Historic Medicaid statute change opens door for CCBHC opportunities

In a move of historical significance, U.S. Congress has added Certified Community Behavioral Health Clinics (CCBHC) services as a new option under state Medicaid plans, underscoring the important role of these clinics in the communities they serve.

This major change to the federal Medicaid statute was enacted under the Consolidated Appropriations Act of 2024 (CAA) and took effect in March.

Medicaid statute change offers a faster option.

Medicaid statute changes are rare. This is the first time since the Medicaid statute was enacted in 1965 that mental health and substance abuse services have been specifically included in this manner in the Medicaid law.

The change is part of an overall transformation taking place in mental health and substance use disorder services in communities throughout the nation, with the intent to ensure wider service availability to Medicaid beneficiaries.

It is also important because it offers states another option for using the CCBHC model to deliver needed services instead of waiting for their turn to participate in ongoing CCBHC demonstrations.

Confusing rules and regulations for different types of CCBHCs.

Previously, states had limited options in implementing CCBHC service models.

Only a handful of states were targeted for an initial demonstration model launched through the Protecting Access to Medicare Act of 2014 (PAMA.) Those states included Kentucky, Michigan, Minnesota, Missouri, New Jersey, New York, Oklahoma and Oregon.

The PAMA demonstration has been widely considered successful and has been extended several times, but expansion has been slow.

This meant states not included in the initial demonstration had to piece together their own versions if they wanted to offer CCBHC services. The result is sometimes confusing, as there is a collection of different types of CCBHC models operating under several different types of rules and regulations.   

10 new states just added to CCBHC demonstration.

In 2022, the Bipartisan Safer Communities Act expanded the PAMA demonstration, but the expansion took a phased-in approach over many years. Only 10 states are added to the Medicaid Demonstration program every two years, and each expansion requires detailed compliance measures to be met before the states can join.  

The latest round of states just joined the CCBHC Medicaid Demonstration Program this month. On June 6, 10 states were admitted to the program after successfully developing all the required infrastructure and working with providers to implement programs fully compliant with CCBHC standards.

The 10 new states are Alabama, Illinois, Indiana, Iowa, Kansas, Maine, New Hampshire, New Mexico, Rhode Island and Vermont. 

The new CAA change in the Medicaid statute is important because it will allow states to choose the CCBHC model immediately, if desired, without waiting for their chance to join the PAMA demonstration.

Decisions ahead under Medicaid statute change.

No guidance has been issued as I write this, but the Centers for Medicare and Medicaid Services (CMS) is expected to issue CCBHC model guidance at any time, and I will report on it as it is made available.

In the meantime, the CAA change in the Medicare statute has left many CCBHCs with questions. Should they remain in the PAMA demonstration? How will this change impact any plans to pursue acceptance in the next round? Should they pursue the new Medicaid State Plan option?

SimiTree’s CCBHC experts can help CCBHCs with these and other important questions.
We help CCBHCs meet all certification criteria and provide guidance in data collection, calculation, quality reporting, and more.

Reach out to us today to learn how we can help your organization comply with SAMHSA’s new CCBHC certification criteria, leverage quality data to improve care, streamline workflow, and drive optimal performance.

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J’non Griffin serves as Senior Vice President for the Compliance as well as Coding divisions at SimiTree. With a healthcare career that spans three decades, she has a track record of helping many provider types implement effective compliance programs. She has worked with organizations nationwide  to develop compliant emergency preparedness and operation plans, implement fully compliant plans of care, and meet regulatory demands. As an AHIMA ambassador, Griffin was instrumental in preparing the coding community for the launch of ICD-10.