Differences Between Community Mental Health Centers and Certified Community Behavioral Health Clinics

During the 2021 Session, the Legislature passed Senate Sub. for HB 2208 which, among other things, requires the Kansas Department for Aging and Disability Services (KDADS) to establish a certification process for certified community behavioral health clinics (CCBHCs), a Medicaid provider type.

Currently, KDADS anticipates that all of the state’s 26 community mental health centers (CMHCs) will transition to become CCBHCs. The current projection is that CMHCs will begin certification during FY 2022, and by FY 2025 all 26 CMHCs will have transitioned.

Services Provided by Community Mental Health Centers and Reimbursement Mechanism

CMHCs are mental health facilities that provide community-based public mental health services, and largely serve as the main entry points for the mental health system. CMHCs provide outpatient services to adults and children but also provide behavioral health screening for patients.

Currently, a CMHC bills and will receive reimbursement for each different service it provides. That reimbursement rate covers the cost for the provider to provide that service and does not cover any administrative costs the CMHC might have.

KDADS has indicated that this reimbursement model can place a CMHC in a situation where it might not be able to provide more intensive services. Due to reimbursement the CMHC might receive for certain services, and how frequently the services are utilized, this could reduce the services offered in certain areas, such as the western part of the state.

Services Provided by Certified Community Behavioral Health Clinics and Per Person Per Month Payment

CCBHCs are a relatively new Medicaid provider type that requires a clinic to meet certain requirements in order to earn certification. Generally, a CCBHC is required to provide a certain set of core services. These include, but are not limited to:

• Person-centered treatment planning;
• Crisis services;
• Outpatient mental health and substance use services; and
• Screening, assessment, diagnosis and risk assessment.

Currently, there are no CCBHCs operating in the state.

A CCBHC is funded through a per-person per-month model, where the facility receives a set amount each month based on the actual costs of providing care for patients. Different from the service reimbursement model CMHCs use, per-person per-month amounts factor in facilities’ administrative costs based on reported costs to the state.

Phased Plan for CCBHC Implementation

During the 2021 Legislative Session, KDADS indicated it would implement a phased approach to transitioning CMHCs to CCBHCs. Its plan would begin in FY 2022 and continue through FY 2025. KDADS provided an estimate for the Medicaid expenditures for services offered by CCBHCs. Below is a chart demonstrating the phased approach to certification.

In 2021 SB 159, the Legislature added approximately $2.7 million, including $1.2 million from the State General Fund (SGF), for CCBHC funding for FY 2022. This funding would provide $1.6 million, including $627,342 SGF, for the low-end service estimate in FY 2022.

The additional $1.1 million, including $556,710 SGF, would provide additional operating funding for the agency itself to allow for 10.0 FTE positions and other contractual services associated with CCBHC certification and ongoing compliance duties the agency anticipates.

KDADS and the Kansas Department of Health and Environment (KDHE) are working with CMHCs and consultants to move the CCBHC implementation schedule forward. KDHE will need to establish a prospective payment system that will require an approval request to the federal Centers for Medicare and Medicaid Services. KDADS and KDHE have indicated they have begun the state plan amendment necessary for CCBHC certification and anticipate submitting it to the federal Centers for Medicare and Medicaid Services by January 2022.