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CCBHCs in Kansas:

New Federal Designation and What Comes Next

Kansas was selected for the Section 223 Medicaid Demonstration program for the Certified Community Behavioral Health Clinic (CCBHC) model in June 2024, marking a significant milestone in the state's mental health services landscape. This selection brings the potential for enhanced funding and expanded services aimed at improving mental health care for Kansans.

This edition of A Kansas Twistwill explore what this designation means, how it differs from the current CCBHC operations in Kansas, and the potential benefits and challenges that lie ahead.

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The CCBHC Model

The Certified Community Behavioral Health Clinic (CCBHC) model, developed by the Substance Abuse and Mental Health Services Administration (SAMHSA) and the Centers for Medicare and Medicaid Services (CMS), is designed to provide a comprehensive range of mental health and substance use disorder services, ensuring access to high-quality care for all individuals. Established under the Protecting Access to Medicare Act (PAMA) of 2014, the model aims to fill critical gaps in the mental health system by offering a broad spectrum of services. These include 24/7 crisis intervention, outpatient mental health and substance use services, primary care screening and monitoring, and support for families and caregivers(Figure 1).By integrating these services, CCBHCs strive to improve the coordination of care and ensure that individuals receive holistic, person-centered treatment. The model emphasizes the importance of meeting stringent certification criteria, which include requirements for staffing, availability and accessibility of services, care coordination, quality and other reporting, and organizational authority.

Since its inception, the CCBHC model has shown promising results. According to the 2024 CCBHC Impact Report from the National Council for Mental Wellbeing, CCBHCs have significantly expanded access to care, serving over 3 million individuals across the country. Additionally, the report indicates that 81 percent of Medicaid and grantees with longer-standing SAMHSA funding and certification see patients for routine needs within 10 days of an initial outreach (national average is 48 days), with 65 percent offering access within a week or less, and 21 percent providing same-day access.

As Kansas becomes a Medicaid demonstration state for the CCBHC model, it joins a growing list of states committed to transforming mental health services through this innovative and comprehensive approach. By leveraging successes and lessons learned from other states, Kansas has the opportunity to improve accessibility, quality and coordination of mental health care for its residents.

Kansas and Current CCBHC Operations

While Kansas was not in the first wave of CCBHC demonstration states, it was the first state to pass legislation that identified the CCBHC model as a solution to the mental health and substance use crisis. Established through Senate Substitute for House Bill 2208 in 2021, CCBHCs in Kansas are certified by the Kansas Department for Aging and Disability Services (KDADS).

The initial push for CCBHCs in Kansas was supported by federal funding opportunities and grants aimed at expanding access to mental health care. In 2022, Kansas was awarded a federal planning grant from SAMHSA to support the development and expansion of the model. The state has transitioned all 26 existing community mental health centers covering the 105 Kansas counties into CCBHCs. As of now, CCBHC certification is limited to community mental health centers. However, with the passage of House Bill 2784 in 2024, any community mental health center or qualified nonprofit provider meeting the criteria will be eligible for certification beginning on Feb. 1, 2027.

As Kansas transitions into the Medicaid demonstration program, organizations such as the Bert Nash Community Mental Health Center in Douglas County illustrate how this model is able to reshape the delivery of care. Patrick Schmitz, CEO of Bert Nash, explained, "As a community mental health center, we are responsible for the behavioral health care of this community and making sure that [individuals] have access to [care] regardless of the level of illness that they have and their financial status."

The CCBHC framework has enabled Bert Nash to significantly expand their services. The center is now offering over 40 programs that include nutritional therapy, school-based care, housing support, substance abuse training and psychiatric advisement. This model allows for timely access to care based on the severity of need: triage categories are arranged by crisis, urgent and routine, which allows the center to provide same-day support to those in crisis. Schmitz states that if clients need attention for three hours the same day, the CCBHC framework allows this to be possible. This is a major shift from the pre-CCBHC approach where initial assessments could take up to 30 days or more.

In addition to more positive clinical outcomes, the implementation of the CCBHC framework has had positive impacts on staff retention. Schmitz reiterated that keeping staff is critical to the retention and development of skills. Through the CCBHC model, temporary training can be transformed into long-term career skillsets for behavioral health providers.

What It Means To Be a Medicaid Demonstration State

Being a CCBHC Medicaid demonstration state means a state has moved beyond planning and is actively implementingCCBHCs under Section 223 of the Protecting Access to Medicare Act of 2014.While all states implementing CCBHCs must select a Prospective Payment System (PPS) model and establishrates, only demonstration states are required to payclinics using these rates under Medicaid. However, states that are not part of the demonstration can support CCBHCsthrough alternative mechanisms, including State Plan Amendments(SPA) or Section 1115 waivers. The PPS provides fixed daily or monthly payments that are designed to support high-quality, comprehensive care regardless of volume.

• Daily PPS: Provides a single payment per client per day (e.g., in Kansas, only one daily claim is reimbursed per patient, no matter how many services they receive that day).
• Monthly PPS:Functions more like a value-based model, offering a fixed monthly rate per client that encourages care coordination, efficiency and outcomes-based care.

States customize PPS rates based on cost reports and patient complexity, and they have flexibility to define CCBHC requirements and scope of services to meet local needs. When becoming a demonstration state, the state also accepts responsibility for federal oversight, including performance reporting and quality measurement. The number of demonstration states has expanded from eight in 2016 to 18 (Figure 2), reflecting growing interest in integrating behavioral health care with Medicaid sustainability and accountability. The funding for expansion was made available through the federal Bipartisan Safer Communities Act, which gave the U.S. Department of Health and Human Services authority to add ten new states to the demonstration program every two years beginning in 2024.

Figure 2. Federal CCBHC Medicaid Demonstration States

Source: KHI analysis of Substance Abuse and Mental Health Services Administration Section 223 Medicaid Demonstration and State Programs, 2023.

Potential Challenges and Considerations

As of June 2025, President Trump'sFiscal Year 2026 Budget Request includes a proposal to maintaincurrent funding levels for CCBHCs, while shifting oversight services from SAMHSA to the newly formed Administration for a HealthyAmerica.While the proposal is subject to Congressional approval, it underscores the importance ofexamining ongoing implementation experiences and considerations for program sustainability.

A 2022 evaluationof the demonstration program identified several lessons learned and recommendations to support and guide current and future states in implementing the CCBHC model. Although the model has shown promise, states and providers have encountered a range of operational and systemic challenges, including:

• Implementation of PPS:Many states initially faced challenges establishing rates that aligned with the model's requirements. Over time, these challenges have improved as states refined their rate-setting processes. At Bert Nash, providers have emphasized that CCBHC implementation is a multi-year process requiring substantial organizational transformation. As COO Marsha Paige-White explained, "It takes three to five years to full implement, understand and accumulate all data and actions items." Financially, Bert Nash found the daily PPS to be beneficial for aligning with Medicaid reimbursement, covering approximately 60 percent of services. However, because this funding is limited to Medicaid recipients, the clinic must identify alternative funding sources for the remaining 40 percent. Staff at Bert Nash also highlighted that Medicaid expansion could improve financial stability by reaching more clients.
• Compliance:Meeting certification requirements and complying with both state and federal regulations has posed challenges, particularly when navigating overlapping requirements, as SAMHSA encourages states to require accreditation by an independent accrediting body. For example, Bert Nash noted difficulties meeting CCBHC standards from SAMHSA along with the accreditation requirements of the Commission on Accreditation of Rehabilitation Facilities (CARF), as the overlapping and sometimes conflicting expectations create an administrative burden, required duplicative documentation and can strain staff capacity during implementation.
• Staffing:Recruiting and training sufficient staff to deliver the full scope of CCBHC-required services remains a challenge. The 2023 Certified Community Behavioral Health Clinics Demonstration Program: Report to Congressindicated that 90 percent of CCBHCs have reported difficulties with staffing and workforce development.
• Rural access issues: Rural states such as Kentucky have reported unique barriers to accessing care, particularly around Medicaid transportation. Clients must schedule rides 72 hours in advance and often face long wait times after appointments. In response, Kentucky has implemented a range of strategies, including expanded telehealth services, deployment of mobile units, hiring of CCBHC-based drivers and outreach to raise awareness of available services. Some CCBHCs now serve as transportation brokers, and recent policy changes have expanded eligibility for non-emergency medical transportation to households that own vehicles. These efforts aim to reduce logistical barriers and improve access in remote communities.
• Data sharing and quality reporting: CCBHCs initially struggled to report quality measures due to limited prior experience and insufficient data infrastructure. According to the 2022 evaluation, most CCBHCs were not equipped to meet federal reporting requirements prior to the demonstration. However, nearly all (97 percent) of the original demonstration states subsequently enhanced their data systems, with support from state and federal agencies.
• Variability in implementation: The CCBHC model allows states to create flexibility in how clinics operate, which has led to variation in service use and outcomes. This variation reflects differences in state-level implementation strategies and population needs.

To address these issues, the evaluation recommended technical assistance and support at both the state and federal levels. Ensuring long-term stability, particularly in the context of evolving funding landscapes, requires careful planning, infrastructure investment and policy alignment.

Conclusion

Thedesignation brings new opportunities for expanded funding, improved care coordination and enhanced data reporting. As implementation continues, ongoing attention to workforce capacity, rural access and financial sustainability will be important. By learning from other states and continuing to adapt to local needs, Kansas can further refine its approach and support the delivery of comprehensive, accessible behavioral health care.