Over the past few years, there has been a lot of discussion about the Certified Community Behavioral Health Center (CCBHC), and until recently, it’s been just that – a lot of talk. But over the past few months, the CCBHC concept has begun to take shape – and it’s time for provider organizations interested in becoming a CCBHC to take action.
Last fall, the federal Substance Abuse and Mental Health Administration (SAMHSA) awarded funding to 24 states to develop plans for Certified Community Behavioral Health Center (CCBHC). In October 2016, the states will submit applications to participate in a two-year demonstration program, and in the end, only eight of the 24 states will be selected to participate. Those eight states will begin implementation of the demonstration program in January 2017 (see 24 States Awarded Planning Funds For Federal Certified Community Behavioral Health Center Demonstration).
The question is, what do you do if you’re a provider organization in one of the 24 states that won a planning grant? How do you help to ensure that your state is one of the eight selected to participate in the demonstration?
Any community behavioral health center that wants to be certified as a CCBHC must meet a set of specific criteria outlined by SAMHSA. States must then review documentation proving that the mental health center meets this set of criteria. (For more detail on the specifics of the requirements, see Criteria For The Demonstration Program To Improve Community Mental Health Centers & To Establish Certified Community Behavioral Health Clinics.) The certification criteria are grouped into six topic areas:
- Staffing mix—Staff must have diverse disciplinary backgrounds, have necessary state required licenses and accreditations, and must be culturally and linguistically trained to serve the needs of the clinic’s patient population.
- Service access and availability—The services, including crisis management, must be available and accessible 24 hours a day.
- Coordination of services—Care must be coordinated across settings and provider organization types to ensure seamless transitions for patients across the full spectrum of health services, including acute, chronic, and behavioral health needs.
- Scope of services—All services must be provided in the context of person-centered care, and the CCBHC must provide a specific set of nine services directly, or through a formal partnership or contract with other provider organizations.
- Quality improvement and reporting—All CCBHCs must be able to report encounter data, clinical outcomes data, quality data, and any other data required by the state or federal Medicaid program.
- Organizational, authority, governance, and accreditation—The CCBHC designation is limited to community mental health centers operated by non-profit organizations
At first glance, this list might seem daunting, and while there are challenges to putting together all the required services in the network (including 24/7 crisis access and culturally competent services) – the criteria generally fits into the strengths that most Community Mental Health Centers (CMHC) inherently have. The required care coordination is an extension of targeted case management with a slightly increased level of intensity. The required linkages with community service agencies such as criminal justice, the schools, and other agencies is usually standard practice for case managers. If crisis services need expansion, this provides an opportunity to accomplish this goal with some financial support. For many organizations, their existing strengths will help them to meet this new opportunity.
On the other hand, the required expansion of services to include primary care and coordination with other health care service providers may be more daunting. However, most CMHCs have been searching for a way to collaborate with a federally qualified health center (FQHC) or a Rural Health Clinic to develop improved access to health care services. This requirement will open that opportunity to provide health care access and assist with some of the start-up cost. Expanding your awareness of your consumer’s health care status and needs is a bonus.
Probably the most daunting challenge organizations will encounter with this program is moving to a value-based payment mechanism. In this case, the CCBHC grant requires using a prospective payment structure.This requires understanding and managing services and costs. Many CMHCs have had some experience with managed bundled payments, such as monthly targeted case management rates or some of the Medicaid home- and community-based waiver services. The experience of a prospective payment for the CCBHC may seem different, but with some technical assistance, most CMHCs can develop the needed mechanism to track and manage both the cost and volume of services (see Certified Community Behavioral Health Cost Report). Once you have a structure to perform these financial procedures and analysis, you will find it invaluable when addressing the value-based reimbursement in the future – even if your state or organization doesn’t move forward with the CCBHC program at this time.
Overall, involvement with the process of applying for and, hopefully, becoming a demonstration site as a Certified Community Behavioral Health Center is a worthwhile activity. If you are successful, you are on the “cutting edge” of the movement for care integration. If not, you have developed tools to prepare you for the inevitable future changes that will occur. If you have any questions about this process, feel free to contact me at firstname.lastname@example.org.