Insights

Opportunities related to Certified Community Behavioral Health Clinics (CCBHCs) continue to expand for both states and providers. With this increased investment in the model comes the need for continued refinement and improvement. CCBHCs enable government and other payors and providers to increase capacity and move towards a transformed behavioral health system that is responsive to local community needs. This article summarizes a number of new developments that will impact CCBHCs, including a few opportunities for expansion that you may not want to miss.

Background

CCBHCs provide integrated and coordinated community-based care for individuals across the lifespan who are living with and/or at risk for behavioral health conditions. The model is designed to increase access to behavioral health services; provide a comprehensive range of services, including crisis services, that respond to local needs; incorporate evidence-based practices; and establish care coordination as a linchpin for service delivery. To date, CCBHCs have demonstrated positive outcomes, such as: [i]

• Significant reductions in client hospitalizations
• Increased access to high quality community-based care, including services like Medication Assisted Treatment and care coordination
• Mitigation of the challenges related to the national health care workforce shortage
• Innovative and strengthened partnerships with cross-system partners, such as law enforcement, schools, and hospitals

SAMHSA CCBHC Demonstration Grant Opportunity Releases for States

Earlier this month, SAMHSA released its CCBHC Demonstration Program opportunity for states who currently or have previously held a CCBHC Planning Grant. The Demonstration RFP (request for proposals) will allow selected states to initiate a CCBHC Demonstration Program starting on July 1, 2024. In 2016, Minnesota, Missouri, Nevada, New Jersey, New York, Oklahoma, Oregon, and Pennsylvania were selected by the U.S. Department of Health and Human Services (HHS) to participate in the initial CCBHC Demonstration Program. In August 2020, Kentucky and Michigan were selected as two new CCBHC Demonstration States through the Coronavirus Aid, Relief, and Economic Security Act (P.L. 116-136). Through this most recent 2024 CCBHC Demonstration opportunity, SAMHSA will select up to 10 additional states to participate in the CCBHC Demonstration, as outlined by the Bipartisan Safer Communities Act of 2022 (P.L. 117-259).

For those interested in this RFP:

• Eligibility: States selected for the 2016 or 2023 CCBHC Planning Grant (that are not currently participating in the Demonstration Program) are eligible to apply for this RFP.
• Due Date: Applications are due March 20, 2024, at 11:59pm EST and must be submitted by email to [email protected]. Awarded states will be announced in June 2024.  
• Evaluation Criteria: As outlined in the Protecting Access to Medicare Act (PAMA) of 2014, state applications will be scored on their ability to:
  • Provide the most complete scope of services
  • Improve availability of, access to, and participation in, CCBHC services
  • Improve availability of, access to, and participation in assisted outpatient mental health treatment in the state
  • Demonstrate the potential to expand available mental health services in a demonstration area and increase the quality of such services without increasing net federal spending

For additional context and background on this opportunity, HMA and the National Council hosted a webinar on October 6, 2022, on “Developing a Strategy for the CCBHC State Demonstration RFP.” During this webinar, we engaged representatives from New York and Michigan to share information about their demonstration program implementation to date.

Other CCBHC Updates of Note

In addition to this state Demonstration RFP, there have been several recent updates to CCBHC-related guidance documents that are worth noting for anyone who is currently participating and/or interested in the CCBHC model:

Updates to the Prospective Payment System (PPS) Guidance

Under the state CCBHC Demonstration Program, CCBHCs are paid a daily or monthly Prospective Payment System (PPS) rate. In 2023, in preparation for issuing an updated guidance, CMS held a forum for states, providers, and other stakeholder input on newly proposed PPS changes. In February 2024, the updated PPS Guidance was released, reflecting gathered feedback incorporating payment flexibilities and alignment with revisions to the CCBHC criteria. One major change was the addition of two PPS options for states, which addresses the high-cost and specialized care delivered through mobile and on-site crisis intervention services provided directly to individuals. Specifically:

• PPS-3 offers states the option to reimburse CCBHCs on a daily basis, including daily Special Crisis Services rates, which allow states to set separate PPS rates for crisis services provided by CCBHCs.
• PPS-4 offers states the option to reimburse CCBHCs on a monthly basis, including monthly Special Crisis Services rates. Quality Bonus Payments are also required under this PPS-4 structure.

Additionally, the metrics for Quality Bonus Payments (which are required as part of the PPS-2 and PPS-4 monthly rate structures and optional for the PPS-1 and PPS-3 daily rate structures) have been modified to align with the revised CCBHC Quality Metrics. Additionally, CMS added new guidance related to payments to CCBHCs that are also certified as FQHCs (Federally Qualified Health Centers) and other provider types operating within the Medicaid program.

Overall, this updated PPS Guidance is effective on or after January 1, 2024 for existing CCBHC Demonstration States and on or after July 1, 2024 for newly selected states added to the program under the above CCBHC Demonstration Program RFP.

CCBHC Quality Metrics: Final Specifications Released

Further, when SAMHSA revised the CCBHC criteria in March of last year, they also updated the required and optional quality measures for both CCBHC providers and states operating a Demonstration program. The revised guidance specifies that all CCBHCs, including those participating in a State Demonstration Program as well as providers funded by a SAMHSA CCBHC Grant, must begin collecting and reporting on the required provider-specific measures starting in calendar year 2025. Similarly, states participating in the CCBHC Demonstration Program must transition to reporting on the new state-specific measures as well, with their first measurement year for the new measures running from January 1, 2025 – December 31, 2025.

Earlier this month, SAMHSA released the final specifications for each of the required and optional CCBHC quality measures. Providers and states alike are currently working hard to prepare their quality processes and systems to report on these new measures. With the inclusion of SAMHSA-funded CCBHCs in these quality measure reporting requirements, the hope is that the expanded data will assist us all in better understanding the impact of the CCBHC initiative as it relates to access to care and outcomes.

Guidance for States on CCBHC Criteria Customizations

Finally, SAMHSA recently released updated guidance for states looking to customize the federal CCBHC criteria as part of their CCBHC Demonstration Programs, to align with updates they made to the federal criteria in March of 2023. The guidance outlines, for a variety of criteria, how states may add or customize the requirements. Importantly, all CCBHCs operating either under a SAMHSA CCBHC Grant Program or a state-run CCBHC Demonstration Program must meet all of the revised federal CCBHC Criteria on or before July 1, 2024. Building on the federal criteria, many states are strategically taking advantage of customization opportunities to better align the CCBHC model with their system-wide goals and address gaps within their current behavioral health system’s capacity.

Upcoming opportunities for CCBHC expansion

In addition, there are several upcoming opportunities on the horizon for both states and providers looking to enter the CCBHC space.

New CCBHC-Expansion Grants for Behavioral Health Providers

SAMHSA’s Fiscal YeaGr 2024 budget requested $552.5 million for the CCBHC Expansion Program, which is a $167.5 million increase above the FY 2023 enacted level. The CCBHC-Expansion Grant Program includes both “Improvement and Advancement” grants for existing CCBHCs looking to enhance their programs, as well as “Planning, Development, and Implementation” grants for providers looking to establish a new grant-funded CCBHC.

SAMHSA’s FY24 funding will support 360 continuation grants, as well as award a new cohort of 158 grants, and a technical training assistance center grant to continue the improvement of mental disorder treatment, services, and interventions for children and adults. The budget also proposes to establish “an accreditation process [that] would ensure consistent adherence to the CCBHC model and create capacity to confirm adherence to the criteria and the model.”

While the new CCBHC-Expansion Grant RFPs are not currently posted on SAMHSA’s list of projected RFPs, we can expect (based on prior rounds) they are likely to be released sometime in the spring.

Expected Upcoming CCBHC Planning Grant for States

In addition to seeding the selection of a new cohort of 10 states to participate in the CCBHC Demonstration Program starting through the above Demonstration Program RFP and then every two years thereafter, the 2022 Bipartisan Safer Communities Act also earmarked funding for SAMHSA Planning Grants to support states looking to join the Demonstration. For states who are not selected to participate in the CCBHC Demonstration Program starting on July 1, 2024, we expect another CCBHC Planning Grant RFP to be released in the fourth quarter of this calendar year, with another round of 15 Planning Grants to be awarded to selected states in 2025.

States looking to prepare for the next Planning Gant RFP can review HMA’s summary of the most recent Planning Grant opportunity and watch HMA’s webinar co-hosted with the National Council for Mental Wellbeing that provides an overview of the previous RFP.

Interested in Learning More?

Reach out to our experts! HMA offers a deeply informed yet neutral perspective on CCBHC development, with team members who specialize in operations, quality, and fiscal components of the CCBHC model. We have helped 17 states successfully write their CCBHC Planning Grant applications, and in 2023 alone, we helped behavioral health providers secure approximately $80 million in expansion grant funding they are using to support their communities. Our team of experts brings extensive experience supporting both states and providers to leverage the CCBHC model to support their overall system transformation goals.

Click here to learn more about our work with CCBHCs or contact:

Heidi Arthur, Principal
Kristan McIntosh, Principal
Josh Rubin, Principal

[i] https://www.thenationalcouncil.org/wp-content/uploads/2022/06/22.06.06_HillDayAtHome_CCBHC_FactSheets.pdf

The National Council for Mental Wellbeing (NCMW) launched the Center for Workforce Solutions in 2023 in partnership with The College for Behavioral Health Leadership (CBHL) and Health Management Associates (HMA). The partnership is leveraging Collective Impact to address the workforce crisis, and using a cross-sector approach to address the long-standing challenges for expanding and solidifying the behavioral health workforce. The partners identified a gap in advancing workforce solutions with many national convenings creating various sets of recommendations without a coordinated or clear approach to moving recommendations to action.

Why use Collective Impact?

• Workforce challenges and solutions require a cross-sector approach including changes in Federal and State regulations as well as at the provider level. Need a coordinated approach to truly reach change.
• There are a lot of recommendations nationally with stalled action in many cases because the recommendations require other implementers to act.
• No single accountable entity to ensure recommendations move forward
• Need for cross-sector agreement on strategies and then cross-sector implementation
• Scale of the challenge can create overwhelm and inertia to address big gaps
• Leverage the work being done across partners while building a coordinated effort

Check out this webinar recording to learn more about the history of this effort.

Link to the Webinar

2023 Progress

The partnership was busy in 2023 with activities to build multiple avenues for change:

• Building a robust partnership and backbone for the collective impact approach which is working seamlessly to support a national and cross-sector group of leaders to support implementation of recommendations that often require multiple levels of the system and cross-sector engagement.
• Developing a draft framework for the complexity of the workforce challenges and solutions and thinking about the implementers (regulators, policy makers, providers, and others) that are needed to implement recommendations.
• Cross-walking more than 400 recommendations from national sources including national and state approaches as well as provider lessons using the framework to understand consistent recommendations, identify themes and prioritize where to focus moving recommendations to action.
• Launching a Behavioral Health Provider and Association ECHO on workforce building a network of providers to share case studies and learn from each other and discuss innovative solutions for addressing workforce challenges.
• Continuing to identify funding support to move the collective impact approach forward.

What’s Coming in 2024?

• National Workforce Conversation—a virtual meeting open to all interested nationally to communicate and share information broadly and to collectively track what’s working and lessons learned in workforce efforts.
• Launch Steering Committee and Working Groups—which will include national key decision makers who will guide a coordinated approach to implementing recommendations and working cross-sector to be accountable to change.
• Launch Second ECHO for Providers and Associations to continue to share what’s working and improve the immediate workforce crisis at the provider level. Stay Tuned https://www.thenationalcouncil.org/program/center-for-workforce-solutions/engage/echo/
• NatCon’24: Register and join the Workforce Development and Talent Management Track (April 15 – 17, 2024)

Investments in children’s behavioral health represent a critical window of opportunity for fostering healthy child development and nurturing the resilience necessary for lifelong well-being. With over 40 percent of U.S. children and youth relying on the Medicaid system for healthcare coverage, it presents a platform to significantly enhance early intervention and prevention services, particularly for vulnerable children. Federal and state policymakers are increasingly active in formulating policies that prioritize investments in initiatives promoting mental and physical health at this pivotal developmental stage.

Health Management Associates (HMA) has partnered with the National Association of State Mental Health Program Directors (NASMHPD) Technical Assistance Coalition to produce a series of briefs that characterize the opportunities to improve coordination of services for children. Beyond the statistics lie the stories of countless vulnerable children and families facing immediate and critical needs. Addressing these issues requires comprehensive cross-system reforms, including policies that promote integrated financing, enhance care coordination, facilitate provider collaboration, and bolster upstream prevention efforts.

The importance of socio-emotional wellbeing as core to childhood development is underscored by evidence-based models and approaches, which consistently demonstrate the substantial value and long-term impact of investing in children’s mental and behavioral health. These investments not only benefit children and adolescents but also extend their positive effects to primary caregivers, creating a comprehensive and sustainable framework for fostering well-rounded, mentally resilient, and physically healthy lives.

The insights and recommendations presented in these briefs* underscore the urgency of coordinated action to improve the well-being of our nation’s youth and the opportunity for collaborative approaches to improve outcomes:

1. Bolstering The Youth Behavioral Health System: Innovative State Policies To Address Access & Parity (previously published in 2022)
2. System Integration Across Child Welfare, Behavioral Health, And Medicaid (previously published in 2022)
3. State Policy and Practice Recommendations to Advance Improvements in Children’s Behavioral Health*
4. Improving Outcomes for Children in Crisis with Evidence-Based Tools*
5. The Role of Specialized Managed Care in Addressing the Intersection of Child Welfare Reform and Behavioral Health Transformation*
6. Early Childhood Mental Health: the Importance of Caregiver Support in Promoting Healthy Child Development and Clinical Interventions for Children*
7. Connecting Schools to the Larger Youth Behavioral Health System: Early Innovations from California*

*Briefs 3-7 were funded by SAMHSA’s TT1 grant award for FY 2023.

This is part of a larger effort supported by HMA and a number of partner organizations, including NASMHPD, The Annie E. Casey Foundation, Casey Family Programs, MITRE, National Association of Medicaid Directors (NAMD), Child Welfare League of America (CWLA), and the Federal Government agencies ACF and SAMHSA, to help create a dialogue among state agencies and stakeholders working to improve child welfare. The briefs HMA released are a starting point for much of the upcoming dialogue. A federal policy discussion is being held at SAMHSA in mid-November.

Recognizing the complexity of the challenges that lie ahead, it is evident that no single agency can tackle them in isolation. This approach requires adequate funding and robust partnerships at all levels, from local to state and federal. HMA and our partners are producing a unique convening of state agencies promoting a collective approach to improving child-centered care, one that emphasizes child and family-centered practices and fosters local collaborations across each community’s system of care. This invitation-only event in early February 2024 will convene eight state government child welfare agencies and experts to develop methods for improving their services.

The work HMA is doing with our partners highlights the gravity of the problems while providing inspiring examples of successful collaborations from across the country. By examining what works in these models, the way forward becomes evident —a path toward the development of more seamless systems of care for children and youth grappling with behavioral health needs. As states and communities navigate these critical issues, we put forward this body of work as a valuable resource, offering insights and strategies to transform our approach to children and youth well-being and behavioral health support.

HMA will be sharing more about this effort in the coming months, including a webinar with our partners on December 12; registrants will receive a summary of the findings following the February 2024 event. If you want to learn more about this and other initiatives in child behavioral health, please contact HMA children’s behavioral health experts Caitlin Thomas-Henkel and Uma Ahluwalia.

Timeline of Key Events

• November 3, 2023: Release of SAMHSA funded briefs
• November 16, 2023: Federal Policy Convening (private)
• December 12, 2023: HMA Webinar featuring Partner Agencies to discuss federal convening insights, plans for February State Policy Lab. Watch webinar replay here.
• February 7-8, 2024: State Policy Lab (invitation only)
• Dates TBD: Release of blueprint/insights from State Policy Lab

At the upcoming NATCON24 convention, HMA principals Heidi Arthur and Ellen Breslin will conduct a motivating workshop called “Lifting Voices for Meaningful, Actionable Change: Insights from Navigating the Children’s System of Care.” During this workshop, Heidi and Ellen will discuss how their own journeys as mothers of children with significant behavioral health needs have informed their work as policy and practice advisors to state and local authorities. They will lift up the voices of their fellow parents and youth, whose insights they sought in order to inform improvements to behavioral health care and access at the state and local levels around the country. Heidi and Ellen seek to make this an engaging workshop for attendees and encourage all to join the call to action. 

Please join their workshop at NATCON24 on Monday, April 15, 2024 from 10:30– 11:30 AM CT in room 132, Level 1, ACCC.

As longtime leaders in health and human services, HMA’s behavioral health experts bring front line and leadership experience to their work supporting behavioral health authorities, child welfare programs and community and school-based providers of all kinds. We consult with public and private sector entities who serve children and families in order to improve access, streamline, and integrate care. We aim to advance equity and improve quality in state, county, and local program development. Contact us to learn more.

Learn more about the foundations of this project by accessing the Lifting Voices report from October 2023 below.