Over the years, we’ve written about the federal Certified Community Behavioral Health Clinic (CCBHC) initiative (see CCBHCs Are Moving Forward – What This Means If Your State Isn’t Moving Forward, Are You Ready To Be A Certified Community Behavioral Health Center?, CCBHCs In 8 States Projected To Serve 380,000 Individuals In First Year). And this summer, the demonstration was slated to end, leaving states, Congress, and provider organizations scurrying to figure out what to do next. So where are states now and what does the future look like?
As a reminder, CCBHCs are behavioral health provider organizations that receive a prospective payment rate for delivering care in return for meeting six key criteria related to staffing mix; service access and availability; coordination of services; scope of services; quality improvement and reporting; organizational, authority, governance, and accreditation. In order to help states prepare for the demonstration, planning grants were awarded to 24 states in 2015 and then eight states were selected to actually participate in the demonstration. Those states are Minnesota, Missouri, Nevada, New York, New Jersey, Oklahoma, Oregon, and Pennsylvania (see 75 Behavioral Health Provider Organizations In 8 States Prepare For CCBHC Demonstrations).
Technically, the demonstration ended on June 30, 2019 after two years. In August, Congress extended funding for the demonstration to September 13, 2019 (see House Passes Short-Term CCBHC Extension, Bill Now Heads to White House), and in September the Senate cleared a short-term spending bill that includes an extension of the CCBHC until November 21 (see Senate Clears Stopgap, Pivots To Endgame Spending Talks and H.R.4378 – Continuing Appropriations Act, 2020, and Health Extenders Act of 2019). Continued funding for the program is included in the President’s budget and is expected to have bipartisan support (FY2020 Budget in Brief).
Regardless of the decisions at the federal level, six of the eight states are committed to continuing to fund the program. Only Pennsylvania and New Jersey are awaiting federal funding to make their decision to continue the program (see July MAAC Meeting Minutes). In order to continue the demonstration, most states are submitting state plan amendments (SPA) to the Centers for Medicaid & Medicare Services (CMS).
- Minnesota- Continued payment for the CCBHC program was included in the state’s 1115 demonstration waiver approved in June 2019. The approval is for one year in order to allow the state to submit the necessary SPAs and documentation to continue the program (see Minnesota Medicaid To Expand Addiction Treatment Via CCBHCs & Short-Term Residential Treatment Benefit).
- Missouri – In June, the state received approval of their SPA to continue the CCBHC program (see Missouri Medicaid To Continue Prospective Payments To 15 CCBHOs).
- Nevada – The state plans to continue paying a bundled rate for services and will certify seven additional clinics. Until the SPA is approved, the three clinics will receive about 75% of their average monthly billing (see Nevada Submits Medicaid State Plan Amendment To Transition CCBHC Funding To Traditional Medicaid
- New York – Official documents on the continuation of the program is not available, however the state is expected to submit a state plan amendment.
- Oklahoma – CMS approved Oklahoma’s SPA to continue the CCBHC program on July 1, 2019. The state plans to certify new CCBHCs (see SPA OK 19-0010).
- Oregon – The state has indicated that they plan to submit a SPA right away (see Request for comment – OHA proposes to amend the Medicaid State Plan to include the Certified Community Behavioral Health Clinics Demonstration as a state plan program).
Overall, the fact that six states are planning to permanently continue to the CCBHC program is promising. It indicates that they are committed to new model for delivering and financing behavioral health services. For provider organizations, who do not serve these states, the results of the demonstration are still relevant. CCBHCs really serve as a model for the future, the key competencies required of the organizations include the adoption of technology, tracking of outcomes, new financing models, and coordination of services. Organizations can use the CCBHC model as a benchmark for their organization and as a model for developing core competencies for operating in a value-based environment.
For even more, join us at The 2019 Technology & Informatics Institute in Philadelphia on October 29 for the keynote address, Leveraging Technology To Expand Access, Enhance Consumer Experience & Improve Outcomes In A Behavioral Health Care Marketplace Dominated By Value-Based Models featuring Alison Nelson, Senior Vice President for Optum Technology, Optum.