June 4, 2023

Attached, please find our formal comments submitted in response to a CMS CCBHC PPS Technical Guidance document released last month.    Comments were due on Friday, June 2.  Here’s a link to the CCBHC Guidance Document that is the subject of this comment period:https://www.medicaid.gov/medicaid/financial-management/downloads/ccbh-pps-prop-updates.pdf

Please note:  The Technical Guidance is short on detail in several important areas.  It is our understanding there will be future opportunities to provide comments once CMS provides additional information based on the questions it receives during this comment  period.  Having said this, we did take this opportunity to comment on several issues that (in our opinion) require changes including the CCBHC re-basing interval, the CCBHC Quality Bonus Program, and the ability to include costs for IT and other critical costs in the PPS rate calculation methodology.