CCBHC: Promise and Challenges

After many years of advocacy by providers, in 2014 Certified Community Behavioral Health Centers (CCBHCs) came into existence via demonstration projects across eight states. The aim was to broaden access and improve quality for behavioral health services and to integrate those services into clients’ overall healthcare. The demonstration projects’ participants became eligible for prospective payment to ensure that they had the resources to meet the standards established by SAMHSA. Those standards included programmatic and service requirements. Initial certification criteria were published in 2015. Standards were revised by SAMHSA in March of this year.

Programmatically, participating organizations had to meet standards for staffing, access to care, coordination of care, service scope, quality and reporting processes, and governance. Under scope of services, the CCBHC was to provide nine services directly or arrange through MOUs and partnerships:

  • Crisis services
  • Screening, diagnosis, and assessment
  • Person- and family-centered treatment planning
  • Outpatient mental health and substance use services
  • Psychiatric rehabilitation
  • Primary care screening and monitoring
  • Targeted case management
  • Peer, family support and counselor services
  • Community-based mental health care for veterans

The implementation of CCBHCs has since been expanded through a series of funding mechanisms so that some continue to receive prospective payments (similar to the federally qualified health centers model), while others are funded through expansion grants or Medicaid waivers. The latter two do not receive prospective payments and the expansion grant funding is reduced in the second grant cycle; and the different types are administered through different entities, depending on the funding source.  As of 2022, The National Council for Mental Wellbeing reported that there were over 500 CCBHCs across 46 states, plus Washington, DC, Puerto Rico, and Guam.

CCBHCs: Impact & Challenges

The impact of the changes made by these CCBHCs on service delivery has been substantial. In the same National Council report, data presented indicates that CCBHCs see, on average, 23% more clients and have significantly expanded access to MAT, primary care, crisis services, and collaboration with criminal justice. Almost all have added staff and widened outreach capacity enabling services to be delivered in the community. The majority have made steps to address social determinants of health, by partnering to create better opportunities for housing, address food insecurity, and increased employment.

It is clear, then, that this model has proved itself and is likely to continue to be expanded as policy makers and the public continue to see mental health and substance use as healthcare priorities. But, progress and system change rarely come without challenges. In reviewing the programmatic standards, two aspects jump out to me as posing potential challenges for providers.

“Staffing requirements, including criteria that staff have diverse disciplinary backgrounds, have necessary State required license and accreditation, and are culturally and linguistically trained to serve the needs of the clinic’s patient population.” (PAMA Section 223)

The first, is staffing. This blog has addressed the many issues related to staffing across many months. Organizations are facing shortages in all behavioral health specialties and professions. As a CCBHC, an organization may be better positioned to attract professionals to work in an environment that is less constrained (because the positions are actually appropriately funded and sufficient to meet demand). Working for an organization that offers a broad range of services and can fulfill a vibrant mission may also be attractive to applicants.

At the same time, the CCBHC model will require excellent recruitment resources and the ability to properly deploy human resources across the organization. Effective and comprehensive on-boarding and on-going training are highlighted in the standards. HR departments will need comprehensive training plans, assignment and monitoring processes, and budgets to ensure compliance with the required evidence-based practices, linguistic and cultural competence, and tracking of staff licensure and credentials.

“Reporting encounter data, clinical outcomes data, quality data, and such other data” (PAMA Section 223)

The second area that I took notice of was quality improvement and reporting. In fact, this area, it seems to me, would touch on all the programmatic standards to achieve continuous quality improvement. The ability to capture the various types of data required can pose a challenge to any organization. There have been few required outcome measures, and measurement-based care is new to the behavioral health field in general.  As ContinuumCloud’s recent technology survey revealed, large segments of the behavioral health industry lag behind in EMR and data capabilities, and in adoption of technology in general. 

The standards in this area require data on demographics of consumers, staffing, access to care, utilization, types of services utilized (level of care), care coordination, costs, and outcomes. As this model continues to expand – to be the best practice at an organizational level – CCBHCs will need to develop or implement sophisticated data capabilities. Additionally, they will need to adopt standardized and validated measures to assess clients, plan treatment, and monitor progress against established benchmarks.

In short, the CCBHC model offers a set of standards for effective behavioral health care at the community level. Its standards are rigorous, and organizations will be challenged to meet them. The rewards, however, in terms of mission and outcomes for improved wellbeing for those who need care are powerful motivators to meet those challenges.

This is the first in a three-part blog series examining the CCBHC model, requirements, and cultural shifts that are leading to progress in service delivery and outcomes. View part 2, CCBHC: Do You Have the Information? and part 3, CCBHC and Culture: There and Back Again to learn more.

About the Author

Maggie Labarta

Maggie Labarta is Founder and Consultant at Impact Non-profit Consulting, having previously retired as CEO of Meridian Behavioral Healthcare. Labarta holds a Ph.D. in Clinical and Community Psychology and has extensive experience in both administration and clinical practice. She also has particular expertise in strategic planning, data and analytics as management tools, and organizational development. She provides consultative services for numerous community organizations.

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