid demonstration, effective July 1, 2024.

New CCBHC Expansion Grant Opportunities

On March 23, 2023, SAMHSA announced two new Notices of Funding Opportunity for CCBHC expansion grants, as follows.

  1. For organizations that do not already participate in a state’s Section 223 Demonstration Program, and have not otherwise been certified as a CCBHC or attested to meeting the Certification Criteria under a prior CCBHC Expansion Grant, the FY 2023 CCBHC Planning, Development, and Implementation Grants (CCBHC-PDI) grant program provides an opportunity for awardees to plan for, develop and implement a CCBHC model.
  2. For organizations that have already been certified by their states as CCBHCs or that participated in a previous CCBHC Expansion award, the FY 2023 CCBHC Improvement and Advancement Grant (CCBHC-IA) grant program provides an opportunity to enhance and improve their CCBHCs that meet the CCBHC Criteria.

For each opportunity, SAMHSA may provide up to 62 awards with up to $1 million per award. Applications are due by May 22, 2023.

SAMHSA Updates to CCBHC Certification Criteria

The PAMA 2014 legislation required the Secretary of HHS to issue “criteria” for a clinic to be certified as a CCBHC.

SAMHSA initially issued CCBHC criteria in 2015. In March 2023, SAMHSA issued updated Criteria, with the stated purpose of aligning the requirements with the current health care landscape. For example, the revised Criteria address emerging best practices and acknowledge behavioral health workforce shortages. The revisions also take into account policy changes since 2015 relating to crisis care, telehealth and the response to the opioid epidemic, as described in SAMHSA’s summary of changes resource.

Key changes to the Criteria for safety net providers to note include the following:

  • The revised CCBHC Criteria modify the guidelines for designated collaborating organizations (“DCOs”)—entities that furnish a CCBHC service on behalf of a CCBHC. Whereas under the prior standards, only certain CCBHC services could be furnished via DCO, the revised standards provide that any CCBHC service may be furnished by a DCO, so long as the CCBHC directly furnishes more than half of CCBHC services.
  • The revised CCBHC Criteria strengthen the technology and patient privacy guidelines for CCBHC care coordination arrangements, and also clarify that where CCBHCs encounter challenges in entering formal care coordination agreements, “joint protocols” with providers and organizations in the community suffice.

Upcoming Events

FTLF will be hosting a webinar on April 24 at 1 p.m. ET that will cover these new developments. To be notified when the webinar is available, click here.

For further learning, we also have a February 2023 recorded workshop on CCBHC Opportunities in CY2023 available here.