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Certified Community Behavioral Health Clinics (CCBHCs) are required to provide services to anyone seeking help for a mental health or substance use condition, regardless of their diagnosis, place of residence, age or ability to pay. These requirements are described in detail in SAMHSA’s federal CCBHC certification criteria.
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The CCBHC federal Medicaid rate does not pay for:
- Those enrolled in Minnesota Care
- Incarcerated individuals
- Undocumented individuals
- Commercial primary/Medical Assistance (MA) secondary
- Medicare primary/MA secondary
- Uninsured
- Underinsured (commercial insurance)
The uncompensated costs of providing services to individuals who are not enrolled in Medicaid (uncompensated care) are absorbed by the CCBHC as “bad debt.” Per federal Medicaid rate regulations, bad debt expense is not an allowable expense for the CCBHC federal Medicaid rate. This is a known gap in the CCBHC model. The federal certification criteria require CCBHCs to provide services to all, regardless of ability to pay. At the same time, the CCBHC prospective payment system (PPS) rate must not include costs for uncompensated care based on The Centers for Medicare & Medicaid Services (CMS)’ PPS Guidance (Section 5.1b)1 and the Code of Federal Regulations (CFR) requirements.
Unlike Federally Qualified Health Centers (FQHC), CCBHCs do not receive federal grant dollars to defray the cost of services provided to uninsured and underinsured individuals. CCBHCs do not have levy authority to recoup the costs of uncompensated care. As a result, CCBHCs have very few options, with the strongest being to leverage state and locally appropriated funding to cover the costs of this unfunded mandate. All state and locally appropriated funding received by CCBHCs is subject to reporting requirements on the CCBHC cost report which determines the PPS rate, to ensure non-duplication of payment to CCBHC providers.
CMS requires states to develop federal Medicaid rates using actuarially sound principles with respect to the data, assumptions and calculation methodology used. States must ensure non-duplication of payment to CCBHC providers. Minnesota contracts with an independent third-party accounting firm to review and validate CCBHC cost reports to ensure compliance with all state and federal requirements outlined above.
If you have questions pertaining to this guidance, please reach out to the CCBHC general mailbox at mn_dhs_ccbhc@state.mn.us. If you have questions about how adult mental health initiatives (AMHI) funds can be used to help cover the costs of uncompensated care, please reach out to the AMHI general mailbox at mn_dhs_amhi.dhs@state.mn.us.
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