SAMHSA 101: What you need to know

The additional revenue streams created by the new SAMHSA law sound great. However, becoming certified is challenging. About 15% of the Behavioral Health (BH) market will be eligible for these new revenue opportunities as a Certified Community Behavioral Health Clinic (CCBHC). Those who don't provide the required nine core services within their group have the option to become a Designated Collaborating Organization (DCO). A DCO renders specialized service(s) on behalf of a CCBHC.

To qualify as a CCBHC, the core services you must provide are:

  1. Crisis mental health services, including 24-hour mobile crisis teams, emergency crisis intervention, and crisis stabilization
  2. Screening, assessment, and diagnosis
  3. Patient-centered treatment planning
  4. Outpatient mental health and substance use disorder services
  5. Primary care screening and monitoring*
  6. Targeted case management*
  7. Psychiatric rehabilitation services*
  8. Peer support services and family support services*
  9. Services for members of the armed services and veterans*

CCBHCs in every state must provide these services regardless of whether they are independently covered under the Medicaid state plan. Services marked with an asterisk (*) above may be provided via a contracted DCO.

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CCBHC vs DCO – How does each entity work?

CCBHC

The CCBHC coordinates and maintains responsibility for the care and services rendered by any contracted DCO(s). A DCO is not under the direct supervision of the CCBHC, but is engaged in a formal contractual relationship. Each party should describe their mutual expectations and establish accountability for services provided, as well as the funding sought and utilized.

DCO

Payment for DCO services is included within the scope of the CCBHC prospective payment system per-visit rate. Because the CCBHC is paying the DCO to render services on its behalf, and the CCBHC bears financial responsibility for the services, the CCBHC/DCO relationship is necessarily contractual.

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Who can become a CCBHC?

For non-profit organizations or local government centers to meet the criteria, they must:

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Offer nine required services

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Maintain community linkages

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Meet minimum standards

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Utilize prospective payment

Of the nine mandatory services defined, four must be provided directly by the CCBHC.

  • Screening, assessment, and diagnosis
    Includes risk assessment
  • Person-centered treatment planning
    Includes risk assessment and crisis planning
  • Crisis mental health services
    Includes 24x7x365 mobile teams, crisis intervention, and crisis stabilization
  • Evidence-based outpatient mental health and addiction treatment
    Includes cognitive behavioral therapy "and other such therapies which are evidence-based"

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Interested in becoming a DCO?

A CCBHC can use a DCO to augment their service offerings. A CCBHC can use more than one DCO to deliver the five mandatory core services that the CCBHC does not need to provide directly, or to provide additional non-mandatory services. In all cases, however, the CCBHC retains clinical responsibility for the consumer and the quality of care/outcome(s). In addition, it is the CCBHC that will receive the Daily or Monthly Rate (i.e. get paid by CMS) so the CCBHC will be responsible for paying the DCO(s) through the contractual fee they mutually agreed to.

Ask yourself the following questions before choosing the DCO path:

  • Which organizations in your service area are best situated to become CCBHCs?
  • Are any of these organizations your current partners?
  • How will your organization identify and approach potential CCBHC partners?
  • What is the capacity of your organization to take on additional consumers?
  • What services does your organization offer that a potential CCBHC partner may not be able to provide?
  • What costs are associated with the CCBHC services that you would provide?
  • How will your organization exchange information electronically with a CCBHC?

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Understanding bundled rates

Daily bundled rate

To calculate the daily bundled rate, each clinic first determines their allowable costs and non-allowable costs, and then creates a Base Year cost. Once this is done and the clinic is certain all costs have been included, it must determine the annual number of visits it receives from consumers.

The advice provided by SAMHSA is that this number can include the three visit types:

  1. Number of daily visits for patients receiving CCBHC services provided directly from staff
  2. Number of daily visits for patients receiving CCBHC services directly from DCO (not included above)
  3. Number of additional anticipated daily visits for patients receiving CCBHC services

Monthly bundled rate

The monthly bundled rate is calculated very differently than the daily rate. Clinics must divide annual costs by 12 to determine an average monthly cost. Next, they must determine how many unique clients they serve each month. A client must have at least one visit per month to count. However, they may have many visits and still count as a single client. The clinic then divides the average monthly cost by the number of unique clients seen in a month to determine the monthly rate.

This rate is paid to the clinic for each unique consumer who has at least one visit in a month, but is only paid once per month regardless of how many visits the consumer has during the month.

The CCBHC monthly bundled rate has provisions for five specific consumer populations who have higher costs. They are:

Adults with serious mental illness (SMI)

Adults with significant substance abuse disorders (SUDs)

Adults with SMI and co-occurring substance abuse disorders (SMI/SUDs

Children or adolescents with serious emotional disturbance (SED)

Consumers with a recent history of frequent hospitalizations related to behavioral health conditions

Beyond services, learn the 5 major components to this industry change

1. Service Transition

Many groups are not large enough or diverse enough to provide the services required by S. 264. However, many groups will want to grow to become a CCBHC due to the enhanced CMS payments. To meet these four service requirements, organizations may need to expand their operations or acquire or merge with other organizations to augment their service offerings.

2. Care Coordination

Providers must ensure seamless transitions for patients across the full spectrum of health services, including acute, chronic, and BH needs. Effective care coordination allows physical and behavioral care to balance, thus providing the best outcomes. This is achieved through sharing of comprehensive healthcare information.

3. Staffing

Once the clinic has been certified, it must solicit the input of its consumers and family/caregivers to determine the staffing requirements to meet its needs. This feedback will be used to update the staffing assessment at least every three years that the clinic is certified. However, clinics will probably want to perform this analysis more often than every three years because changes will need to be factored into the Prospective Payment System (PPS) cost report. This ensures the PPS rates are sufficient to cover the cost of care provided.

4. Reporting

CCBHCs have a high level of reporting requirements within two specific areas; quality metrics and cost metrics. Clinics will need to generate cost information to support their PPS calculations in order for their revenue to cover their costs. Quality metrics will be required to justify the CCBHC certification, and are necessary for recertification every five years. They will also be necessary to qualify for the quality bonus payments from CMS.

5. Data Sharing

Information exchange will be critical to the success of any CCBHC. The services required for a CCBHC necessitate that providers share information among their peers in the clinic to ensure quality outcomes over the life of the consumer. If DCOs are used, the processes will also need to include sharing that information bi-directionally with one or more external entities. Current Health IT solutions do not excel at this level of information exchange, so clinics will need to start preparing early to ensure success.

Transition intelligently with the right expertise and tools

Having both BH and medical information in one record is not common, but it's possible. The comprehensive, integrated, and interoperable behavioral health EHR from NextGen Healthcare delivers this in a single platform. Enjoy a fully integrated EHR and PM with intuitive BH content and workflow tools.

The NextGen® BH solution can help your clinic improve care outcomes, streamline data sharing and access, reduce costs, and make reporting easier. With it, you'll have the foundation you need to become a CCBHC.

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