CCBHC Certification: The Nine Services and the 2023 Criteria

Certified community behavioral health clinics (CCBHCs) were created by Section 223 of the Protecting Access to Medicare Act of 2014. SAMHSA describes the model's promise simply: CCBHCs "are required to serve anyone who requests care for mental health or substance use, regardless of their ability to pay, place of residence, or age," must offer crisis services 24 hours a day, seven days a week, and must coordinate care so people do not have to assemble it themselves across several providers.

The rules that make that promise concrete are the CCBHC Certification Criteria. SAMHSA released an updated version in March 2023, and most CCBHCs had to comply by July 1, 2024. Clinics are certified against those criteria by their state, not by SAMHSA. For how states take part, see the CCBHC demonstration and how states certify clinics.

What are the nine required services?

SAMHSA lists the services a CCBHC must provide, directly or through a formal partnership:

1. Crisis services
2. Outpatient mental health and substance use services
3. Person- and family-centered treatment planning
4. Community-based mental health care for veterans
5. Peer, family support and counselor services
6. Targeted case management
7. Outpatient primary care screening and monitoring
8. Psychiatric rehabilitation services
9. Screening, diagnosis and risk assessment

The partnership route has limits. A partner that delivers services on the clinic's behalf is a Designated Collaborating Organization (DCO) under a formal agreement, and the 2023 criteria require the CCBHC to deliver directly "the majority (51% or more) of encounters across the required services (excluding Crisis Services) rather than through DCOs" (criterion 4.a.1). The clinic stays responsible for making sure people get all nine services.

How are the 2023 criteria organized?

SAMHSA groups them into six program areas:

• Staffing: a staffing plan driven by a community needs assessment, plus licensing and training.
• Availability and accessibility of services: timely access, outreach, 24/7 crisis access, treatment planning, and accepting everyone regardless of ability to pay or residence.
• Care coordination: agreements with partners such as federally qualified health centers and inpatient and acute care providers, health information technology and care transitions.
• Scope of services: the nine services, delivered in a person-centered, family-centered and recovery-oriented way.
• Quality and other reporting: required quality measures and a quality improvement plan.
• Organizational authority, governance and accreditation: representation of the people served in governance, and the licensing, certification or accreditation the state requires.

Which requirements are hardest for an existing clinic to meet?

The community needs assessment and staffing plan

Before certification and recertification, the clinic completes and documents a community needs assessment and a staffing plan responsive to it, updated at least every three years; states may add their own requirements (criterion 1.a.1). Staff must include licensed substance use counselors, though SAMHSA's FAQ says not every counselor providing SUD services must be one, and a medically trained prescriber who can manage medications for opioid, alcohol and tobacco use disorders, employed or under formal arrangement (1.b.2). The medical director must be on site at least some of the time.

Access timelines

Urgent needs get clinical services, including an initial evaluation, within one business day of the request; routine needs within 10 business days. The comprehensive evaluation is due within 60 calendar days of the first request for services (criteria 2.b.1 to 2.b.3). Existing clients seeking routine outpatient care must be offered an appointment within 10 business days.

Crisis response

Crisis services must be available around the clock (2.c.1), and the clinic's methods for crisis prevention, response and follow-up must be in its policies and made public (2.c.2). Mobile crisis teams are expected to arrive in person within one hour, two hours in rural and frontier settings, with response not to exceed three hours. SAMHSA's FAQ adds that a telehealth response within three hours does not meet the criterion. All three crisis services (emergency crisis intervention, 24-hour mobile crisis teams, and crisis receiving and stabilization) must be part of the CCBHC, directly or through a state-sanctioned DCO. The Medicaid side of mobile crisis is in the Medicaid mobile crisis option.

No refusal for inability to pay or residence

The clinic publishes a sliding fee discount schedule covering all CCBHC services, posts it on its website and in the waiting room, and has written policies for eligibility that are applied equally to everyone (2.d.2 and 2.d.4). No one is denied services because of where they live (2.e.1).

Governance

Governance must reflect the people served. Under one option, at least 51 percent of the governing board are people with lived experience of mental or substance use disorders and their families; under the other, the clinic sets up another meaningful mechanism, such as an advisory committee whose recommendations enter the formal board record (6.b.1).

Licensing, Medicaid and accreditation

The clinic must be enrolled as a Medicaid provider and be a licensed, certified or accredited provider of both mental health and substance use disorder services, including services for children, youth and families, and must follow any state accreditation, certification or licensing requirement (6.c.1). That makes the state facility license and Medicaid enrollment prerequisites, not afterthoughts; see Medicaid enrollment for behavioral health facilities.

Do SAMHSA's FAQs change the service rules?

SAMHSA's criteria FAQs settle several points clinics ask about. SUD treatment is to be provided as described in ASAM Levels 1 and 2.1 and include treatment of tobacco use disorders (4.f.1). Psychopharmacology is a required part of outpatient services. Methadone is not part of the CCBHC's medication services "unless the CCBHC is also an Opioid Treatment Program." Primary care screening goes beyond a client's self-report and follows protocols set by the medical director, though a clinic may rely on a client's own primary care provider's screening if it keeps the record.

Who certifies, and for how long?

The state. Under criterion 6.c.2, a clinic must be certified by its state as a CCBHC or have submitted an attestation to SAMHSA under the CCBHC Expansion grant program, in which case it is designated only while it holds that federal funding. State-certified clinics are designated for a period the state sets, not longer than three years before recertification, and states may decertify. SAMHSA publishes a compliance checklist that states use when they apply for the demonstration and when they add clinics. No consultant can certify a CCBHC, and no one should promise that a state will.

Where does a gap assessment fit, and what do we do?

A gap assessment reads your clinic against the 2023 criteria and SAMHSA's compliance checklist, criterion by criterion, and reports what is missing: a needs assessment that is older than three years, a staffing plan without a tobacco treatment prescriber, crisis coverage that relies on telehealth, a sliding fee schedule that is not posted, governance without lived experience. Our CCBHC Readiness Gap Assessment is $2,495, flat. It is consulting only: we do not file the state application and we do not certify anything. Your state certifies; your leadership decides what to fix. If the gaps include the state license itself, our state license packages and the state licensing index are the place to start, and the clinicians a CCBHC must employ are licensed through our sister sites, such as White Glove Counseling and White Glove Social Work.