If you’re in Behavioral Health (BH) you have probably reviewed the new laws from the Substance Abuse and Mental Health Services Administration (SAMHSA) surrounding care coordination in BH. This industry change is complex, so I’d like to make it a little easier for you to interpret what’s required of you, and what action you may need to take.
Legislation S. 264 requires CCBHCs to provide nine broad service areas. Of these nine, a CCBHC must provide four, and the remaining five may be provided by either the CCBHC or through tight contractual relationships with DCOs. The four required service categories that the CCBHC must provide are:
- Crisis services
- Screening, diagnosis, and risk assessment
- Person-centered, family-centered treatment planning
- Outpatient mental health and substance use services
- Outpatient primary care screening and monitoring
- Targeted case management
- Psychiatric rehab services
- Peer, family support, and counseling services
- Community-based mental health care for veterans
Many groups are not large enough or diverse enough to provide the services required by S. 264. However, the majority will want to grow sufficiently 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.
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.
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.
CCBHCs have a high level of reporting requirements due to two 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 necessary for recertification every five years. They will also be necessary to qualify for the quality bonus payments from CMS.
Information exchange will be critical to the success of any CCBHC. The services required for a CCBHC require that physical healthcare providers share information with their peers in BH within the clinic to ensure quality outcomes over the life of the consumer. If DCOs are used, the processes will need to include sharing that information bidirectionally with one or more external entities. Current Health IT (HIT) solutions do not excel at this level of information exchange, so clinics will need to start preparing early to meet this need.
The demonstration program has now come to an end. Organizations that intend to become a CCBHC or a DCO need to begin planning for the transition now to be successful when the program begins across the country. Going forward, these changes will fundamentally alter the methodology for delivering BH care and being reimbursed.
At NextGen Healthcare, we'll help ensure your success through this SAMHSA change, as well as in future healthcare reform challenges.