States with Section 223 planning grants are expected to certify clinics, apply for the demonstration program, and monitor clinic compliance.
There is no required format that a state must use for its certified community behavioral health clinic (CCBHC) certification process. If a state has an existing certification process, it can use it as long as the state can validate that all the criteria were reviewed and met. The State Certification Guide is a tool to assist states in assessing prospective CCBHCs. To learn more about states' options for certifying clinics, access State Discretion in the CCBHC Criteria – 2016 (PDF | 242 KB).
States are permitted to certify every clinic statewide, as long as the clinics meet the criteria. SAMHSA and its federal partners at the Centers for Medicare and Medicaid Services (CMS) and Office of the Assistant Secretary for Planning and Evaluation (ASPE) at the Department of Health and Human Services (HHS) are willing to work with any state that would like to do this. Technical assistance will be primarily provided through ASPE to determine comparison sites.
Monitoring Clinic Compliance
It is the states’ responsibility to track and monitor a CCBHC’s compliance with the criteria and develop a process to ensure the criteria are met. The expectation is that the states will work closely with clinics to identify challenge areas and assist with process improvement in order to fully meet the criteria.
While it is expected that all certified clinics will meet the requirements listed in the criteria, it is acknowledged that not all clinics will meet 100% of the criteria at the time their applications are submitted. States will be able to provide justification and a remediation plan in their applications to meet all of the criteria by the time the state launches the program in 2017.
States will be able to provide justification in their application to the demonstration program for not meeting certain criteria for their CCBHCs.
Staffing Plans and Workforce Shortages
The states have flexibility in determining the staff providing services. Decisions should be based on the needs of the consumers and best clinical practice.
The CCBHC must develop a staffing plan that meets the requirements of the state behavioral health authority and any required state accreditations standards. The staffing plan is also informed by the needs assessment and includes clinical and peer staff. The criteria recognize that there are professional shortages in the behavioral health workforce. Therefore, some services many be provided by contract, part-time, or by providers shared between clinics. Learn more about care coordination for CCBHCs.
In addition, CCBHCs may use telehealth/telemedicine and online services to alleviate shortages. Learn more about using telehealth and telemedicine at CCBHCs.
If a CCBHC is unable to develop a staffing pattern to provide needed services during hours that have been determined in the needs assessment and/or offer evidenced-based practices based on the results of the needs assessment, the CCBHC would not meet the criteria in these areas. Under these circumstances, it will be up to the state to determine when or if the CCBHC meets the expected level of certification.