PRA Crosswalk of Changes

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GEN IC #99 – CMS 0938-1148 Crosswalk of Changes
2026 Template Prior to
Comment
CCBHC Assurances

2026 Template Changes
after Comment
CCBHC Mandatory
Assurances – added
“Mandatory”

Checkbox: “The state has
a process to ensure that
CCBHC organizations will
meet the most recent
version of the CCBHC
Certification Criteria…”

Checkbox: “The state has
a reasonable process to
ensure that CCBHC
organizations will meet
the most recent version of
the CCBHC Certification
Criteria…”
New Checkbox and Text
Box added: Optional
CCBHC Services
checkbox and descriptive
text box

No content

No content

New Checkbox and Text
Box added: Coverage
Limitation
checkbox and descriptive
text box

Type of Reason for Change
Change
Rev
Clarifies mandatory
assurances and services
versus optional CCBHC
services states may provide in
addition to the mandatory
services – internal revision.
Rev
Adds “reasonable” in
response to comments
received to emphasize state
consideration for providers
who will need to make
changes when updates are
made to the criteria.
Rev
Adds a new checkbox and text
box for states to add
information about optional
services they may elect to
provide through this benefit
based on comments received.
Rev
Adds a new checkbox and text
box for states to add
information about coverage
limitations – internal revision
in consideration for a
dedicated space rather than
using the existing general
additional information box.

Burden
Change
No

No

No

No