Federal Certified Community Behavioral Health Clinics (CCBHCs) certification criteria require that CCBHCs coordinate care with Federally Qualified Health Centers (FQHCs). Specifically, criteria published by SAMHSA in 2015 mandate that CCBHCs establish “care coordination expectations with FQHCs (and, as applicable, Rural Health Clinics (RHCs) to provide health care services, to the extent the services are not provided directly through the CCBHC.” To meet this requirement, CCBHCs must demonstrate that they have at least an informal agreement with an FQHC or RHC (e.g., letter of support, agreement, or commitment), though formal agreements (e.g., contracts, Memorandum of Agreement, Memorandum of Understanding) are preferred.
The specifics of the design and content of these relationships remains unknown. The existing literature on CCBHCs and FQHCs reside in PAMA-mandated United States Department of Health and Human Services (HHS) reports to Congress that are required to investigate three areas. None of these areas cover the CCBHC certification requirements related to care coordination, resulting in reports that skim over arrangements between CCBHCs and medical and social service providers, including FQHCs. Indeed, the relevant data from the reports are limited to counts of the number of CCBHCs that have a designated collaborating organization (DCO), other formal, or informal relationship with FQHCs, RHCs, and other primary care providers. Further, the HHS reports only review CCBHCs enrolled in the Section 223 Demonstration Program, ignoring the far majority of CCBHCs that do not participate in the Demonstration but have received SAMHSA expansion grants. Finally, the HHS reports do not discuss variation in state certification criteria related to relationships with FQHCs.
Despite their limitations, the existing literature provokes additional inquiry. The HHS reports demonstrate that CCBHCs have DCO or other arrangements with FQHCs, and that some CCBHCs offer on-site primary care services in addition to primary care screening and monitoring, which is one of the nine service categories. Oregon has gone a step further, mandating that sites provide 20 hours of on-site primary care services per week in the second demonstration year. These findings suggest that the relationship between CCBHCs and FQHCs are further complicated by the fact that some CCBHCs offer on-site primary care services in addition to the mandated nine categories of CCBHC services.
Coming summer 2022.