Define CCBHCs as a provider type within CMS
Recommendation
Congress should define Certified Community Behavioral Health Clinics (CCBHCs) as a provider type within the Centers for Medicare and Medicaid Services (CMS).
Background/summary
Congress established the CCBHC model as a Medicaid demonstration under Section 223 of the Protecting Access to Medicare Act of 2014. The original 10 CCBHC demonstration states will be graduating from the demonstration over the next few years and will need to seek a state plan amendment or an 1115 waiver to maintain their already-implemented CCBHC models. Additionally, other states that seek to establish the CCBHC model outside of the demonstration will also need to apply through a state plan amendment or waiver. The lack of a federal CCBHC definition creates a risk that states and their CCBHCs may not have consistent models, affecting both outcome data and the quality of care provided.
The Bipartisan Safer Communities Act of 2022 allows for 10 new states to join the CCBHC Medicaid demonstration every two years. Having a standard federal CCBHC definition gives states the ability to continue their existing CCBHC models and will expedite efforts for states implementing the CCBHC model by having clear guidance for state plan amendments and 1115 waiver. This will also support fidelity to the CCBHC model that Congress established and continues to support.[1]
citations
1. Becker, Colleen. 2022. “The Value of Certified Community Behavioral Health Clinics.” National Conference of State Legislatures. Last Updated July 7, 2022.