CCBHC Funding Frequently Asked Questions

These are two separate activities with different funding sources:

• The SAMHSA Funding Announcement is a one-time federal grant for federal fiscal years 2019 and 2020. This is not Medicaid funding. These grants will flow directly from SAMHSA to the grantees.
• The 1115 waiver request is for continuation of current Medicaid PPS payments for the existing 6 CCBHCs. Federal Medicaid payments under the current Section 223 demo are currently authorized through June 30, 2019. The 1115 waiver would authorize continuation of Medicaid PPS payments for an additional 4 years, through June 30, 2023.

No, not under current law. The Minnesota Legislature would need to change state law and provide additional matching funds before additional CCBHCs could be included for Medicaid PPS payments.

Executive Summary
The purpose of this program is to increase access to and improve the quality of community behavioral health services through the expansion of CCBHCs.

Expectations
CCBHC Expansion is one of SAMHSA’s services grant programs. SAMHSA intends that its services programs result in the delivery of services as soon as possible after award. At the latest, award recipients are expected to provide services to the population(s) of focus by the fourth month after the grant has been awarded.

Collaboration with the state behavioral health authority and state Medicaid Office is expected.

Required Activities:
You must use SAMHSA’s services grant funds primarily to support direct services. This includes the following activities:

• The FOA has a detailed list of required CCBHC services and activities. In addition, see MN CCBHC Scope of Services table describing what is required vs optional for CCBHC certification. Note that the FOA (p. 8 – 9) requires certain additional services, such as ACT, which are currently not required.

Allowable Activities:

• Develop and implement tobacco cessation programs, activities, and/or strategies.
• Conduct an analysis of barriers and facilitators to facilitate changes in services and local relationships necessary to become fully certified.
• Vocational and educational counseling aimed at assisting individuals receiving treatment to be able to better integrate into their communities and live productive satisfying lives.
• Partnering with local housing authority to integrate behavioral health supports into community housing.

Data Collection and Performance Measurement:
No more than 15 percent of the total grant award for each budget period may be used for data collection, performance measurement, and performance assessment.

Infrastructure Development (maximum 20 percent of total grant award for the budget period)
Although services grant funds must be used primarily for direct services, SAMHSA recognizes that infrastructure changes may be needed to implement the services or improve their effectiveness. You may use no more than 20 percent of the total services grant award for each budget period for the following types of infrastructure development, if necessary, to support the direct service expansion of the grant project

• The FOA has a list of allowable infrastructure expenditures, including technical assistance, training, collaboration and information systems development.

Construction
Construction or major alteration and renovation are not authorized under this program.

Supplement Not Supplant
Grant funds may be used to supplement existing activities. Grant funds may not be used to supplant current funding of existing activities. “Supplant” is defined as replacing funding of a recipient’s existing program with funds from a federal grant.

The SAMHSA FOA includes the following statement on page 11:

Recipients must utilize third party and other revenue realized from provision of services to the extent possible and use SAMHSA grant funds only for services to individuals who are not covered by public or commercial health insurance programs, individuals for whom coverage has been formally determined to be unaffordable, or for services that are not sufficiently covered by an individual’s health insurance plan. Recipients are also expected to facilitate the health insurance application and enrollment process for eligible uninsured clients. Recipients should also consider other systems from which a potential service recipient may be eligible for services (for example, the Veterans Health Administration or senior services), if appropriate for and desired by that individual to meet his/her needs. In addition, recipients are required to implement policies and procedures that ensure other sources of funding are utilized first when available for that individual.

DHS comment: see also the following statement in the DHS MHCP Provider Manual regarding Medicaid and Medicare “payment in full” provisions:

A provider must accept MHCP (including MA) reimbursement as payment in full for covered services provided to a recipient. A provider may not request or accept payment from a recipient, a recipient's relatives, the local human services agency, or any other source, in addition to the amount allowed under MHCP, unless the request is for one of the following:

• Spenddown
• Copay
• Family deductible
• Insurance payment that was made directly to the recipient. MHCP is liable for the amount payable by MHCP minus the third-party liability amount.

Considering the above provisions, DHS recommends that applicants for the SAMHSA grant limit their funding request to:

• CCBHC services for uninsured individuals or CCBHC services for individuals who are not on Medicaid and their insurance does not cover certain CCBHC services. To the extent that these individuals may have some insurance, the grant funds should not be used for services which are within the limits of the individual's health care coverage.
• For Medicaid recipients to be served by new CCBHCs, CCBHC services which are not covered by Medicaid, such as care coordination (unless the applicant is a Behavioral Health Home)

Since the current 6 CCBHCs receive cost-based Medicaid payment for all currently required CCBHC services, receipt of grant funding by these CCBHCs for Medicaid recipients would be a duplication of payment.

No. If the grant is used for Medicaid recipients in that way, it would probably be in conflict with Medicaid “payment in full” provisions. The PPS wrap payment for the existing CCBHCs is based on provisions in the Section 223 demo that allow the wrap payment to supplement existing Medicaid and Medicare payments. This authority is limited to the 6 CCBHCs in the demo. The SAMHSA grant does not have similar authority.

Since new CCBHCs are not eligible for the Medicaid PPS, a cost report is not required prior to certification. Instead, the FOA has a grant budget which focuses on use of proposed use of grant funds. Matching funds are not required for the grant. Grantees will be required to file expenditure reports detailing how the grant was used. It is not clear whether that will take the place of the cost report which is required by CCBHC criterion 5.a.5 after the first year.

Based on new information from SAMSHA’s June 14 webinar, Minnesota DHS has 2 roles:

• Collaboration with grant applicants regarding:
  • Continued state certification of existing CCBHCs pursuant to federal criteria and state law (M.S. 245.735)
  • Technical assistance regarding certification of new CCBHCs pursuant to a federal process which will be announced after grant awards are made
  • Provision of crisis services through a state-sanctioned crisis network
  • Sustainability planning after the grant ends.

• Review and comment regarding each applicant’s Public Health System Impact Statement (PHSIS)

DHS issued an e-memo to potential applicants on June 1, 2018 indicating that, as part of its review and comment role, it will prioritize applicants:

• who are an existing CCBHC to focus on more impact in tribal areas and other underserved communities within the currently defined CCBHC service area
• who are a behavioral health provider interested in becoming a CCBHC who are ready to meet the certification criteria and serve a geographic region not currently served by a CCBHC.

Applicants are required to submit their PHSIS to DHS by July 9, 2018, i.e. by the same deadline that applies to grant submission to SAMHSA. DHS review of the PHSIS is due to SAMHSA within 60 days after the grant submission deadline. The PHSIS should be e-mailed to:

• Maisha Giles, Behavioral Health Director - maisha.giles@state.mn.us

For more information regarding the existing CCBHC certification process, please contact jane.king@state.mn.us