Certified Community Behavioral Health Clinics (CCBHC): What It Means For Behavioral Health Providers

In April of 2014, Congress passed the Protecting Access to Medicare Act of 2014, which is also referred to as PAMA. Section 223 of this Act requires that the Department of Health and Human Services (HHS) create a process to certify Community Behavioral Health Clinics. Once a clinic receives certification, it becomes a Certified Community Behavioral Health Clinic (CCBHC).

What is a CCBHC?

The EMHA defines Certified Community Behavioral Health Clinics as facilities specifically designed to provide a community with an all-inclusive range of substance use and mental health disorder services, especially for individuals who have the most complex needs.

Who do Certified Community Behavioral Health Clinics Serve?

CCBHCs are designed to provide easy, welcoming access to medical care, behavioral health and support services, even if he or she is unable to pay for the services received. In addition, the individual’s place of residence is irrelevant.

These individuals include (but are not limited to):

• Children who have serious emotional disturbances
• Individuals with chronic addiction
• Those with mild/moderate substance use disorders
• Individuals who have complex health profiles
• Adults who have severe mental illness (Schizophrenia, Bipolar disorder, etc.)
• Individuals with mild/moderate mental illness
• Insured and uninsured individuals
• Those who are on Medicaid
• Members of the armed services/veterans
• Low income or underserved individuals/families

Each state is required to certify that its CCBHCs offer the following services. Some of these services must be offered directly, whereas others can be offered through a designated collaborating organization (DCO). However, in order to offer services through a DCO, a formal contract must be created. While the demonstration program is in effect, the following services will be covered even if they are not included in the state’s Medicaid plans.

Evolution of the CCBHC Program

• April 2014: Congress enacts Protecting Access to Medicare Act of 2014 (PAMA), requiring Department of Health and Human Services to establish a process for certification of Certified Community Behavioral Health Clinics as part of a two-year demonstration project under Medicaid
• October 2015: SAMHSA awards 24 states planning grants to design a CCBHC program
• October 31, 2016: Deadline for states to submit CCBHC program plans
• January 2017: States are selected to begin two-year demonstration program
• 2018
• November 21, 2019: CCBHC funding extension signed into law through December 20, 2019
• December 6, 2019: Congress unveils updated bill that includes two-year extension of the CCBHC program
• December 20, 2019: Congress approves 2020 appropriations bill that includes 5-month extension for the CCBHC demonstration and a $50 million increase for the CCBHC Expansion Grants
• January 15, 2020: SAMHSA opens CCBHC Expansion Grant Program to clinics across all 50 states. Application deadline is March 10, 2020.

CCBHC Readiness

What is CCBHC readiness? The statute that created the CCBHC program has set forth certain requirements that a clinic must meet to become certified. Some community behavioral health providers are already taking steps to become “CCBHC-ready.” These providers are creating new relationships as well as strengthening and formalizing their existing relationships with the social service agencies and other providers within their communities.

For-Profit Organizations and Clinics Are Not Eligible

Despite the fact that privately-owned, for-profit organizations and clinics are not eligible to become a CCBHC, these establishments can still participate by becoming a designated collaborating organization (DCO). To become a DCO, a formal agreement must be created between the for-profit establishment and the CCBHC. Even in the event that the Indian Health Services (IHS) or the local behavioral health authority pays for the services rendered at the clinic, a for-profit clinic is not eligible to become a CCBHC.

For-Profit Organizations and Clinics Can Become DCOs

For-profit organizations that want to become a DCO must meet certain requirements.

These requirements include:

Scope of Services

The CCBHC criteria require CCBHCs to provide consumers a range of services. While many of the required services must be provided by the certified community behavioral health clinic itself, other services can be provided by a contracted DCO.

A Formal Relationship Between the CCBHC and the DCO Must Be Created

The formal relationship between the DCO and the CCBHC is critical in that the certified community behavioral clinic is ultimately responsible for all of the care a consumer receives. This is true whether the services are provided by the CCBHC itself or by the DCO. The relationship between these two establishments is considered a contract.

The CCBHC and DCO Formal Agreement

The formal agreement that is made between the DCO and CCBHC may also be referred to as a Memorandum of Understanding (MOU) or a Memorandum of Agreement (MOA). This agreement should describe the expectations of each party (the DCO and the CCBHC) as well as establish accountability for the services that will be provided. In addition, specifics related to the funding that will be sought and utilized need to be addressed when creating this contract.

CCBHC Preparedness – The Process for Becoming a CCBHC

To become a CCBHC, there are six core areas that the Excellence in Mental Health Act outlines.

All six of these core areas are required:

1. Availability and easily accessible services
2. Staffing
3. Care coordination
4. Quality and other reporting
5. Scope of services
6. Organizational authority, accreditation and governance

Eventually, the SAMHSA will set forth specific standards related to each of the six core areas. States will be responsible for putting these six core areas in use and establishing a certification process for facilities that would like to become CCBHCs. The eight states that the SAMHSA chose to participate in the CCBHC federal demonstration program have a unique opportunity to essentially transform the way behavioral health services are delivered to high-need populations.

The Centers for Medicare and Medicaid Services (CMS) is committed to assisting states as they explore the options for maintaining CCBHC services. The behavioral health advocacy community and congressional champions of the EMHA are working together to expand the demonstration so it includes more states, and lasts longer than two years.

Clinics Operated by the State

Since a state-operated clinic is considered a local government behavioral health authority, these clinics are eligible to become a CCBHC. That said, in order to be eligible, a county, locality, state or region must oversee the clinic’s substance use and/or mental health services and provide these services at the clinic itself. Clinics owned and operated by the local behavioral health authority can become a CCBHC as long as it meets the criteria necessary for certification.

Nonprofit Organizations

A nonprofit organization that has multiple clinics may become a CCBHC. To do so, all of its components must meet the criteria set forth by the HHS. If all of the requirements are not met, the parent organization will not be a certified community behavioral health clinic.

A clinic that is part of a large nonprofit organization can become a CCBHC, and another faction of the same organization can become a DCO. Needless to say, the clinic must meet the requirements set forth by the HHS, and the other faction of the organization must meet the requirements to become a DCO.

For example, a nonprofit organization with only one certified community behavioral health clinic and a state-sanctioned, licensed or certified behavioral health crisis system may apply for the crisis system to become a DCO for its already existing CCBHC. Again, the requirements of this relationship must be satisfied.

Tribal Health Organizations

Tribal health organizations, health centers or clinics may become a CCBHC as long as the organization, center or clinic meets the requirements set forth by the HHS. Furthermore, the facility must be operated under the authority of an Indian tribe, a tribal organization or the IHS in accordance with a contract, cooperative agreement, grant or compact with the IHS (pursuant to the Indian Self-Determination Act). In addition, entities that are funded as Urban Indian Health Centers via a contract or grant from the IHS (under Title V of the Indian Health Care Improvement Act) can become a CCBHC or a DCO.

The CCBHC Contracting and Community Partnerships Toolkit

The National Council for Behavioral Health offers providers the CCBHC Contracting and Community Partnerships Toolkit to assist them as they determine their eligibility to become a CCBHC or DCO. Via this documentation, providers can also learn more about the goals of the CCBHC demonstration.

Did you know that 55 of the 67 CCBHCs are current Relias clients? Relias offers learning content aligned to CCHBC certification criteria along with data analytic capabilities on community health measures for ongoing performance tracking.

Learn more

CCBHC News and Resources

• The National Council—CCBHC Topic Hub
• The National Council—CMS and SAMHSA Guidance Documents
• The National Council—CCBHC Certification Criteria Feasibility and Readiness Tool
• The National Council—Getting Paid as a CCBHC
• SAMHSA—CCBHC Criteria
• SAMHSA – Funding Opportunity Announcement (FOA) Information
• SAMHSA – FY 2020 Certified Community Behavioral Health Clinic Expansion Grants (PDF)
• Relias—CCBHC Sample Training Plan
• Relias—Board Member Training