June 15, 2022

Recent national and state advocacy efforts to ensure Congress does more to address the mental health needs of Americans in the face of numerous public health epidemics including gun violence, may shortly bear fruit.  Rumor has it the federal gun reform package we’ve been reading about may move as early as next week, carrying with it language that advances one of the National Council’s primary objectives –  to expand the availability of CCBHC services across the country.

While it is difficult to reconcile the fact that Congress may finally advance the CCBHC model as part of its’ gun reform package, it does appear to be the vehicle by which some important mental health advances may occur.

A note of caution:  It’s still not clear what the actual language is and it is still possible the gun reform package could fall apart. For one thing, the cost of the package that includes all kinds of important MH reforms, is significant.  As such we expect there will be pushback from the right regarding the price tag of the legislation, while the progressive left has also weighed in, bemoaning the fact that certain specific gun reform proposals are left out of the package.

I recently shared an email (Monday afternoon) that included 3 attachments from the National Council’s Association Execs meeting.  There is a Power Point discussing the status of the CCBHC model across the country, what’s happening in various states in terms of integrating CCBHC services into state Medicaid programs, etc.   There is also a note of caution in the slide deck reminding us that some State Medicaid Directors are choosing to flip on the switch for Medicaid CCBHC services but they are not paying the PPS rate for the services.

Here in New York, our priority continued to be the expansion of CCBHC ‘Demo” designations to all eligible organizations, with an accompanying requirement that all CCBHC demo services receive the PPS rate.  At the present time, there are several obstacles to our achieving this goal, including the fact that CMS has told the National Council it does not have the authority (in the federal statute that implements the Demo) to allow a Demo state to add more providers to its’ list of Demo agencies.  Apparently the National Council has asserted that nothing in the statute precludes this.  Unfortunately, Congress does not like to go back into federal statute that has already been enacted to fix something or to make a clarification.  In my experience getting Congress to rescind or amend statute is very difficult to achieve.  These are just a few of the issues we face as we work to bring all eligible Outpatient Clinic provider organizations into the CCBHC Demo world, including but not limited to those that received a SAMHSA CCBHC Expansion grant in the past.

I am told we could see a first draft of the gun reform legislation later this week.  We may even seen something on Telehealth in the gun reform package.  Stay tuned.