Certified Community Behavioral Health Clinics (CCBHC)
Areas of State Discretion in the CCBHC Criteria
September 19, 2016
DISCUSSION VERSION
- Staffing
Criterion 1.a.3 / If physicians are unavailable as medical directors, states may approve the CCBHC’s approach to fill these positions, to ensure compliance with state laws on the prescription and management of medications. / Nevada’s Behavioral Health Community Network (BHCN)definition for Medical Supervisor requires a provider to have two years of behavioral health experience and prescriptive authority. A Psychiatric APRN can serve in this role if able meet Nevada’s standards below:
All APRNs are independent and do not need supervision if they meet the criteria below per AB 170, from 2013.
/ 8/23/16
Criterion 1.b / States may specify which staff disciplines they will require to certify CCBHCs, to assure compliance with laws and regulations. / CCBHCs meet certification requirements set forth by HCQC and enrollment requirements of Medicaid, and must be within scope of licensure and practice.
If working towards licensure, same requirements apply for clinical supervisor (see state’s licensing board’s rules for supervisor—for interns). If no licensing board, see Medicaid Manual, Chapter 400.
If an unlicensed provider type, provider must meet appropriate Medicaid guidelines for services (Provide Type will be dependent on service itself and linking to crosswalk to provider qualification (see Services Grid crosswalk).
Staffing qualifications must meet all requirements for required services and primary care screening and monitoring.
At the very least, CCBHCs will have adequate staffing to meet minimum qualifications for all required services. / 8/23/16
Criterion 1.c.1 / Additional staff training may be required by states to ensure compliance with standards. / CCBHCs must document that staff has been trained, at a minimum, in:
- Cultural competency
- Managing high risk suicidal patients
- Working with families (NV PEP)
- EBPtraining
- Trauma informed care
- Trauma assessments
- Working with veterans
- Mandatory reporter training (child abuse and neglect).
- HIPAA training and clinical documentation
- Initiating legal holds
- Sexual harassment
Criterion 1.d.5 / State may determine that CCBHCs comply with federal and state confidentiality and privacy requirements. / CCBHCs must comply with HIPAA and 42 CFR requirements.
Information must flow between the DCO and CCBHC and be in compliance with these requirements.
CCBHCs must obtain written consentif collateral information from families and friends is required. / 8/23/16
- Needs Assessment- Based on the needs assessment, states may determine specific requirements in these areas
Criterion 1.a.1 / Cultural, linguistic, and treatment needs of the population to be served / No additional comments/decisions.
Note: CCBHCs may adjust EBPs, bilingual staffing, and support services based on populations served. / 8/23/16
Criterion 1.b.2 / Staffing plans including size and composition appropriate to the needs of the CCBHC consumers / CCBHC staffing plans must address minimum standards for required services and to ensure access and availability of appropriate staffing types and levels.
Peer support services must be adequate to be able to provide required services in a timely manner.
For all required services, must have adequate staffing to meet the intensity and needs of each individual. / 8/23/16
Criterion 4.e.8 / Other aspects of treatment planning based on the needs of populations served / State requires CCBHCs to include treatment planning that is person centered and components address all of the person’s needs. / 8/23/16
Criterion 4.f.2 / Evidence-based practices specific to the CCBHC site, including psychiatric rehabilitation services / CCBHCs must continually evaluate and implement EBPs needed for specific populations served. / 8/23/16
Criterion 2.e.2 / The geographic boundaries of the service area (catchment area in 2.e.2) / The CCBHC catchment area will align with the FQHC catchment areas.
Note: State level reporting will collect and report back to CCBHC on members outside of the catchment area. CCBHCs must plan to recruit/contract with other providers as needed to build network of care. Must coordinate care outside of the CCBHC catchment area. / 8/23/16
- Availability and Access
Criterion 2.a.5 / State laws and Medicaid regulations set standards for mobile in-home services, telehealth/telemedicine, and on-line treatment. / No comments/decisions. / 8/23/16
Criterion 2.a.7 / State standards may address provision of voluntary and court-ordered services. / Provision of services, regardless of whether voluntary and court-ordered, must meet criteria for clinical appropriateness and medical necessity. CCBHCs must comply with the courts for BH services. / 8/23/16
Criterion 2.b.1 / State standards for evaluation content and time-frames may be more stringent. / CCBHCs must comply with the current program monitoring components (e.g., onsite record reviews) required under SAPTA. / 8/29/16
Criterion 2.e.2 / States may have protocols to address consumers seeking services from outside the service (catchment) area, including:
- Using the needs assessment to determine the service area, and
- Coordinating protocols across CCBHCs.
CCBHCs must establish protocols for out of state consumers where services must coordinated in person’s own community.
CCBHCs must have written policies about transitioning patients between levels of care and across CCBHCs. / 8/29/16
- Care Coordination
Criterion 3.b.4 / States may apply their own privacy laws to communications between CCBHCs and DCOs about patients. / CCBHCs must comply also with state privacy laws including requirements specific to the care of minors.
Contracts between a CCBHC and a DCO must address consent forms, compliance with HIPAA, 42 CFR Part and other state and federal laws, including patient privacy requirements specific to the care of minors. / 8/29/16
Criterion 3.c.1 / If CCBHCs are unable to establish care coordination agreements with community agencies, states may decide whether to allow contingency plans. / Agreement definition: an arrangement between a CCBHC and DCO as evidenced by a contract, MOU, LOI or letter of support (LOS)/agreement. The inability of a clinic to secure any of these documents will result in failure to meet certification requirements.
Example: If at the end of March 2017 there is no formalcontract/agreement, a letter of support (LOS)could be the contingency plan. The LOS must outline what will be provided to the best of provider’s ability based on staff and resources, and how the services would be provided. At a minimum, primary care is still required to coordinate care with other care providers. A LOS must state that the provider will be in compliance with the care coordination requirements of their respective programs (FQHC and CCBHC).
LOS will be part of CQI plan and must be renewed annually to ensure compliance. In addition, LOS will be subject to program monitoring.
All LOS must be reviewed and approved by HCQC for compliance with certification requirements. / 8/29/16
- Scope of Services – Note: States may need CMS approval to amend state plans in some of these areas.
Criterion 4.a.1 / States and clinics may decide which of five required services will be provided directly by CCBHCs or by DCOs. / The Needs Assessment and Policy workgroup recommended that Medication Assisted Treatment (MAT) would be a required specialty service to be provided by either a CCBHC or a DCO. / 6/1/16
Criterion 4.d.4 / States may decide what level of licensed BH professional will conduct consumer evaluations. / DPBH and DHCFP completed qualification levels for required and allowable services. / 7/18/16
Criterion 4.d.5 / States will consider 12 factors in the criterion but will specify the requirements for consumer evaluations. / #1, 2 and 3 and 4. 6, 7, 9, 10 in ASI (Addiction Severity Index)
#5 apply the WHO Disability Assessment Scale 2.0
#11 applyWHODAS 2.0
#12 in ASI and ASAM / 8/23/16
Criteria 4.d.6
and 4.g.1 / States may require other specific screening and monitoring of behavioral health and primary care by CCBHCs. / Finalized by Needs Assessment and Policy Workgroup. / 9/9/16
Criterion 4.e.8 / States may set standards for other aspects of treatment planning based on the needs of the populations. / CCBHCs must include care coordination, prevention, and community inclusion and support. / 9/9/16
Criterion 4.f.2 / States must set the minimum evidence-based practices to be used by CCBHCs. / Finalized by Needs Assessment and Policy Workgroup. / 8/23/16
Criterion 4.i.1 / States should specify which evidence-based services and other psychiatric rehabilitation services are required based on the needs of the population served. / Finalized by Needs Assessment and Policy Workgroup. / 8/23/16
Criterion 4.h.1
Definitions / States should specify the scope of additional targeted case management services and the populations for which they are intended. / The Needs Assessment and Policy Workgroup definedthe scope of targeted care management services. / 8/23/16
Criterion 4.j.1 / States should specify the scope of peer and family services based on the needs of the population served. / No comments/decisions. / 9/9/16
- Crisis Response
Criterion 4.c.1 / States determine if there is an existing state-sanctioned, certified, or licensed system or network for the provision of crisis behavioral health services.
- The state defines and ensures inclusion of these crisis services:
- 24 hour mobile crisis teams
- Emergency crisis intervention services
- Crisis stabilization services
- Suicide crisis response
- Services capable of addressing crises related to substance abuse and intoxication, including ambulatory and medical detoxification
The Bureau of Health Care Compliance and Quality developed the following approach for state-sanctioned crisis services:
In Nevada, there are no state-sanctioned crisis intervention services that provide all of the elements required of a CCBHC and also none that provide services to all of the different population designations served by a CCBHC.
However, a CCBHC may contract with any service(s) that is(are) currently providing crisis intervention to assist the CCBHC in developing services that will provide all the following elements:
- 24 hour services, delivered within 3 hours from initial contact to the CCBHC (including mobile crisis teams)
- Both behavioral health (including suicide intervention) and substance abuse (including detoxification services)
- Service provision to all of the population designations (including, children, adults and members of the military/veterans)
8/16/16
- Quality Measures
Criterion 5.b.2 / States review and approve the continuous quality improvement (CQI) plan of each CCBHC. Elements of the CQI are determined by the state but should include:
- Suicide deaths or attempts
- 30-day readmissions
- Other events to be examined and remediated as part of the CQI plan
- Organizational Authority and Governance
Criteria 6.b.1, 6.b.2, 6.b.3, and 6.b.4 / States must approve any alternate approach (to 51% participation by consumers, people in recovery, and family members) that a CCBHC proposes to use, to ensure meaningful participation by consumers, persons in recovery, and family members.
- The state determines if proposed alternatives to the board membership participation by these groups is acceptable.
- If the alternative is not acceptable, the state must require that additional or different mechanisms be established to assure that the board is responsive to the needs of CCBHC consumers and families.
Sources: May 4, 2016 webinar and PowerPoint presentation by Captain David Morrissette, Ph.D.; the Criteria for the Demonstration Program to Improve Community Mental Health Centers and to Establish Certified Community Behavioral Health Clinics @
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