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The Protecting Access to Medicare Act of 2014 (PAMA) was enacted in 2014. Section 223 of the Act provides for the creation and evaluation of a demonstration program to improve community mental health services. Section 223 authorized the U.S. Department of Health and Human Services (DHHS) to establish a federal criteria for the demonstration program and for clinics to be certified by a state as a Certified Community Behavioral Health Clinic (CCBHC).
In 2016, Michigan's Department of Health and Human Services (MDHHS) requested to become a CCBHC demonstration state under Section 223 of PAMA. Initially, eight other states were selected by DHHS to participate in the demonstration from 2017 - 2019. Then, on August 5, 2020, Michigan's request was approved by Centers for Medicare and Medicaid Services (CMS) as the federal CARES Act of 2020 authorized two additional states to join the demonstration.
Michigan's two-year long demonstration began on October 1, 2021. At the end of the demonstration, MDHHS will evaluate the program's impact and assess the potential to continue or expand the initiative.
CMS CCBHC Demonstration Versus SAMHSA CCBHC Expansion Grants
There are two federal programs that contain "CCBHC" in the name - the CMS CCBHC Demonstration and the Substance Abuse and Mental Health Services Administration (SAMHSA) CCBHC Expansion Grant. These are two different opportunities, as outlined below:
CMS CCBHC Demonstration - funded using a Prospective Payment System (PPS) rate for qualifying encounters provided to Medicaid beneficiaries. States are responsible for overseeing the demonstration program, including clinic certification, payment, and compliance with federal reporting requirements. 13 entities are participating in the CMS CCBHC Demonstration.
SAMHSA CCBHC Expansion Grants - funded directly to local clinics with self-attestation that they meet baseline CCBHC criteria. States do not have any direct role in these grants. Michigan has SAMHSA CCBHC Expansion Grantees that are also included in the CMS CCBHC demonstration.
The CCBHC demonstration aims to improve the behavioral health for all Michiganders by:
- increasing access to high-quality care,
- integrating behavioral health with physical health care,
- promoting the use of evidence-based practices, and
- establishing standardization and consistency with a set criterion for all certified clinics to follow.
The demonstration requires and emphasizes accessible 24/7/365 crisis response services, along with other critical elements including: strong financial and quality metric reporting accountability; 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.
CCBHCs are designed to provide comprehensive mental health and substance use disorder services to persons in need, regardless of their ability to pay, including those who are underserved, have low incomes, are on Medicaid, insured or uninsured, and are active-duty military or veterans.
CCBHCs are considered a new Medicaid provider type, however Medicaid is not required to receive services.
CCBHCs are required to provide a set of nine comprehensive services, either directly by the CCBHC or through designated collaborating organizations (DCOs):
- Crisis mental health services, including 24-hour mobile crisis teams, emergency crisis intervention services, and crisis stabilization.
- Screening, assessment, and diagnosis, including risk assessment.
- Patient-centered treatment planning or similar processes, including risk assessment and crisis planning.
- Outpatient mental health and substance use services.
- Outpatient clinic primary care screening and monitoring of key health indicators and health risk.
- Targeted case management.
- Psychiatric rehabilitation services.
- Peer support and counselor services and family supports.
- Intensive, community-based mental health care for members of the armed forces and veterans, particularly those members and veterans located in rural areas.
Services must be provided in accordance with the federal criteria provided by SAMHSA.
CCBHC services are available to any person in need, including but not limited to those with serious mental illness, serious emotional disturbance, long-term chronic addiction, mild or moderate mental illness, and substance use disorders. A pre-existing diagnosis is not required, as CCBHCs are required to provide timely assessment and diagnostic services.
Any person with a mental health or substance use disorder (SUD) ICD-10 diagnosis code, as cited in Appendix B (page 38) of the CCBHC Demonstration Handbook, is eligible for CCBHC services. The mental health or SUD diagnosis does not need to be the primary diagnosis. Individuals with a dual diagnosis of intellectual disability/developmental disability are eligible for CCBHC services.
CCBHCs must service all individuals regardless of residency or ability to pay. For individuals residing out of state, CCBHCs are responsible for providing, at a minimum, crisis response, evaluation, and stabilization services and should have protocols developed for coordinating care across state lines.
Locations & Contact Information
13 behavioral health service providers are participating in the demonstration program. These sites, comprised of both rural and urban locations, include 10 Community Mental Health Services Programs (CMHSPs) and 3 non-profit behavioral health entities, together serving 16 Michigan counties. For locations and contact information, go to Consumer Resources.