GAO Says CCBHC Program’s Effectiveness Unclear Due to Vague Rules, Data Limitations

Expanding the Certified Community Behavioral Health Clinic (CCBHC) program has been a top priority of behavioral health stakeholders for years. 

Proponents often make their case with data that suggests the model saves money and improves outcomes in the long run. However, a new report from the U.S. Government Accountability Office (GAO) puts forth another claim: It says preliminary analyses of the Medicaid demonstration offer an incomplete picture of the model’s effectiveness due to data limitations and the ambiguity of certain program rules. 

The CCBHC Medicaid demonstration was born in 2014, when Congress approved the two-year program in an effort to improve mental health services in eight states. Since then, the program has been extended to September 2023 and expanded into additional states. 


CCBHCs in the program get higher Medicaid payments in return for offering a certain set of integrated addiction and mental health services to the under- and uninsured. They must also meet criteria related to timeliness, reporting, staffing and coordination with social services, criminal justice and education systems.

Providers in non-demonstration states can also become CCBHCs by applying for dedicated SAMHSA grants. The only difference is that the grant funding is capped and not provided through Medicaid. Plus, it runs out after a set amount of time, usually two years.

GAO findings

To date, the Department of Health and Human Services (HHS) has issued three annual reports assessing the initial CCBHC Medicaid demonstration period, which ran from 2017 to 2019 and looked at 66 participating CCBHCs across eight states. It’s also set to publish a fourth later this year.


The reports look at access, costs and quality. However, the GAO says HHS’s findings aren’t necessarily indicative of how well the program works due to problems with program data. 

“For example, most clinics hadn’t reported quality measures before, so there is no baseline data available for measuring progress,” the GAO wrote in its report. “As another example, HHS didn’t tell states which services to provide under the program — a design decision that makes uniform assessments more difficult.”

In addition to the lack of baseline data and uniform program design, GAO said that lack of comparison groups and lack of detail on Medicaid encounters also make progress hard to measure. 

“HHS allowed states to identify different program goals and target populations, and to cover different services,” the authors of the GAO report wrote. “HHS also did not require states to use standard billing codes and billing code modifiers it developed. The lack of standardization across states limited HHS’s ability to assess changes in a uniform way.” 

The GAO said such limitations will continue to complicate HHS’s efforts to assess the demonstration going forward.