Certified Community Behavioral Health Clinics (CCBHCs) are facing stricter rules for helping clients who need emergency services, requiring greater coordination with community resources.
A new crisis management requirement under updated certification criteria for CCBHCs aims to stabilize crisis situations faster by making certain intervention services begin immediately at the clinic level.
Clinics will no longer be allowed to routinely divert responsibility to local law enforcement, send clients to an acute care emergency room, or wait to refer a person in a crisis situation to outpatient services.
Exceptions will be allowed in cases of high risk or immediate danger when involving the police or acute medical personnel. This may be reasonable, but clinics will otherwise be expected to manage any behavioral health crisis on their own.
Under the new Substance Abuse and Mental Health Services Administration (SAMHSA) rules, the clinic must have its own Crisis Management Plan in place that ensures services are provided 24 hours a day, 7 days a week.
However, clinics have a great deal of flexibility in determining how they will create their unique crisis response programs. SAMHSA’s requirement gives clinics the freedom to partner with existing resources and make use of a variety of different models ranging from mobile crisis stabilization units to walk-in crisis clinics.
SAMHSA’s new CCBHC certification criteria
The enhanced crisis management response is one of numerous changes SAMHSA is requiring for clinics under revised certification criteria announced in 2023. Clinics are working now to meet timelines for compliance based on their CCBHC expansion grant status and state demonstration pilot requirements.
Kathy Dettling, SimiTree’s Vice President of Clinical Strategy, has been advising clinics on how to meet all the new criteria, including the implementation of new quality data reporting requirements. (Read the details about new reporting requirements in my previous post here.)
She has also been helping clinics put into place the required 24-7 crisis management plan.
I recently had the chance to question Kathy about this new requirement. We talked about some of the particular challenges clinics will face during implementation, and the various ways clinics are complying.
Here’s a recap of our discussion:
Q. What changes are ahead for CCHBCs under the new crisis management requirement?
Clinics will be required to provide a level of crisis intervention services with 24-hour, 7-day availability. Every CCBHC will be required to have a full Crisis Management Plan in place to deal fully with the need for behavioral health services outside of regular hours, whether the crisis is detoxification, mental health stabilization, or another type of crisis need.
Q. How is that different from the way clinics operate now?
Right now, it is common for clinics to keep regular office hours and direct any after-hours patients to call 911 or seek emergency care at the hospital emergency department. But a crisis doesn’t stop after hours. Clinics need to understand they will no longer be able to deflect responsibility. They will be responsible for fully assessing the person who is experiencing the crisis and providing intervention services. They might rely on a Crisis Line or a Suicide Prevention Line and make use of a number of different models to do this. Different states have different opportunities.
Q. Can you outline some of the specifics needed for a fully compliant Crisis Management Plan?
CCBHCs will need to address risk assessments and crisis planning that focuses on measures needed to reduce current, future, and ongoing risk. The plan will also need to address the clinic’s working relationships, agreements, and protocols with:
- SAMHSA’s 988 Suicide & Crisis Lifeline
- Local hospital systems, emergency departments, Urgent Care clinics, etc.
- Discharge planning for anyone admitted to medical or psychiatric facilities due to identified mental health or SUD conditions
Q. Why is SAMSHA requiring clinics to have a 24-7 Crisis Management Plan?
The primary goal is stabilization, to be able to resolve a crisis before it reaches a more intense level that could result in an overdose or an arrest or another unwanted outcome. Under the new criteria, clinics will function much as Urgent Care clinics function in the event of a primary care need, providing an alternative to emergency departments. SAMHSA wants CCBHCs to step up and be able to stabilize a crisis without having to make use of hospital emergency departments or in-patient psych units.
Q. Providing 24-7 services sounds like a big task for CCBHCs. How can clinics realistically meet this new Crisis Management requirement?
Community resources are key. The CCBHC doesn’t necessarily need to provide its own crisis management. It can rely instead on a collaborative effort with other resources within the community to make certain it is in compliance with the new requirement. The CCBHC can contract with a DCO – a Designated Collaborative Organization – to act on its behalf during a crisis.
Q. Does that bring its own challenges?
Yes, it does! The CCBHC must determine who within the community is available for 24-7 services – and in some areas, this can be especially difficult due to staffing shortages. Once the clinic has a DCO, the clinic is still responsible for effective coordination of reliable services, and contracting with a DCO opens up a whole new area of compliance considerations.
Q. What are some of the various service models that clinics could rely on in order to meet the new requirement?
There is a wide range of models. Some examples are crisis stabilization units, urgent behavioral health care, walk-in crisis clinics, or mobile crisis units. Mobile units seem to be particularly popular in urban areas. In Ohio, there are some child-specific crisis teams, and I’ve also seen a model in which a master’s level clinician provides support services to families. Other examples I’ve seen included a stabilization unit working with a 24-hour respite center to offer both nursing and support from social workers so that individuals in crisis could be assessed quickly and services such as any necessary medication could begin quickly.
Q. How are you and SimiTree’s other consultants helping clinics develop their new crisis management plans?
We work with clinics to help them develop a full crisis continuum: identifying the right community resources, developing the crisis management plan, and making certain the DCO contract covers all the bases. Our consultants help review and set up effective care coordination within the community, making certain the licensing and certification requirements are met. We also help clinics set up self-monitoring processes needed to make certain they are following up on the psychiatric referrals or appointments as needed, and continuing to develop services that are needed.
SimiTree meets all compliance needs
The work that Kathy and our other consultants are doing with CCBHCs is filling an important and necessary role in the behavioral health compliance area.
As always, when SimiTree works with clients, our data analysts and compliance experts take things one step further, going the extra mile. While we are helping our clients ensure compliance with new CCBHC certification criteria, developing their crisis management plans, and meeting data requirements, we show them how to build improvements into data-collecting processes, including:
- Processes for easily identifying clients who are eligible for the measures
- Reliable tracking and alert systems to stay within required timeframes
- Use of standardized screening tools and assessments for stronger compliance
NEXT WEEK: The 4 Screening Tools Allowed for the SDoH Assessment
Reach out to us today to learn how we can help your organization meet SAMSHA’s new CCBHC certification criteria, leverage quality data to improve care, streamline workflow, and drive performance.
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J’non Griffin serves as Senior Vice President/Principal for the Compliance as well as Coding divisions at SimiTree. Her healthcare career spans three decades of clinical and leadership experience, and she has a track record of helping many provider types implement effective compliance programs. She is a certified ACHC and CHAP consultant and holds additional certifications in diagnosis coding and other healthcare specialties. As an AHIMA ambassador, she was instrumental in the implementation of ICD-10.