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Medicaid Explores Certified Community Behavioral Health Centers

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Certified Community Behavioral Health Centers (CCBHCs) are a relatively new model of providing mental health care through Medicaid. They are required to provide nine key services to people with mental illnesses and addiction regardless of people’s ability to pay. Centers must “directly provide (or contract with partner organizations to provide) nine types of services, with an emphasis on the provision of 24-hour crisis care, evidence-based practices, care coordination with local primary care and hospital partners, and integration with physical health care.”

There are three community mental health centers in Mississippi with funding from the Substance Abuse and Mental Health Services Administration (SAMHSA) to pilot the CCBHC model in Mississippi: Communicare (Oxford), Singing River Services (Gautier) and Southwest MS (McComb).

Last Friday, December 10, the Mississippi Division of Medicaid’s Medical Care Advisory Committee discussed Certified Community Behavioral Health Centers and heard presentations about them from Dr. Mallory Malkin of the Department of Mental Health and Dr. Jerri Avery with the Office of the Coordinator of Mental Health Accessibility. It was also mentioned that Wendy Bailey, executive director of the Mississippi Department of Mental Health and Bill Rosamond, Coordinator of Mental Health Accessibility, had requested additional funding for three more community mental health centers to become CCBHCs at recent legislative budget hearings (starts about 1:23:00).

Families as Allies has closely followed the national development of CCBHCs since 2018 and participated in annual training and Hill Day outreach about CCBHCs with the National Council on Behavioral Wellness.  We support the development of CCBHCs in Mississippi and applaud the Medical Care Advisory Committee for exploring this possibility. We also urge the committee to ensure that the steps it takes and that it suggests the state take in this exploration are inclusive and in keeping with national best practices. Specifically, we recommend:

1. Facilitate an inclusive needs assessment focused on the outcomes that matter to people receiving services. Planning for any new initiative should always include service recipients and their families from the beginning  They know better than anyone what they need, and their inclusion supports better outcomes and judicious use of funds. There was no mention of gathering input from service recipients and their families in Friday’s committee meting.

The Substance Abuse and Mental Health Services Administration (SAMHSA) states on its website, “States with CCBHCs should conduct a needs assessment to identify current conditions and desired services or outcomes” and “A needs assessment should be objective and include input from consumers, program staff, and other key community stakeholders.” Consumer and family-run organizations that could help the state gather needs assessment input include the National Alliance on Mental Illness, the Coalition for Citizens with Disabilities, the Association of Mississippi Peer Support Specialists, the Recovery Action Project, the Arc and Families as Allies.

It would be helpful for the needs assessment to include data from Mississippi’s current CCBHCs, an initial review of their fidelity to national best practices and how they are working with the Division of Medicaid to determine return on investment of this new approach.

2Support a competitive bidding process.  One likely reason the CCBHC program has been successful nationally is that interested entities are required to submit proposals detailing how they will meet the goals of the program and then are monitored for those outcomes. We believe forgoing this step will greatly jeopardize the likelihood of success of any CCBHC efforts in Mississippi.

3. Ensure that all interested and eligible organizations have the opportunity to apply for any funding that is made available for CCBHCs.
According to federal law these types of providers are eligible to become CCBHCs:

  • A nonprofit organization
  • Part of a local government behavioral health authority
  • An entity operated under authority of the IHS, an Indian tribe, or tribal organization pursuant to a contract, grant, cooperative agreement, or compact with the IHS pursuant to the Indian Self-Determination Act.
  • An entity that is an urban Indian organization pursuant to a grant or contract with the IHS under Title V of the Indian Health Care Improvement Act (PL 94-437).

This map shows the current CCBHCs in the United States and this is a list of those same organizations.

In addition to traditional community mental health centers, organizations across the United States currently funded as CCBHCs include (links are to specific examples within each category, but there are multiple examples of most categories on the map and list): federally qualified health centersAmerican Indian nations, traditional social service agenciesregional hospitalssubstance use treatment centers, disability organizationscriminal justice reform agenciesorganizations that serve childrenpublic health departments, non-profit mental health providersuniversities and medical schools.

4. Prioritize compliance with all national certification guidelines for CCBHCs without imposing additional requirements from the state.  Rigorous fidelity to certification guidelines, including the prioritization of licensed/licensed eligible staff and use of electronic health records, makes it easier to compare Mississippi’s work to other states and increases the likelihood of achieving similar positive outcomes.  The imposition of additional requirements, such as state certification standards that go beyond what CCBHCs require, could needlessly impede the fundamental goals of CCBHCs and prevent qualified providers from pursuing the opportunity.

5. Implement and oversee any state CCBHC pilots through the Division of Medicaid. The Division of Medicaid’s oversight of any CCBHCs would facilitate data collection on outcomes and the efficacy of the payment model.  Any eligible applicant for a CCBHC would already be under Medicaid’s purview, but would not necessarily be under the purview of the Department of Mental Health. DMH does not have any oversight over mental health services delivered outside of the community mental health center system. Mental health services outside of DMH’s scope include those delivered by federally qualified health centers, the University of Mississippi Medical Center, other universities, public health clinics and private providers.

6Establish mechanisms for the Medical Care Advisory committee to limit conflicts of interest.  If it has not done so already, we encourage the committee to establish protocols for situations in which a member could have a real or perceived conflict of interest due to their organizational affiliation.

It should also be noted that the Medical Care Advisory committee is federally mandated to include “members of consumers’ groups, including Medicaid beneficiaries, and consumer organizations.” The committee does not currently appear to include beneficiaries or the organizations that represent them. Including these perspectives as federally mandated would also help serve as a safeguard against conflicts of interest.

[photo by Ken Lund from Las Vegas, Nevada, USA – Jackson, Mississippi 40 (1)Uploaded by xnatedawgx, CC BY-SA 2.0]

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