Nov 7 Agenda: changing requirements for social work licenses & community health clinic certification

As of Election Day, we're back in business, with one bill dropped from this agenda.

Thursday, November 7, 2024     9:00 AM

AGENDA:

HB 5371 (Rep. Brabec) Human services; medical services; certified community behavioral health clinics; provide certification and funding for.

HB 5372 (Rep. Phil Green) Human services; medical services; certified community behavioral health clinics; provide certification and funding for.

HB 5785 (Rep. Brabec) Health occupations; psychologists; requirements for practice by limited licensed psychologist; modify.

OR ANY BUSINESS PROPERLY BEFORE THIS COMMITTEE

Certified Community Behavioral Health Clinics (CCBHCs) were instated in Michigan under the Protecting Access to Medicare Act of 2014 (PAMA). The MDHHS was then authorized by the state to publish criteria for clinics to be certified as CCBHCs. The purpose of this act was to provide services to individuals seeking mental health or substance abuse treatment, regardless of their ability to pay. House Bills 5371 and 5372 both intend to alter the payment and building criteria for these clinics. 

https://www.legislature.mi.gov/documents/2023-2024/billanalysis/House/pdf/2023-HLA-5371-BC2B1A33.pdf

House Bill 5371 would require DHHS to develop a prospective payment system for funding CCBHCs under the medical assistance program. The system would have to comply with all federal payment methodologies. DHHS would have to submit to the federal Centers for Medicare and Medicaid Services any approval request necessary for a Medicaid 1115 waiver. The system would have to be implemented (subject to approval) before January 1, 2028.

Prospective payment system would mean a payment methodology that funds, in advance, a CCBHC for the anticipated costs of carrying out the direct and indirect clinical and administrative activities required of CCBHCs.

The bill also would require DHHS to certify as a CCBHC a community mental health center licensed by DHHS that adheres to all federal CCBHC requirements.

DHHS would have to develop and issue rules to implement the bill

House Bill 5372 would do all of the following:
• Prohibit the state government from implementing a policy that contradicts or interferes with the implementation of federal definitions or requirements for a CCBHC.
• Require the state government to develop a process of determination for additional CCBHC sites in specific geographic regions that must comply with federal CCBHC requirements.
• Require the state government to continue to participate with the federal government to implement CCBHCs. The bill states, “To opt out of participation, there must be a vote of the legislature.”

FISCAL IMPACT:
The state is currently participating in a federal demonstration program to provide Medicaid reimbursements for enrolled CCBHC sites through September 30, 2027. The FY 2024-25 DHHS appropriations for supplemental CCBHC costs total $525.9 million Gross ($128.4 million GF/GP), which, according to DHHS, will support 33 CCBHCs located in 30 counties and an additional three locations within those 30 counties starting January 1, 2025.

Since FY 2021-22, the program has expanded based on available appropriations. House Bill 5371 would instead require DHHS to certify licensed community mental health centers as CCBHCs if the health center adheres to all federal CCBHC requirements. It is unknown how many additional CCBHC sites would enroll, but each additional CCBHC costs, on average, approximately $14.5 million Gross ($3.5 million GF/GP).

Additionally, once the current federal demonstration program ends, states can decide to continue the CCBHC program, but at a lower federal reimbursement rate. Under House Bill 5372, that continued participation would be required. The lower federal reimbursement rate, based on the FY 2024-25 FMAP rates, would cost the state approximately $90.0 million annually.

A number of CCBHCs are community mental health services programs (CMHSPs), so a local CMHSP could receive additional Medicaid reimbursements for providing CCBHC services.

The program costs 525.9 million dollars per year, with the expected costs of an additional 15 million per CCBHC. While mental health has been a serious issue especially in inner city and rural communities, we should consider how far the 15 million dollars per clinic is going to improve the lives and overall health of our population.