The goal of the Excellence in Mental Health Act (EMHA) is not to direct healthcare professionals on how they should provide care; instead, the EMHA is designed to aid a facility in its ability to provide each client with an excellent standard of care despite his or her particular situation. The act offers quality objectives that intend to place a renewed focus on person-centered care as well as the quality of the care delivered. Furthermore, the act defines a new approach to providing medical care: Certified Community Behavioral Health Clinics (CCBHC).
Certified Community Behavioral Health Clinics – Defined
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.
The CCBHC Federal Demonstration Program
In 2015, the Substance Abuse and Mental Health Services Administration (SAMHSA) awarded grants to 24 states, and each of these states used their grant to plan Certified Community Behavioral Health Clinics (CCBHC) projects. The 24 states had until Oct. 23, 2016 to submit their program proposals to the SAMHSA. On Dec. 22, 2016, the SAMHSA selected the eight states that will participate in this federal demonstration program.
The eight states selected to participate in the CCBHC Federal Demonstration Program are:
- New Jersey
- New York
Project grants will fund the CCBHCs of these eight states for at least two years.
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.
CCBHCs must provide the following services directly:
- Treatment planning that centers around the client
- Crisis mental health services
- Emergency crisis intervention
- 24-hour crisis teams (mobile) that are available 365 days a year to assist with stabilizing individuals in the least traumatizing and restrictive environment as well as in the most clinically appropriate, and cost-effective settings.
- Crisis stabilization
- Outpatient mental health services
- Outpatient substance use services
- Screening, evaluation and diagnosis (including risk management)
The following services can be offered by the CCBHC itself and/or through a contracted DCO:
- Support services – family and peer
- Intensive mental health care for veterans and current members of the armed forces (especially for those who reside in rural areas)
- Psychiatric rehabilitation
- Targeted case management
- Primary care screening/monitoring
- Care coordination agreements with other systems and providers (i.e., primary care, education, hospitals, child welfare, foster care, criminal justice, etc.)
This Assortment of Required CCBHC Services is Deliberate
The goal of a CCBHC is to provide individuals with a comprehensive array of services that will allow for easy access, the ability to stabilize individuals who are in crisis, as well as provide treatment to individuals who have the most serious addictions and complex mental health issues. Additional services are integrated into the CCBHC as a means to ensure a health care approach emphasizing recovery, trauma-informed care, wellness and the integration of physical, and behavioral health.
Benefits of Becoming a CCBHC
CCBHCs are entitled to receive enhanced payment via a Prospective Payment System (PPS), which is similar to the method used by Federally Qualified Health Centers and other providers. The PPS method is designed to reimburse providers based on the anticipated costs associated with serving the people in their community. This is beneficial because CCBHCs will be able to receive payment for numerous activities that are not usually funded through the current funding streams. For example, CCBHCs can receive payment for services rendered outside of the clinic itself, for peer services, telehealth, care coordination activities, and more.
States have two payment options to choose from:
- A daily rate – the CCBHCs are paid a single daily rate for each of the Medicaid clients that received services at the clinic itself or the DCO.
- A monthly rate – the CCBHCs are paid a monthly rate for each Medicaid client who received services at the clinic itself or the DCO during a specific month. Under the monthly rate, clinics can subdivide client populations according to their different level of need, which allows for varying pay rates.
The services rendered to a Medicaid client are irrelevant: PPS rates are CCBHC specific and clinics receive the same rate regardless of the services rendered (unless the monthly rate is chosen, in which varying rates apply).
To establish PPS rates, CCBHCs are required to create a cost report. This report must include the cost of providing services to all the clients, not just the clients who have Medicaid. The cost report will assist the SAMHSA in establishing a per-day or per-month cost of serving clients in a particular clinic. This report can include cost estimations related to new services or costs that will be incurred, or provided during the demonstration phase of the federal demonstration program. The costs related to DCO services are included in the prospective payment rate for the CCBHC. For the purpose of the prospective payment system, DCO encounters are considered CCBHC encounters and paid accordingly.
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:
- Availability and easily accessible services
- Care coordination
- Quality and other reporting
- Scope of services
- 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.
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