Becoming a CCBHC: Staffing Requirements

Welcome to the inaugural post of our six-part blog series, unraveling the intricacies of becoming a Certified Community Behavioral Health Clinic (CCBHC). In this series, we will navigate through the essential requirements outlined by the Protecting Access to Medicare Act (PAMA) to shed light on the path toward achieving CCBHC certification.

CCBHCs play a crucial role in delivering comprehensive behavioral health services, and to achieve this, strict staffing requirements are mandated by the PAMA. Ensuring that staff possesses diverse disciplinary backgrounds, necessary licensing and accreditation, and cultural and linguistic training is imperative for the success of CCBHCs.

A cornerstone of the staffing requirements is the completion and documentation of a community needs assessment along with a staffing plan. These documents must be updated at least every three years to ensure that the CCBHC aligns its staffing with the evolving needs of the community it serves. The size and composition of the staff should be directly correlated with the findings of the community needs assessment, emphasizing the importance of tailoring services to meet the specific demands of the community.

In establishing a robust management team, the inclusion of a Chief Executive Officer (CEO) and a Medical Director is mandatory. Interestingly, the size of the clinic may allow for both roles to be filled by a single person, providing flexibility in meeting these key positions. Maintaining adequate liability/malpractice insurance is a non-negotiable requirement to safeguard both staff and patients in the delivery of behavioral health services.

Licensure and credentialing of providers form another critical aspect. All providers within the CCBHC must operate in accordance with the laws governing their respective state licenses, certifications, or registrations. This ensures a high standard of care and compliance with state regulations. Moreover, the staff must include a medically trained provider with the ability to prescribe and manage medications under state law, addressing a fundamental need for comprehensive care.

Cultural competence and ongoing training are integral components of the staffing requirements. A comprehensive training plan must be in effect, aligning with the National Standards for Culturally and Linguistically Appropriate Services (CLAS). Regular assessments of the skills and competence of providers are mandatory, ensuring that the staff is well-equipped to serve a diverse patient population. In-service training, accompanied by written policies and documentation, ensures continuous improvement in the delivery of culturally sensitive care.

Linguistic competence is highlighted with a commitment to providing meaningful access to language assistance and interpretation/translation services for those in the community with Limited English Proficiency (LEP). Accessibility considerations extend to auxiliary aids for individuals with disabilities, emphasizing an inclusive approach to service delivery. Vital documents, available both in print and online, adhere to accessibility standards, treating all interactions as Protected Health Information (PHI).

In essence, the staffing requirements outlined for CCBHCs by PAMA underscore the significance of a well-rounded, culturally sensitive, and licensed workforce. By addressing the needs of the community, maintaining high standards of care, and ensuring accessibility for all, CCBHCs can fulfill their vital role in providing behavioral health services that meet the diverse needs of the populations they serve.

General Staffing Requirements

• Complete and document a community needs assessment along with a staffing plan. Both should be updated at least every 3 years.
• The size and composition of all staff should appropriately correlate to the community needs assessment.
• A CEO and a Medical Director must be included as part of the management team. Size may allow for both roles to be filled by the same person.
• The CCBHC must maintain adequate liability/malpractice insurance.

Licensure and Credentialing of Providers

• All providers must have, maintain, and operate in accordance with laws that govern their respective state licenses, certifications, or registrations.
• Staff must include a medically trained provider who can prescribe and manage medications under state law.

Cultural Competence and Other Training

• A training plan must be in effect that satisfies and include requirements of the state behavioral health authority and any accreditation standards the state requires.
• The training must be aligned with the National Standards for Culturally and Linguistically Appropriate Services (CLAS)
• Regular assessments must be conducted around the skills and competence of providers
• In-service training should be provided as necessary with written policies along with written accounting of the training.

Linguistic Competence

• Those in the community with Limited English Proficiency (LEP) must be provided meaningful access to language assistance and interpretation/translation services.
• Auxiliary aids for those with disabilities must be readily available.
• Vital documents must be available on paper and online with similar accessibility as the above, and all interactions must be treated as Protected Health Information (PHI).

Stay tuned for the upcoming blogs where we will delve into accessibility, care coordination, service scope, quality reporting, and the organizational foundations that define the roadmap to becoming a Certified Community Behavioral Health Clinic.