It seems that everywhere I turn in public health circles these days, I’m part of conversations about improving access to mental health services, integrating mental and physical health, and promoting mental health and wellness as a key part of overall health.
There are good reasons these conversations are happening now. We are coming to understand the prevalence of mental illness among children and adults, and the extent to which mental illness heightens morbidity from chronic disease, as well as intentional and unintentional injuries. At the same time, we know that mental wellness can contribute to personal well-being, strong relationships, and increased resilience. Mental health has been identified as a priority in the Community Health Needs Assessment process for many nonprofit hospitals, both by individual hospitals as well as at the statewide level, as in North Dakota and Minnesota. Importantly, those conversations are beginning to make their way into law and policy.
As discussed previously in this blog and by our partners in public health law, the Mental Health Parity and Addiction Equity Act and the Affordable Care Act have expanded access to mental health care, tobacco cessation benefits, and treatment of substance use disorders. Expanded access is being achieved in part through increased coverage under health insurance plans, in order to provide coverage comparable to that provided for primary care for physical health. In April, the Centers for Medicare and Medicaid Services published a proposed rule to apply mental health parity requirements to Medicaid managed care organizations, Medicaid alternative benefit plans, and Children’s Health Insurance Programs.
Another way that expanded access to mental health care may be achieved in the coming years is through demonstration projects under Section 223 of the Protecting Access to Medicare Act of 2014. Under Section 223, which was previously part of a separate bill called the Excellence in Mental Health Act, selected states may expand access to mental health services at community behavioral health clinics, especially among Medicaid recipients affected by serious mental illness and severe substance use disorders, as well as children with serious emotional disturbances. This has been called the single largest investment in community behavioral health in more than 50 years.
Section 223 directed the Substance Abuse and Mental Health Services Administration (SAMHSA) to establish criteria for certified community behavioral health clinics (CCBHCs). It also authorized SAMHSA to award planning and demonstration grants to states for the purpose of implementing certification of community behavioral health clinics and developing prospective payment systems to facilitate Medicaid payment for services provided by CCBHCs.
The deadline for states to complete applications for planning grants was August 5. Look for an announcement in October of up to 25 planning grants totaling nearly $25 million that will enable participating states to engage in gathering input from key stakeholders, begin certifying CCBHCs, and to establish a prospective payment system. From the states selected to receive planning grants, up to eight states will be awarded two-year grants to carry out demonstration programs including approved prospective payment systems to facilitate enhanced Medicaid payments to CCBHCs for mental health services beginning in 2017.
In part, the move toward certification of community behavioral health clinics is akin to the move toward accreditation in public health. The criteria for certification were set forth in the request for applications (Appendix II) for state planning grants under six broad requirements related to:
The criteria are intended to ensure that there is not simply an expansion of access to mental health services, but that the improved access is accompanied by improved coordination and quality of care.
For public health departments and related organizations located in states that receive either planning or demonstration grants, there may be opportunities to leverage this standardization and expansion of individual clinical services into collaborations to advance mental health at the population level, for example through screening and preventive interventions and mental health promotion activities. Indeed, CCHBCs may provide some services through formal relationships with “Designated Collaborating Organizations.” Opportunities to connect these efforts to improve systems for community mental health services with broader efforts to restructure, reform, and integrate healthcare and public health systems may also emerge.
This post was prepared by Jill Krueger, J.D., director of the Network for Public Health Law—Northern Region.
The Network for Public Health Law provides information and technical assistance on issues related to public health. The legal information and assistance provided in this document does not constitute legal advice or legal representation. For legal advice, readers should consult a lawyer in their state.
Support for the Network is provided by the Robert Wood Johnson Foundation (RWJF). The views expressed in this post do not necessarily represent the views of, and should not be attributed to, RWJF.