PRA Comments on Community Behavioral Health Clinics

In March, Congress passed into law the Protecting Access to Medicare Act of 2014 (PAMA), and PRA was pleased that Section 223 included a demonstration that would create Community Behavioral Health Clinics (CBHCs) that would pilot the delivery of integrated health and behavioral health services.  This demonstration was based on the “Excellence Act,” of which PRA had been a supporter and on which many of our leadership and membership had lobbied Congress for several years. 

We were then pleased to see that the Substance Abuse and Mental Health Administration (SAMHSA) has proceeded quickly to begin implementation of Sec 223 and held an all-day listening session for interested stakeholders on November 12, in which PRA participated. In addition, SAMHSA solicited written comments, and PRA took the opportunity to go on the record with SAMHSA to inform their guideline development process.  Key points emphasized by PRA included: 

· Psychiatric Rehabilitation services must be an essential component to all Section 223 demonstrations.

· Peer Support services must be included and valued in each demonstration.

· On Quality and Reporting:

o   Quality and performance measures should focus on key indicators of recovery and not merely on the reduction of symptoms for individuals.

o   Data collection efforts should draw on reporting metrics and mechanisms that are already in place, wherever possible.

o   PRA asks for a seat at the table to discuss the metrics by which the success of the Section 223 programs will be judged.

o   Quality and reporting metrics should be finalized with sufficient lead time to allow those wishing to apply to participate to build a system around achievement of the quality benchmarks.

· PRA asks that both non-profit organizations and local government organizations be permitted to participate in the Section 223 demonstration

· SAMHSA should not create staffing requirements that limit staffing only to those with clinical licenses. Rather, we encourage consideration of models that utilize a broad array of qualified individuals who have demonstrated their qualifications through experience and targeted training and encourage recognition of the Certified Psychiatric Rehabilitation Practitioner (CPRP) credential.

PRA looks forward to working with our members, leaders, and policymakers to bring this important demonstration forward in 2015 and beyond.  To join the PRA Public Policy Task Force to work on these issues with us, please contact please email PRA Info or call 703-442-2078