Comments on payment guidance for Certified Community Behavioral Health Clinics

Health clinic waiting room with diverse patients

Certified Community Behavioral Health Clinics (CCBHCs) aim to provide access to behavioral health care for people regardless of their ability to pay, place of residence, or age. Importantly, CCBHCs are required to provide a comprehensive set of behavioral health care services—including 24/7 crisis care—and care coordination between physical, mental, and social systems.

In an effort to continuously improve and ensure that payment policies are clear and adequate, the Centers for Medicare and Medicaid Services (CMS) sought public comment on proposed updates to CCBHC Prospective Payment System (PPS) Guidance. In June 2023, Richard Frank and Julia Paris submitted a comment letter addressing a number of issues, including optional uses of special crisis service rates, optional discontinuation of the special population payment, and quality bonus payment metrics.

Read the full comment letter here.

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