Certified Community Behavioral Health Clinics (CCBHC) Demonstration Program
In 2016, MDHHS applied to CMS to become a CCBHC Demonstration state under Section 223 of the federal Protecting Access to Medicare Act of 2014 (PAMA). That request was approved on August 5, 2020, when the federal CARES Act of 2020 authorized two additional states-Michigan and Kentucky-to join the demonstration. As a result, MDHHS was approved for a two-year demonstration with an anticipated implementation start date of October 1, 2021. The two-year period begins upon implementation. CMS requires a state to implement the demonstration in at least two sites - one rural and one urban. Moreover, per CMS, only the 14 prospective CCBHC Demonstration Sites named in Michigan's 2016 application are eligible to participate in the state's demonstration. These sites include 11 Community Mental Health Services Programs (CMHSPs) and 3 non-profit behavioral health entities, together serving 18 Michigan counties. MDHHS will ultimately select CCBHC Demonstration Sites in accordance with federal requirements, including the attainment of state based CCBHC certification, and available funding.
The CMS CCBHC Demonstration requires states and their certified sites to provide a robust set of coordinated, integrated, and comprehensive services to all persons with any mental illness or substance use disorder diagnosis. Moreover, the demonstration requires and emphasizes 24/7/365 crisis response services (e.g., mobile crisis services). Other critical elements include but are not limited to: strong accountability in terms of financial and quality metric reporting; formal coordination with primary and other care settings to provide intensive care management and transitions; linkage to social services, criminal justice/law enforcement, and educational systems; and an emphasis on providing services to veterans and active-duty service members. To account for these requirements, the state must create a PPS reimbursement structure that finances CCBHC services at an enhanced payment rate to properly cover costs and offer greater financial predictability and viability. The PPS is integral to sustaining expanded services, investments in the technological and social determinants of care, and serving all eligible Michiganders regardless of insurance or ability to pay.
CMS CCBHC Demonstration Versus SAMHSA CCBHC Expansion Grants
To mitigate potential confusion, there are two federal programs that contain the "CCBHC" name - the CMS CCBHC Demonstration and the SAMHSA CCBHC Expansion Grant. These are two disparate opportunities as outlined below:
The CMS CCBHC Demonstration is operationalized by the State and uses a Prospective Payment System (PPS) rate for qualifying encounters provided to Medicaid beneficiaries. Prospective CMS CCBHC Demonstration Sites are limited to the 14 entities included in Michigan's 2016 application to CMS. Moreover, the State is responsible for overseeing the demonstration program, including clinic certification, payment, and compliance with federal reporting requirements.
The SAMHSA CCBHC Expansion Grants, however, are funded directly to local clinics with self-attestation that they meet baseline CCBHC criteria - the State does not have any direct role in these grants. Michigan has 24 SAMHSA CCBHC Expansion Grantees, some of which were also named in Michigan's 2016 application to CMS.