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Summary of Changes

This document summarizes the changes to the original 2015 version of the Certified Community 

Behavioral Health Clinic (CCBHC) criteria, which are reflected in the 2023 version.

Through a six-month process, the Substance Abuse and Mental Health Services Administration 

(SAMHSA) convened listening sessions with interested parties to revise the CCBHC criteria. Input from 

individuals, organizations, states, and federal agencies shaped the 2023 version. The changes can be 

summarized into the following categories1

: 

• Significant Updates to Advance the Field: These are significant changes that correspond to 

updates to federal policies, national standards, evolving technologies, and/or infrastructure 

changes. 

• Needed Structural Changes to the Criteria: These changes help align the delivery of service 

requirements with the statute or updated regulations.

• Increased Flexibility: These changes provide CCBHCs with additional flexibilities that were not 

available in the 2015 criteria. 

• Additions that Strengthen the Model: These changes strengthen the CCBHC model. 

• Updated Language and Examples: These changes reflect changing terminology in behavioral 

health. Examples are added to reflect emerging evidence-based services and to identify 

innovations in the field. 

• Clarifications: These changes reflect clarification of the original criteria in areas where CCBHCs 

and states identified ambiguities.

Significant Updates to Advance the Field

Crisis Care

Since the initial criteria were published, SAMHSA has developed guidance around the components of 

a comprehensive crisis system in its National Guidelines for Behavioral Health Crisis Care – A Best 

Practice Toolkit. In addition, the national 988 Suicide & Crisis Lifeline was established. States have 

also been working to develop their crisis response systems. Crisis care requirements in the criteria

have been amended to align with the National Guidelines and the implementation of 988 while 

recognizing the difference in state definitions and the varying availability of crisis services. Trauma 

informed approaches must be applied to crisis care services.

2.c Incorporates education about 988. 

3.a.5 Ensures that all persons receiving services have discussed a crisis plan, even if it simply 

to call 988. 

1 Some minor language changes may not be reflected in this table. 
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3.c.3 Requires that the CCBHC have a care coordination partnership with the 988 Suicide & 

Crisis Lifeline call center serving the area in which the CCBHC is located.

4.c Integrates the National Guidelines for Behavioral Health Crisis Care – A Best Practice 

Toolkit including minimum standards for the coordination of crisis services, mobile crisis 

response, and crisis stabilization. Describes expectations for emergency crisis 

intervention services that include coordination with state, regional, and systems to 

make referrals and coordinate and track care in real-time. Requires CCBHCs to establish 

protocols to track referrals made from the call center to the CCBHC or its DCO crisis care 

provider to ensure the timely delivery of mobile crisis team response, crisis stabilization, 

and post crisis follow-up care.

4.c Describes expectations for mobile crisis care team availability and to respond within one 

hour (2 hours in rural and frontier settings) from the time that they are dispatched, with 

response time not to exceed 3 hours. Revisions permit the use of technologies when 

remote travel distances make response times unachievable. States that certify clinics 

that seek to use state sanctioned crisis systems that do not meet these requirements 

and individual CCBHCs that seek a DCO with a state-sanctioned crisis system that do not

meet expectations may request approval HHS to do so.

4.c Describes crisis stabilization services and the minimum urgent care/walk-in services that 

identify the individual’s immediate needs, de-escalate the crisis, and connect them to a 

safe and least-restrictive setting for ongoing care. 

4.c Incorporates the risk of drug and alcohol related overdose and intervention support 

following a non-fatal overdose and overdose prevention activities. 

4.c Requires CCBHC training to focus on the application of trauma-informed approaches 

during crises.

Responding to the Opioid Epidemic

In the midst of the continuing national overdose crisis, the Criteria have been strengthened in several 

areas to increase the focus on substance use disorders and overdose: 

1.b.2 Clarifies that the requirement that the CCBHC must have the capacity to prescribe FDAapproved medications used to treat opioid and alcohol use disorders makes an 

exception for Methadone. If the CCBHC does not have the ability to prescribe 

methadone directly, it should provide referral to an OTP with care coordination to 

ensure access to methadone and coordination with other services in the scope of their 

facility’s legal ability to do so. 

1.b.2 Adds requirement to consult with or have addiction medicine specialist or physician on 

staff unless the Medical Director has experience with substance use disorder. 

1.b.2 Recognizes need for the availability of Methadone. If the CCBHC does not have the 

ability to prescribe methadone directly, it should provide referral to an OTP with care 
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coordination to ensure access to methadone and coordination with other services in the 

scope of their facility’s legal ability to do so.

1.b.2 Other FDA-approved medications are added to Buprenorphine in 1.b.2. 

1.c.1. Training on overdose prevention and response.

2.c.3 Includes focus on overdose prevention.

3.c.2 Updates partnerships to include an OTP if any exist within the CCBHC service area and 

included a focus on overdose prevention during transfers. 

3.c.3 Adds SUD Recovery/Transitional housing to the list of examples of potential 

partnerships.

4.c.1 “Intoxication” including ambulatory and medical detoxification” replaced with 

“including risk of overdose and intervention following overdose reversal.” Overdose 

prevention activities must include the provision of naloxone for overdose reversal to 

individuals who are at risk of opioid overdose, and as appropriate, to their family 

members.

4.d.3 Evaluation includes herbs and supplements and the indication for any newly started 

medications in the initial evaluation and replaced substances with “the use of any 

alcohol and/or other drugs.”

4.d.4 Includes withdrawal and overdose risk concerns to the comprehensive assessment. 

4.d.8 (Previously 4.d.9) Clarifies how CCBHCs act if unsafe substance use is identified during 

screening. 

4.f.1 Adds a focus on harm-reduction and motivational techniques. 

4.h.1 Adds supports for people deemed at high risk of suicide or overdose under targeted 

case management. 

5.b.2 Adds events that require continuous quality improvement plans to address to include 

fatal and non-fatal overdoses, in response to the increase in overdose deaths resulting 

from opioid use and misuse.

Improving Health Equity

The Criteria have been updated to include a more intentional focus on disparities and social 

determinants of health. 

1.c.1 Revises requirements to align training with National Standards for Culturally and 

Linguistically Appropriate Services (CLAS) in Health and Health Care to advance health

equity, improve quality of services, and eliminate disparities.

2.a.6 Clarifies the meaning and intent of “outreach and engagement activities” to extend 

behavioral health services to unserved individuals and underserved communities.
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4.b.2 Adds other cultural or ethnic groups in the recognition of particular cultural and other 

needs of clients and services that respond to the needs of sexual and gender minorities. 

4.d.4 Adds a focus on social determinants of health and cultural, environmental, and linguistic 

factors that may affect the client’s treatment plan as a part of the required 

comprehensive diagnostic and treatment planning evaluation.

5.b.1 Adds the requirements for CCBHCs to have an explicit focus on populations experiencing 

health disparities (including racial and ethnic groups and sexual and gender minorities) 

and disaggregated data to track and improve outcomes for populations facing health 

disparities. 

Full Summary of Changes

# Location of Change Category Change

1 Throughout Updated 

language

“Integration" is replaced with "coordination" for 

CCBHC services unless the word is used in specific 

context.

2 Throughout Updated 

language

"Consumer" is replaced with "person [people] 

receiving services" whenever the term referred to 

person receiving services(s). In Section 6, Board 

Governance “consumer” was replaced “individuals 

with lived experience of mental and/or substance 

use disorders and families.”

3 Throughout Updated 

language

“Detoxification” is replaced with “medical 

withdrawal management.” 

4 Throughout Updated 

language "Catchment area" is replaced with "service area."

5 Throughout Updated 

language "State" is replaced with "certifying state."

6 Throughout Updated 

language

"Mental health and substance use" is replaced with 

"behavioral health" unless the distinction is made 

for licensing or other purposes.

7 Throughout Updated 

language

“Needs assessment” is replaced with “community 

needs assessment.” 

8 Throughout Updated 

language

“Abstinence” is removed from the definition of 

health as a non sequitur.

9 Throughout Updated 

language

Telehealth/telemedicine are expanded to include 

video conferencing, digital therapeutics, remote 

patient monitoring, asynchronous interventions, 

and other technologies to the extent possible in 

alignment with the preferences of the person 

receiving services. 

10 Throughout Updated 

language

“Medicaid Demonstration” is replaced with “Section 

223 CCBHC Demonstration."
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# Location of Change Category Change

11

Behavioral health in 

Definitions 

Updated 

language

The definition of behavioral health is updated to 

reflect promotion and prevention as well as 

treatment. 

12 Client in Definitions Updated 

language

“Client” is replaced with “Person or People 

Receiving Services” referring to people who receive 

one of the nine required CCBHC services. The new

definition also points out that the person receiving 

services has a role in directing, expressing 

preferences, planning, and coordinating services. In 

these situations, when there is a legal guardian for 

the person receiving services, these roles shall also 

be filled by the legal guardian.

13 

Community Needs 

Assessment in

Definitions 

Addition that 

strengthens the 

CCBHC model

CCBHC staffing plans, accessibility, and scope of 

service depend upon the completion of an accurate 

assessment of the behavioral health needs of the 

entire service area and all of the people who live 

there, including unserved and underserved 

communities. The requirements for the community 

needs assessments are assembled from the 

SAMHSA 223 web pages, criteria that cite the 

community needs assessment, the list of 

community partners identified in statute, 

requirements in SAMHSA’s notice of funding 

availability for CCBHC Expansion grants, and the 

requirement that CCBHCs coordinate crisis care 

response with law enforcement agencies. The 

CCBHC is directly responsible for conducting the 

community needs assessment. Criteria that are 

impacted by the information gained from the 

community needs assessment are identified 

throughout the criteria. 
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# Location of Change Category Change

14 CCBHCs in Definitions 

Addition that 

strengthens the 

CCBHC model

The definition of CCBHCs makes the distinction 

between CCBHCs that are certified by states and 

those that are designated as CCBHCs after receiving 

SAMHSA CCBHC Expansion grants and indicates that 

CCBHCs must have the capacity to directly provide 

mental health and substance use services to people 

with serious mental illness and serious emotional 

disorders as well as developmentally appropriate 

mental health and substance use care for children 

and youth, unless substantially prohibited by their 

state because of their provider type. The definition 

describes how long certification and/or designation 

may last and under what circumstances they may 

end. 

15

Designated 

Collaborating 

Organizations in 

Definitions 

Clarification 

The definition of a designated collaborating 

organizations clarifies the meaning of meeting 

CCBHC criteria by indicating that services that they 

provide under Criteria 4 must conform to the 

relevant applicable CCBHC criteria. Agreements with 

CCBHCs must include provisions that assure that the 

required CCBHC services that DCOs provide under 

the CCBHC umbrella are delivered in a manner that 

meets the standards set in the CCBHC certification 

criteria. DCOs are required to work towards 

inclusion of additional integrated care elements 

(e.g., including DCO providers on CCBHC treatment 

teams, collocating services). Language specific to 

Section 223 Demonstration payment mechanisms 

are removed from the definition. 

16

Measurement-Based 

Care in Definitions

Addition that 

strengthens the 

CCBHC model

The definition of measurement-based care is 

included in Definitions and is referenced in 4.d.4 

Comprehensive Evaluation. 

17

Peer/Family/Caregiver 

Support in Definitions Updated “Peer/Family/Caregiver Support” replaces “Peer Support” and “Peer Support Specialist” 

18

Required Services in 

Definitions Clarification The nine services that CCBHCs must provide are listed here. 

19

Satellite Facility in 

Definitions Updated 

The definition of a satellite facility is updated 

because the services that CCBHCs must provide 

directly have changed. 

20

Targeted case 

management was 

removed from 

Definitions 

Updated Targeted case management is defined in Criteria 

4.h.
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# Location of Change Category Change

21 Appendix B Updated

The quality measures used for the first Section 223 

Demonstration program were updated for a variety 

of reasons including the recognition that CCBHCs 

are no longer restricted to participation in the 223 

Demonstration program. The new measures are 

found in Appendix B.

22 1.a.1

Needed 

structural 

changes

Community needs assessments and staffing plans

are prepared by the CCBHC. Its components are 

described in the terms and definitions of the criteria

and must be updated regularly but no less 

frequently than every 3 years. Certifying states may 

add additional community needs assessment 

requirements. 

23 1.a.2

Addition that 

strengthens the 

CCBHC model

Notes that staffing is based on the community 

needs assessment.

24 1.a.3

Increased 

flexibility 

Removes the requirement that only CCBHCs 

operating within behavioral health professional 

shortage areas were permitted to hire a nonpsychiatrist as the Medical Director, clarifies the 

role of the Medical Director and the need for 

consultation, recognizes positions that are 

equivalent to CEO, and clarifies the role of the 

Medical Director to provide guidance for clinical 

care. Adds that for CCBHCs unable to hire a 

psychiatrist and hire another prescriber instead, 

psychiatric consultation will be obtained regarding

behavioral health clinical service delivery, quality of 

the medical component of care, and integration and 

coordination of behavioral health and primary care.
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# Location of Change Category Change

25 1.b.2 Clarification 

Clarifies that CCBHCs must include medically trained 

behavioral health care providers to prescribe FDA 

approved medications that can be used including 

methadone and specified treatment of tobacco use 

disorders. This would not include methadone, 

unless the CCBHC is also an Opioid Treatment 

Program (OTP). If the CCBHC does not have the 

ability to prescribe methadone for the treatment of 

opioid use disorder directly, it shall refer to an OTP 

(if any exist in the CCBHC service area) and provide 

care coordination to ensure access to methadone. 

Defines experience in the assessment and 

treatment of substance use disorders, and that 

telehealth services delivered must be coordinated 

with other services delivered by the CCBHC. 

Certified/trained peer specialist(s)/recovery 

coaches and certified/staff family peer specialists

are added to the examples of staff. Certifying states 

may specify which disciplines they require of staff.

26 1.c.1

Addition that 

strengthens the 

CCBHC model

Clarifies existing requirements and frequency of 

training specific to those staff in contact with clients 

and adds evidence-based practices; cultural 

competency; CCBHC policies and procedures for 

integration primary care; and care of co-occurring 

mental health, substance use, and health to 

required training. Clarifies that training must 

conform to CLAS standards. 

27 1.c.2

Addition that 

strengthens the 

CCBHC model

Clarifies that staff competence is assessed regularly, 

and records of assessments are maintained for the 

duration of employment for staff with direct 

contact.

28 1.c.3

Addition that 

strengthens the 

CCBHC model

Encourages CCBHCs to provide initial and ongoing 

compliance with, or fidelity to, evidence-based, 

evidence-informed, and promising practices. 

29 1.d.1

Addition that 

strengthens the 

CCBHC model

Removes “if” from the expectation that CCBHCs 

take reasonable steps to provide meaningful access 

to individuals with limited English proficiency and 

language-based disabilities.

30 1.d.2 Clarification Clarifies that translation/interpretation services are 

readily available in several formats.

31 1.d.3 Clarification Clarifies that disabilities are not limited to hearing 

impairments.
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32 1.d.4

Addition that 

strengthens the 

CCBHC model

Updates the ways that clients can access 

information about CCBHC services by adding “online

and paper format” and clarifies that resources 

should be available throughout the time the client is 

served. Adds that the community needs assessment 

informs the threshold for languages that require 

language assistance. 

33 1.d.5 Increased 

Flexibility 

Removes the interpretation of HIPAA Privacy Rule in 

their application to CCBHC policies.

34 2.a.1

Addition that 

strengthens the 

CCBHC model

Adds “sanitary” to the expectations of the CCBHC 

environment and encourages CCBHCs to establish 

tobacco free campuses. 

35 2.a.2 Clarification Notes that times and locations of CCBHC operations 

are informed by the community needs assessment.

36 2.a.3 Clarification 

Provides examples of non-clinic settings that 

CCBHCs may provide services and that their 

selection is informed by the community needs 

assessment. 

37 2.a.4 Clarification Clarifies the intent behind transportation services.

38 2.a.5

Addition that 

strengthens the 

CCBHC model

Emphasizes alignment of service delivery 

technologies with preferences of people receiving 

services. 

39 2.a.6 Clarification 

Clarifies intent of outreach and engagement, adds 

“retention” and “inclusion” of underserved 

populations, and adds that it is informed by the

community needs assessment. Assistance to access 

benefits and services are now described in 3.a.7

40 2.a.8 Clarification 

Clarifies the meaning of a continuity of 

operations/disaster plan in reference to client 

services and access to medication as well as health 

IT systems including health records (both 

security/ransomware protection and backup) and 

access to these systems in case of disaster.
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41 2.b.1 Clarification 

Clarifies that first contact with clients may include 

other remote forms of communication and changed 

terminology so that “preliminary screening” is 

referred to as “preliminary triage”. The 

“comprehensive person-centered and familycentered diagnostic and treatment planning 

evaluation” is reduced to “comprehensive 

evaluation". Notes that appropriate action may 

include plans to reduce or remove risk of harm and 

facilitation to outpatient services. Cross-references 

4.c.1 regarding timelines and plans. Notes that

recent information may be reviewed with the 

person receiving services and incorporated into the 

CCBHC health records from outside providers at the 

CCBHC’s discretion. Notes that independent 

screening and assessment processes for certain 

child and youth populations or other populations 

established by the state may be incorporated in the 

findings to avoid duplication of effort. 

42 2.b.1 and 2.b.3 Clarification 

Clarifies the difference between new person 

receiving services in 2.b.1 and existing person 

receiving services in 2.b.3 and that each must have 

timely access to services, including safety planning if 

appropriate. 

43 2.b.2 Increased 

flexibility 

The requirement for primary care consultation is 

removed. The frequency of treatment plan reviews 

and updates have been reduced from four times per 

year (every 90 days) to two times per year (every 6 

months) and that changes are endorsed by the 

person receiving services. 

44 2.b.3 Clarification 

Clarifies language related to timely access to 

services for people who are already receiving 

services and accommodates their preferences. 

Same day and open access scheduling are 

encouraged.

45 2.c.1 Clarification 

Clarifies that crisis management services must be 

available 7 days a week. The response time stated 

here is removed and referred to 4.c.

46 2.c.3 Updated 

language

Updates crisis planning by including 988 and 

overdose prevention. Cross-references to 3.a.4 and 

1.d.

47 2.c.5 Clarification Clarifies the purpose of establishing protocols with 

law enforcement.
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48 2.d.2

Addition that 

strengthens the 

CCBHC model

Recognizes literacy barriers as an issue for 

communicating sliding fees.

49 2.e.2

Addition that 

strengthens the 

CCBHC model

Encourages the CCBHC to consider technology or 

other practical service delivery mechanisms for 

people receiving services who live within the service 

area but distantly from CCBHC facilities. Clarifies 

that CCBHCs are not required to provide continuous 

services including telehealth to individuals who live 

outside of the CCBHC service area. Protocols may 

address populations that may transition in and out 

of the service area including children in out-ofhome placements and individuals who may be 

displaced by incarceration and housing instability.

50 3

Increased 

flexibility 

Section 223 Demonstration states and participating 

clinics complained that time, energy, and legal 

resources were spent in futile attempts to obtaining 

legal documents from other non-DCO organizations 

to document care coordination agreements. As a 

result, CCBHCs have been unable to obtain care 

coordination agreements. The criteria have been 

revised to allow CCBHCs to achieve meaningful 

partnerships with community partners and 

expanded the means by which they can be 

documented. Criteria 3.c is renamed from “Care 

Coordination Agreements” to “Care Coordination 

Partnerships” and describes how partnerships, 

including attempts at partnerships, may be 

documented. 

51 3.a.1 Clarification 

Clarifies that CCBHCs also coordinate with other 

systems outside of the health system (criminal and 

juvenile justice and child welfare).

52 3.a.2 Clarification 

Clarifies that to promote coordination of care, 

consent for release of information is obtained from 

CCBHC clients with providers outside of the CCBHC 

where information is not able to be shared under 

HIPAA and other federal and state laws and 

regulations. CCBHCs are encouraged to explore 

options for electronic documentation of consent 

when feasible and responsive to the person 

receiving services. 
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# Location of Change Category Change

53 3.a.3 Updated 

language

Replaces “confirming” that the appointment was 

kept with “tracking participation in service to 

ensure care coordination and receipt of supports”. 

54 3.a.4 Clarification 

Clarifies that the crisis plan that CCBHCs must 

develop with each consumer at minimum includes 

counseling the person receiving services on hot and 

warmlines, and mobile and crisis stabilization 

services should a crisis arise when providers are not 

in their office. Plans may support psychiatric 

advance directives as desired by the person 

receiving services and entered into the electronic 

health record of the person receiving services so 

that the information is available to providers in 

emergency care settings where electronic health 

records are accessible. 

55 3.a.5

Addition that 

strengthens the 

CCBHC model

Adds the requirement that the state Prescription 

Drug Monitoring Program (PDMP) must be 

consulted before prescribing medications and

during the comprehensive evaluation to the extent 

that state law allows.

56 3.a.6 Clarification 

Recognizes that agreements for care coordination 

should not limit the person receiving services from 

choosing any provider. 

57 3.a.7 (new)

Addition that 

strengthens the 

CCBHC model

The CCBHC assists people receiving services and 

families to access benefits, including Medicaid, and 

enroll in programs or supports that may benefit 

them. These expectations had been included in 

2.a.6 in and have been moved to create this new 

criterion. 

58 3.b.1 Clarification 

The description of health information technology 

systems is minimized in 3.b.1 and further expanded 

in subsequent sub-criteria. 

59 3.b.2 Clarification 

Adds that CCBHCs ensure that health IT systems 

have appropriate protections in place and adds 

quality measurement and reporting to the activities 

that these systems conduct. Provides guidance and 

examples when upgrading electronic systems such 

as utilizing nationally recognized, HHS-adopted 

standards, where available, to enable health 

information exchange and encourages CCBHCs to 

explore ways to support alignment with standards 

across data-driven activities. 
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60 3.b.3

Needed 

Structural 

Change

Removes “if” and updates language to “current” 

technology. The revision clarifies the required core 

set of certified health IT capabilities that align with 

key clinical practice and care delivery requirements 

for CCBHCs. The note indicates that CCBHCs that do 

not meet these standards when certified should 

plan to adopt and use technology meeting these 

requirements over time. The note points out that

CCBHCs do not need to adopt a single system that 

provides all these certified capabilities but can 

adopt either a single system or a combination of 

tools that provide these capabilities and that CCBHC 

providers who successfully participate in the 

Promoting Interoperability Performance Category of 

the Quality Payment Program will already have 

health IT systems that successfully meet all the core 

certified health IT capabilities. 

61 3.b.5 Clarification 

The plan to focus on ways to improve care 

coordination between CCBHCs and all DCOs is to be 

produced within two years of certification or 

submission of attestation rather than within the 

“two-year demonstration program time frame”. 

The focus of this effort is elucidated to support 

integrated evaluation planning, treatment, and care 

coordination, integrating clinically relevant 

treatment records generated by the DCO for people 

receiving CCBHC services and incorporate them into 

the CCBHC health record. 

62 3.C

Increased 

Flexibility 

The criteria 3.C is retitled “Care Coordination 

Partnerships” from “Care Coordination 

Agreements.” Each of the sub-criteria under 3.c.

Care Coordination Partnerships is now accompanied 

by a note that describes how partnerships may be 

documented. 
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# Location of Change Category Change

63 3.c.2

Addition that 

strengthens the 

CCBHC model

Adds OTP services, medical withdrawal 

management facilities, and tribally operated mental 

health and substance use services including crisis 

services, that are in the service area to the list of 

required partnerships. The criteria also clarify that 

CCBHCs establish protocols and procedures for 

transitioning individuals from EDs, inpatient 

psychiatric programs, medically monitored 

withdrawal management services, and residential or 

inpatient facilities that serve children and youth to a 

safe community setting.

64 3.c.3

Addition that 

strengthens the 

CCBHC model

Clarifies partnerships that are required, from those 

which are optional. In addition to partnerships

required by statute, this criteria points out that the 

CCBHC has a care coordination partnership with the 

988 Suicide & Crisis Lifeline call center serving the 

area in which the CCBHC is located. A number of 

additional agencies are offered as examples 

important community entities with which CCBHCs 

may partner. These partnerships are documented 

slightly differently than the partnerships described 

in 3.c.1, 2, 4, and 5. 

65 3.c.5 Clarification 

Expectations for partnerships with medical 

withdrawal management facilities and ambulatory 

medical withdrawal management providers are

moved to 3.c.2. Clarifies procedures and services, 

such as peer recovery specialist/coaches, to help 

individuals successfully and seamlessly transition 

from ED or hospital to CCBHC and community care. 

CCBHCs should request of relevant inpatient 

facilities, for people receiving CCBHC services, that 

notification be provided through the AdmissionDischarge-Transfer (ADT) system.

66 3.d.1 Clarification 

Clarifies that the members of the adult client’s 

family whom the client “desires” (replacing “does 

not object to”) may be included in the treatment 

team.
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# Location of Change Category Change

67 3.d.1 Clarification 

Adds legal guardian to family/caregiver members of 

the treatment team. Clarifies that the members of 

the adult client’s family whom the client “desires” 

(replacing “does not object to”) may be included in 

the treatment team and that HIPAA allows for 

clients to identify those persons who can receive 

information about their care. While the citation to 

the HIPAA Privacy Rule remains, its interpretation is 

deleted. 

68 3.d.2

Addition that 

strengthens the 

CCBHC model

Adds family/caregivers, to the extent the person 

receiving services desires their involvement or when 

they are legal guardians, to the treatment team. 

69 4.a.1

Needed 

structural 

change

The original criteria limited CCBHCs to organizations 

that directly provided four of the nine core services 

and may provide the other five services through 

formal agreement with designated collaborating 

organizations (DCOs). A recent determination by 

HHS concluded that CCBHCs are not required to 

directly provide 4 core services. This substantive 

change has required revisions throughout the 

document, including definitions of CCBHCs and 

DCOs, care coordination, and particularly to scope 

of services and expectations for CCBHCs 

competency in behavioral health. To avoid the type 

of service fragmentation that have been described 

in federal commissions over the past two decades, 

including the President’s New Freedom Commission 

and in the Interdepartmental Serious Mental Illness 

Coordination Committee, the criteria bolster 

expectations that CCBHCs are fully licensed and 

credentialed behavioral health providers and that 

they will provide a substantial proportion (51% or 

more of encounters across the required services 

excluding Crisis Services) as this will enhance the 

ability of the CCBHC to provide a coordinated 

service package. 

70 4.b.1

Addition that 

strengthens the 

CCBHC model

Adds that shared decision-making is the 

recommended approach for engagement.

71 4.b.2

Addition that 

strengthens the 

CCBHC model

Adds the expectation that care is responsive to the 

race, ethnicity, sexual orientation and gender 

identity of the person receiving services. 
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# Location of Change Category Change

72 4.c.1 Updated 

language

“Psychiatric” is replaced with “behavioral health” 

crisis. Please see Significant Changes to the Field; 

Crisis Services for an in-depth description of 

changes to 4.c.1. 

73 4.d.1 Updated 

language

Adds neuropsychological testing as an example of 

specialized services that may be referred to an 

appropriate provider. Clarifies that screening, 

assessment, and diagnosis can be provided through 

telehealth/telemedicine. 

74 4.d.2

Addition that 

strengthens the 

CCBHC model

Adds preferences of the person receiving services 

among considerations in screening, assessment, and 

diagnosis. 

75 4.d.3

Addition that 

strengthens the 

CCBHC model

Several elements are added, and all are

enumerated, commensurate with best clinical 

practice. These include asking about alcohol and 

drugs including current medications; herbs and 

supplements; cultural and environmental factors 

including linguistic services and supports; pregnancy 

and/or parenting status; a summary of treatment 

history and success of past treatments; intimate 

partner violence; and, for children and youth, 

whether they have system involvement (such as 

child welfare and juvenile justice).

76 4.d.4 Clarification 

4.d.4 is eliminated because it repeated the 

requirement stated in 2.b.1 for a comprehensive 

person- and family-centered diagnostic and 

treatment planning evaluation. Subsequent items in 

section 4.d are renumbered.
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# Location of Change Category Change

77 4.d.4 (previously 4.d.5)

Addition that 

strengthens the 

CCBHC model

Clinicians are encouraged to use their best 

judgement with respect to the depth of the 

assessment, prioritizing people’s preferences. Many 

of the existing considerations are updated and 

elucidated and some new considerations are added 

commensurate with best clinical practice. Additional 

considerations include social determinants of health 

and relevant social supports; cultural, 

environmental, and health-related social needs; 

pregnancy and parenting status; withdrawal and 

overdose risk; a more thorough assessment of 

substances, medications, and supplements, 

including information from the Prescription Drug 

Monitoring Program; risks including withdrawal; 

assessment of social service needs and involvement 

such as child welfare and juvenile justice and 

referral (for children and youth); and preference for 

receiving services including technologies. 

78 4.d.5 (previously 4.d.6) Greater 

flexibility 

Notes that certifying states may elect to require 

other screenings.

79 4.d.6 (previously 4.d.7) Clarification 

Clarifies purpose of motivational interviewing and 

notes that screening and assessment tools are 

developmentally appropriate. 

80 4.d.7 (previously 4.d.8)

Addition that 

strengthens the 

CCBHC model

Adds that screening tools also recognize differing 

literacy levels.

81 4.d.8 (previously 4.d.9)

Addition that 

strengthens the 

CCBHC model

Specific steps to address unsafe substance use are 

elucidated, including a full assessment and 

treatment by the CCBHC or referral to more 

appropriate care, and appropriate action as 

described in 2.b.1 if an immediate threat to safety is 

presented. 

82 4.e.2

Addition that 

strengthens the 

CCBHC model

Adds that the treatment plan is developed with the 

person receiving services; is based on their goals 

and preferences; supports care in the least 

restrictive setting possible; addresses the person’s 

prevention, medical, and behavioral health needs; 

clarifies that shared decision making is the 

preferred model of establishing goals; and

mandates that all necessary releases of information 

are obtained and included in the health record. 
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# Location of Change Category Change

83 4.e.3

Addition that 

strengthens the 

CCBHC model

Adds the initial evaluation, comprehensive 

evaluation, and ongoing screening to consumer 

assessments to inform the treatment plan.

84 4.e.5

Addition that 

strengthens the 

CCBHC model

Adds recovery supports to the components of the 

treatment plan.

85 4.e.6

Addition that 

strengthens the 

CCBHC model

Adds examples of conditions for which consultation 

is sought during treatment planning such as 

traumatic brain injury, developmental and cognitive 

abilities of clients, interpersonal violence, and 

human trafficking. 

86 4.e.7 Updated 

language

Clarifies that health record includes advanced 

directives unless the person receiving services does 

not want it included.

87

4.e.8 was eliminated 

and its contents 

moved to 4.e.7

Updated 

language

Instructions contained in 4.e.8 are moved to a note 

under 4.e.7, that certifying states should specify 

other aspects of person-centered and familycentered treatment planning they will require based 

upon the needs of the population served. 

88 4.f.1

Addition that 

strengthens the 

CCBHC model

To ensure consistency of CCBHC outpatient services 

and to clarify expectations, a minimum set of 

outpatient services has been outlined in 4.f.1. 

Services must include the delivery of evidence 

based and best practices in individual, family and 

medication therapies as well as substance use 

treatment services that align with ASAM level 1 

outpatient and ASAM level 2.1 intensive outpatient 

services and includes treatment of tobacco use 

disorders. Adds that services are delivered in 

alignment with state and federal laws and 

regulations and that when specialized services are 

not practically available, CCBHC professional staff 

may consult with specialty providers. CCBHCs are 

encouraged to engage persons who use potentially 

harmful substances using motivational techniques 

and harm reduction strategies to promote safety 

and reduce substance use. 
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# Location of Change Category Change

89

4.f.2 is eliminated, and 

its contents are 

incorporated under 

4.f.1 as instructions to 

certifying states

Updated 

language

Updates examples of evidence-based and best 

practices including those for first episode psychosis; 

children, youth and their families; substance use 

disorders; effective but underutilized medications 

such as clozapine; and FDA-approved medications 

for substance use disorders including smoking 

cessation. 

90 4.f.2 previously 4.f.3 Updated 

language

Encourages CCBHCs to use evidence-based 

strategies, such as measurement-based care (MBC), 

to improve service outcomes.

91 4.f.3 previously 4.f.4 Updated 

language Reduces repetitive language. 

92 4.g.1 Updated 

language

Because quality measures were revised and many 

CCBHCs and states found the requirements under 

Outpatient Clinic Primary Care Screening and 

Monitoring to be confusing, most of 4.g has been 

substantially revised. The CCBHC medical director 

establishes protocols for HIV and viral hepatitis; 

primary care quality measures from Appendix B; 

and other clinically indicated primary care key 

health indicators. 

93 4.g.2

Addition that 

strengthens the 

CCBHC model

Directs the CCBHC Medical Director to develop 

organization protocols to screen people receiving 

services across the lifespan particularly those with 

chronic disease, ensuring that people receiving 

services are asked about their physical health 

symptoms, and establishing systems for the 

collection of laboratory samples. Laboratory 

analyses can be done directly or through another 

arrangement with an organization separate from 

the CCBHC. CCBHCs should have the ability to 

collect biologic samples and/or coordinate with the 

primary care provider of the people being served.

94 4.g.3

Addition that 

strengthens the 

CCBHC model

Adds that CCBHCs provide ongoing primary care 

monitoring of health conditions including ensuring 

access to primary care services; periodic lab testing

and physical measurement of health status 

indicators and changes in the status of chronic 

health conditions; coordination with primary care; 

and promoting health lifestyle.
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# Location of Change Category Change

95 4.h.1 Clarification 

The definition of targeted case management (TCM) 

is moved from Terms and Definitions to this 

criterion. Other revisions include when, where and 

for whom TCM may be most appropriate including 

critical periods, such as episodes of homelessness or 

transitions to the community from jails or prisons. 

96 4.i.1

Addition that 

strengthens the 

CCBHC model

The purpose and scope of psychiatric rehabilitation 

services are more clearly described, and underscore 

needs supports to live and thrive in the community. 

CCBHCs must provide supported employment and 

supports for social inclusion; supported education; 

medication education, self-management and/or 

individual and family/caregiver psychoeducation; 

and finding and maintaining stable housing. Many 

psychiatric rehabilitation services are recommended 

for consideration. Notes that certifying states 

should specify which services, above the minimum 

required, they will require based on the needs of 

the population served. 

97 4.j.1 Updated 

language

Updates the definition of peer support and 

description of peer services, as well as the variety of 

roles that peers can perform. Notes that certifying 

states should specify the scope of peer and family 

services they will require based on the population 

serviced. 

98 5.a.1

Addition that 

strengthens the 

CCBHC model

Adds that data should be captured electronically 

when feasible.

99

5.a.2 (combined what 

had been 5.a.2 and 

5.a.3)

Needed 

structural 

change

The quality measures used for the first Section 223 

Demonstration program are updated for a variety of 

reasons, including the recognition that CCBHCs are 

no longer restricted to participation in the 223 

Demonstration program. The new measures are 

found in Appendix B. Reporting requirements for 

CCBHCs funded through expansion grants are 

distinguished from those funded under the 

Demonstration. Notes that certifying states may 

require CCBHCs to collect and report optional clinic 

level measures. What was 5.a.3 regarding collection 

of data through DCOs is now in 5.a.2. 
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# Location of Change Category Change

100 5.a.3 (previously 5.a.4)

Needed 

structural 

change

Instructions regarding data collection from DCO that 

had been in 5.a.3 have been incorporated into 5.a.2. 

5.a.3 now addresses Medicaid claims data required 

of states participating in the Section 223 

Demonstration program. Notes that CCBHCs 

participating in the Section 223 Demonstration 

program are responsible for providing data to the 

state and as may be required to HHS and the 

evaluator. 

101 5.a.4 (previously 5.a.5) clarification 

Clarifies that cost reports refer only to CCBHCs 

participating in Section 223 Demonstration 

program. 

102 5.b.1

Addition that 

strengthens the 

CCBHC model

Clarifies that CCBHCs are required to establish 

continuous quality improvement plans for services 

and a review process to review outcomes. 

Outcomes should address improvements in 

behavioral and physical health of people receiving 

services and reductions in rehospitalizations, 

emergency department use, and repeated crisis 

episodes. Adds that the Medical Director is involved 

in the aspects of the CQI plan that apply to the 

quality of the medical components of care, 

including coordination and integration with primary 

care. 

103 5.b.2

Addition that 

strengthens the 

CCBHC model

Adds significant events that require continuous 

quality improvement plans that include fatal and 

non-fatal overdoses, deaths by suicide or suicide 

attempts, and all-cause mortality. 

104 5.b.3 (new)

Addition that 

strengthens the 

CCBHC model

Adds a criterion that requires CQI plans to use 

quantitative and qualitative data and address the 

data resulting from the CCBHC-collected and, as 

applicable for the Section 223 Demonstration, 

State-Collected, quality measures that may be 

required as part of the Demonstration. The CQI plan 

includes an explicit focus on populations 

experiencing health disparities and addresses how 

the CCBHC will use data to track and improve 

outcomes for populations facing health disparities.

105 6.a.2 Updated 

language

Replaces “AI/AN consumers” with “tribal 

members.”

106 6.a.3 Clarification 

Clarifies that an independent financial audit is 

performed annually for all CCBHCs for the duration 

that they are designated CCBHCs.
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# Location of Change Category Change

107

6.b.1 (combines what 

had been 6.b.4) Clarification 

Replaces “the CCBHC’s board members are 

representative of” with “CCBHC governance must 

be informed by” and “types of disorders” with 

health and behavioral health needs”. Describes 

meaningful participation and identifies two options 

for CCBHCs to demonstrate meaningful 

participation in CCBHC governance (exceptions to 

this requirement are described in 6.b.3). 

108 6.b.2 Clarification 

Clarifies the processes for CCBHCs, certifying states, 

and federal grant funding agencies to ensure that 

meaningful participation as described in 6.b.1. 

109 6.b.3 Clarification 

Clarifies that CCBHCs comprising a governmental or 

tribal organization, subsidiary, or part of a larger 

corporate organization that cannot meet these 

requirements for board membership must develop 

an advisory structure and other methods to provide 

meaningful participation as defined in 6.b.1.

110 6.b.4 (previously 6.b.5) Clarification Replaces “banking” with “accounting”. 

111 6.c.1 

Needed 

structural 

change

Adds that the CCBHC must be enrolled as a 

Medicaid provider and licensed provider of both 

mental health and substance use disorder services 

including developmentally appropriate services to 

children, youth, and their families unless there is a 

state administrative, statutory, or regulatory 

framework that prevents or substantially prevents 

the CCBHC organization provider type from 

obtaining the necessary licensure, certification, or 

accreditation to provide these services. CCBHCs are 

also required to participate in the SAMHSA 

Behavioral Health Treatment Locator. 

112 6.c.2

Needed 

structural 

change

Describes how CCBHCs are certified and notes that 

state certified CCBHCs may retain certification no 

longer than three years before certification lapses 

or they are recertified. Also notes that certifying

states may use an independent accrediting body as 

part of the certification process.