Association Executive Directors Community

Dear Association Executives:

Today, SAMHSA and CMS shared some important updates on the CCBHC program. I'm passing these along to you with some commentary on implications/considerations for associations. As discussed in our last monthly call, the National Council will convene a special meeting in early Sept to dive further into the planning grant opportunity and how to prepare. Stay tuned for a calendar invitation, and don't hesitate to let us know what questions you have in the meantime!  –Becca

• HHS will be allowing existing CCBHC demonstration states to add CCBHC sites and will be releasing more details about the process in the coming months. At this time they have no plans to change the rules that apply to satellite facilities. The agencies are now in an information collection phase and has asked state officials to reach out to them about concerns or considerations that might shape specific concrete guidance that will be forthcoming.
• The National Council has been advocating for this for a while now – it's a big win for the states that want to expand their demonstrations! This change offers the opportunity for the 10 demo states to add new clinics (including but not limited to CCBHC-E grantees) and receive the enhanced Medicaid match under the demo. We expect some states that have certified CCBHCs under SPAs may seek to move those clinics under the demo. Other demo states that do not have SPAs and have not continued certifying sites may still be on the fence about whether to take on the effort of re-activating state certification processes, and would likely need budget appropriations to support the state's Medicaid share attributable to adding new sites. Let us know if you'd like to strategize on this in your state.
• HHS will be releasing the CCBHC state planning grant Notice of Funding Opportunity in October 2022 with a planned 60-day application period and announcement of awards in March 2023. States will need to complete these planning grants in order to participate in the 2024 expansion of the Medicaid Demonstration authorized under the Bipartisan Safer Communities Act.
• This tracks with what the National Council had been anticipating and provides helpful timeframes for us to begin planning technical assistance and other resources for state associations, clinics, and state agency officials. By early October, we expect to publish the results of our latest CCBHC Impact Survey which we hope will provide helpful data to those of you working to persuade your states to adopt the model. Stay tuned for more information from us about preparing for the planning grant process.
• HHS is undertaking a process to update the Certification Criteria, CCBHC quality measures, and PPS guidance. This will include listening sessions and opportunities for public input. Additional details about the timing and process for these updates will be provided soon.  
• This was also expected. As mentioned in this week's association call, if you or your members have thoughts on modifications to the CCBHC criteria or payment, please let me know. We will stay in touch with you as these opportunities are announced so that we are fully aligned with the needs of the clinics and can provide effective feedback or deliver sample talking points/comments to you and your members. We do not yet have any clarity on specific audiences SAMHSA and CMS will be reaching out to, other than knowing that CMS plans to host (at a minimum) listening sessions with CCBHC and non-CCBHC state officials in September. The agencies are aware of the ripple effects of any criteria and payment changes at this stage and recognize that if any changes are made, states, demo sites and grantees would need time to come into compliance. Comments on this topic are welcome during the public input process.