On May 28, the U.S. Department of Health and Human Services (HHS), the Centers for Medicare and Medicaid Services (CMS), and the Substance Abuse and Mental Health Services Administration (SAMHSA) announced that 10 new states had been accepted into the Certified Community Behavioral Health Clinic (CCBHC) Medicaid Demonstration Program. With this announcement, the Trump Administration confirmed that the CCBHC model remains a key piece of the nation’s behavioral health system that is poised to continue to grow over the next few years.
CCBHC Program Basics
The CCBHC model dates back to 2014, when the U.S. Congress passed bipartisan legislation to authorize the model as a time-limited Medicaid demonstration program as one way to increase access to coordinated, comprehensive behavioral healthcare services. CCBHCs are healthcare clinics operated by nonprofits or government health authorities that must provide, directly or through partnerships, the following nine services:
· 24/7 Crisis Services
· Outpatient Mental Health and Substance Use Services
· Person- and Family-Centered Treatment Planning
· Community-Based Mental Health Care for Veterans
· Peer Family Support and Counselor Services
· Targeted Care Management
· Outpatient Primary Care Screening and Monitoring
· Psychiatric Rehabilitation Services
· Screening, Diagnosis and Risk Assessment
Like federally qualified health centers (FQHCs), CCBHCs are required to see patients regardless of their ability to pay and must meet federal certification requirements that establish a basic level of service for operation of a clinic.
As noted by HHS in their press release: “Since the program’s launch in 2017, when 66 CCBHCs began operating across eight states, the model has grown significantly. Today, more than 500 CCBHCs operate in 46 states, the District of Columbia and Puerto Rico.”
Three Different Reimbursement Opportunities
One interesting aspect of the CCBHC program is that it has grown into three distinct programs or reimbursement opportunities that account for the 500+ participants cited by HHS.
The first is the CCBHC demonstration program authorized by Congress and run by HHS, CMS, and SAMHSA. In this program (officially referred to as the Section 223 Medicaid Demonstration), states must apply to the federal government to join the demonstration and, after being admitted, then select and certify CCBHCs for participation. Participating clinics must receive and maintain certification from their states in order to receive cost-based reimbursement via a Medicaid prospective payment system (PPS) payment rate. Critically, this program is a demonstration model and thus is timelimited and not a permanent part of the Medicaid program.
The second is a SAMHSA expansion grant which is administered by SAMSHA and acts more like a traditional direct federal grant program. In this program, grants support a select number of CCBHCs directly with a fixed amount of funding. Existing CCBHCs can apply for these competitive grant funding opportunities and, upon selection and award, must demonstrate ongoing compliance with CCBHC requirements for the duration of the time-limited grant.
The third opportunity is an independent state Medicaid program. In this option, states use either a section 1115 Waiver, or a CMS-approved permanent State Plan Amendment, to implement a CCBHC program that offers participating clinics Medicaid reimbursement. Like the other options, participating clinics must work with their state to join the state’s CCBHC program and then work to maintain certification and status as a CCBHC.
2026 Program Expansion
This recent May 2026 announcement of the program expanding into 10 new states stems from a June 2022 gun safety law passed by the U.S. Congress. That law included several mental health provisions, including one that allowed HHS to expand the CCBHC demonstration program to ten additional states every two years for a four-year demonstration period. Prior to that law, funding for the demonstration program was set to expire in 2022 and 2023.
In 2024, HHS announced plans to extend the program to: Alabama, Illinois, Indiana, Iowa, Kansas, Maine, New Hampshire, New Mexico, Rhode Island, and Vermont. With this latest announcement, HHS is extending the CCBHC program to the following 10 states for the next four years: Alaska, Colorado, Hawaii, Louisiana, Maryland, Mississippi, Montana, North Dakota, Washington, and West Virginia.
Impact to BH Providers
As a result, nonprofit behavioral health providers (including FQHCs and tribal health organizations) in these ten selected states should review their state CCBHC programs and the federal certification criterion to determine their eligibility to participate. Additionally, behavioral health providers in every state should consult their state Medicaid program to inquire about the potential for the CCBHC program to become a permanent part of their state Medicaid program. At this point, the federal demonstration program has continued to grow across both Republican and Democratic presidential administrations over the course of the past decade, and it seems likely that more states will look to build on the demonstration model by adding CCBHC reimbursement as a permanent part of their Medicaid programs.
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