NYS Council CCBHC Advocacy

December 21, 2022

Last week, the NYS Council sent all members the CCBHC-D financial analysis we commissioned from Health Management Associates (HMA) actuaries and consultants (attached in case you missed it). The NYS Council has been advocating for vast expansion of the federal CCBHC demo across NYS since early September when CMS indicated it would permit Demo states to expand the numbers of federal demonstration clinics in their state. Our efforts (to date) include but are not limited to:

  • Meetings with state decision makers from across the executive agencies and key legislative leaders to educate and persuade lawmakers to support our request to open up the federal demo to any eligible provider
  • We regularly share published information and data regarding the penetration and outcomes associated with the CCBHC Demo Program with state leaders
  • The NYS Council submitted proposed language to the executive (for inclusion in the upcoming executive budget proposal) that would require NYS to open up the Demo Program to any eligible provider
  • Commissioned a financial analysis performed by HMA actuaries and consultants that describes the minimal costs and significant savings associated with vast expansion of the demo program in NY
  • Later today we will initiate a sign on effort that gathers support from colleague associations, calling for vast expansion of the CCBHC federal demo model here in New York

The following note went to executive agency (Executive, DoH, OASAS, OMH, DOB) leads this morning. It includes an article from OpenMinds as well as the National Council’s 2022 CCBHC Impact Report.

If you want to circulate the Financial Analysis we first shared with everyone last week, please use the version (attached) that makes a minor clarification to a sentence in the Executive Summary. If you have already shared the earlier version, that’s fine – the clarification does not change the financial analysis in any way.


Good morning,
As a follow-up to the CCBHC Demo Financial Analysis we sent you last Friday, we wanted to provide more information regarding the CCBHC Program and its’ growth across the country.

Please see the attached document, and the brief article (below) from OpenMinds.

I remain available to respond to any questions or concerns you may have regarding the Financial Analysis prepared by actuaries at Health Management Associates. Please feel free to contact me at 518 461-8200 at your convenience if I can be of assistance.

Have a good day.

The CCBHC Footprint

December 20, 2022 | Monica E. Oss

Adoption of the Certified Community Behavioral Health Clinic (CCBHC) model has grown rapidly. Fueled by many factors, including the pandemic and an increasing demand for mental health services, total federal investment in CCBHCs from 2018 to 2022 now tops $1.8 billion.

There are now more than 500 CCBHC service locations managed by 350 specialty provider organizations providing CCHBC services—most of them traditional community mental health centers (for more, see our recent report, A Certified Community Behavioral Health Clinics Market Update: A 2022 OPEN MINDS Market Intelligence Report). The services include crisis services, treatment planning, screening and diagnosis, risk assessment, outpatient mental health, substance use services, targeted case management, outpatient primary care screening and monitoring, community-based mental health care, family support services, and psychiatric rehabilitation services. Most of the reimbursement for CCBHC services occurs via a daily or monthly prospective payment rate per consumer. In 24 states, Medicaid health plans are required to pay for the CCBHC services.

My colleague, Sharon Hicks, pointed out that the CCBHC model is designed to assure access to integrated care along with the more traditional community mental health center service offerings, including physical health, a 24-hour crisis system, and services related to social determinants of health. “This model reengineers the traditional service delivery system by providing seamless access to a variety of services through one front door. It softens or removes barriers to entry,” she said. “All services are based on an integrated, whole person care approach aimed at assuring service recipients that the focus of the treatment is on them as people rather than on symptoms they are experiencing. In addition, the PPS payment model also allows provider organizations to maintain mission critical services, such as outpatient clinics, which have unpredictable variability in utilization and revenue rates.”

Overall, the CCHBCs serve relatively few consumers—last year serving 2.1 million unique individuals. But like other federal service model initiatives, the CCBHC program is changing the behavioral health delivery system. My colleague, Ray Wolfe, thinks that the CCBHC program has supported changes that need to happen in the public mental health system, stating “It will prepare the organization’s financial infrastructure for risk-centric, value-based reimbursement. It facilitates adding more robust quality management functions and tools, and helps staff focus on managing HEDIS. It expands the case management role and clinical services to include physical health.”

Expanding on the positive impact of CCBHCs for community mental health centers, Mr. Wolfe also commented on the transitional financial impact of the program, “Organizations had better financial outcomes as a result of CCBHC reimbursement. Outpatient program losses, driven by poor rates and high staffing costs, were radically reduced by the grants and new cost-based billing. As a result, these organizations could increase salaries and retain staff. The value-based PPS payment also allowed the organizations to create new team approaches – clinicians working with dedicated case managers and primary care professionals were able to work collaboratively and share insights in treatment planning. These services, which previously had no billing codes, had suddenly become covered at no cost.

The CCBHC designation also required and paid for new and expanded quality teams – a function that previous reimbursement would not have supported, according to Mr. Wolfe. This prepares the organization for success with value-based reimbursement (VBR). He noted, “Business advantage in everything from opening new sites to creating specialty services for special groups is possible with CCBHC payments – and positions them better in many other contract negotiations.”

CCBHC status is facilitating the shift of the public mental health system to a service delivery model that is ready for the future. Mr. Wolfe concluded, “CCBHC status is important for the future of community mental health centers – from more substantial relationships with payers to expansion and scale. It provides the ingredients for future competitive advantage.”