CCBHCs Still ‘Under Threat’ Despite Some Federal Support

This is an exclusive BHB+ story

Despite rumors about potential cutbacks, Certified Community Behavioral Health Clinics (CCBHCs) received favorable provisions in the One Big Beautiful Bill Act earlier this summer. CCBHCs will be exempt from cost-sharing provisions – preserving accessibility for patients – and rural locations may be eligible for a new pool of federal funding.

Three years after legislation broadened the nationwide expansion of CCBHCs, leaked documents from the Trump administration in April fueled fears about a possible end to the CCBHC program or the elimination of its funding entirely.

These centers provide access to mental health and substance use care for around 3 million patients nationwide and serve as a critical entry point to care for low-income and at-risk populations. So, the change in tune of where CCBHCs land among federal priorities was a welcome one, experts told Behavioral Health Business.

“I think it’s emblematic of the continued bipartisan support that CCBHCs have now had for over a decade,” Rebecca Farley David, senior advisor on public policy and special initiatives at the National Council for Mental Wellbeing, told BHB. “I think policymakers realize that CCBHCs are an important solution to many of the challenges facing our system, and are working to make sure that CCBHCs are embedded formally within some of the programs that they are designing to provide support to the field.”

The National Council for Mental Wellbeing is a membership association representing more than 3,400 mental health and substance use treatment organizations. It advocates for policy and industrywide change.

Still, CCBHCs are not entirely out of the woods. These facilities will still feel the impact of Medicaid cuts triggered by the signing of the One Big Beautiful Bill Act. Cuts to Medicaid and changes to the Affordable Care Act (ACA) and health insurance marketplaces could result in nearly 17 million or as high as 20 million losing their health insurance coverage over the next nine years, according to the Congressional Budget Office.

CCBHCs are specifically designed to serve uninsured and Medicaid populations, and they receive reimbursement for the services they provide. While these entities have been shielded by cost-sharing provisions and are eligible for new rural funding, the ongoing operational landscape given Medicaid cuts remains uncertain.

“Cutting CCBHC funding would result in these patients seeking care in institutions, hospitals or emergency rooms – places where capacity is already limited and where comprehensive, quality mental health services often do not exist,” Dr. Megan Cole, associate professor of population medicine at Harvard Medical School and director of the Harvard Pilgrim Health Care Institute’s division of health policy and insurance research, said. “Other provisions of the OBBB – particularly the unprecedented cuts to Medicaid – will have similar devastating consequences both to patients and to the mental health care system as a whole, including CCBHCs.”

For some, even though the One Big Beautiful Bill solidified some aspects of CCBHCs operationally, the earlier leaked documents that had the facilities on the chopping block created lasting hesitancy. 

The University of Rochester’s Brighter Days Pediatric Mental Health Urgent Care Center is part of the CCBHC program. It has only been operational for about a year, but Dr. Michael Scharf, psychiatrist-in-chief and head of child and adolescent psychiatry at the center, has been closely monitoring developments in Washington, D.C.

“The leaked messages in April seemed to indicate that the administration intended to eliminate CCBHCs… and that’s how we’re operating right now, that’s probably the most important variable in the coming months, the longer-term outlook,” Scharf told BHB during a previous interview. “If there are less services because of cuts… we do expect people to utilize more emergency room services … it’s an unfortunate downstream effect of cuts that are of the magnitude being described.”

The longer-term outlook for CCBHCs, as it currently stands, still entails some uncertainty and changes continue to be somewhat of a moving target, despite codifying CCBHCs deeper into Medicaid. A continuing appropriations bill introduced to the House on Sept. 18, aims to divert a government shutdown and would avoid a funding cliff for CCBHCs by extending funds through the end of October while Congress finalizes the FY26 budget.

“The questions that are really on the table are around the way they’re structuring funding, the provider tax is a piece of that,” Kristine Toppe, vice president of state affairs at the National Committee for Quality Assurance (NCQA), told BHB. “There is an opportunity for them to kind of weigh in on the rural health money. That is really the challenge between now and year-end, because that’s the timeline for them to apply for that funding. I think that those are the kinds of things that CCBHCs should be focused on.”

But state-by-state differences in how they apply Medicaid funding and any changes that might be made in the finalization of the FY26 budget may create other barriers for CCBHCs, Toppe explained.

CCBHC operators and state leaders should prioritize ways to demonstrate their clinic’s value, Toppe advised, including the “use of their accreditation results for the maximum value to the state and to its members.”

Getting creative with how CCBHCs use and apply existing funds will also be critical, she said.

Lynn Sutfin, a public information officer for Michigan’s Department of Health and Human Services, told BHB that the state is among the ones “committed to sustaining and expanding access to behavioral health services through the CCBHC model and beyond.”

Sutfin expects that amid the uncertainties, the “states that continue to invest in CCBHCs will be better positioned to meet residents’ behavioral health needs.”

However, given that the Substance Abuse and Mental Health Services Administration (SAMHSA), which provides federal grant funding to CCBHCs, has been consolidated into a new entity, the future of grants as part of this critical funding is somewhat uncertain.

“The continuation versus discontinuation of SAMHSA … could significantly affect the administration of the program,” Cole told BHB. “Sustaining federal funding levels for CCBHCs, regardless of which agency oversees the program, will also be critical – but this is not yet known. It’s also important to remember that even if CCBHC funding levels are sustained, federal cuts to other programs that support behavioral health mean that CCBHCs will face higher demand and higher levels of acuity from patients, without commensurate resources to offset these needs.”

Farley David echoed this, noting that the biggest misconception about CCBHCs is that the program is still in its pilot phase. However, since its inception in 2014, the CCBHC program has proven its viability, which she said should be sufficient to establish more permanency in funding and support at the federal level for these clinics.

“Continued funding for the CCBHC grants is really critical,” Farley David said. “Those grants have been a crucial springboard for implementation… All these years into the [CCBHC program] demonstration, this is a proven model. At this point, we have a lot of impact data to show how this model has benefited states and communities.”

Since CCBHCs are an optional state program, should funding become too tight to sustain operations, these entities may continue to be “under threat,” Cole added.