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As of: 5/1/26, 7:11 AM
Received: April 30, 2026
Status: Draft
Category: Health Care Professional/Association - Other Health Care Professional
Tracking No. mom-brl7-yoch
Comments Due: April 30, 2026
Submission Type: Web

Docket: CMS-2026-1519
(CMS-10398 #99) Medicaid CCBHC Services SPA Template
Comment On: CMS-2026-1519-0001
(CMS-10398 #99) Medicaid CCBHC Services SPA Template
Document: CMS-2026-1519-DRAFT-0009
Comment on CMS-2026-1519-0001

Submitter Information
Email: [email protected]
Organization: Missouri Behavioral Health Council

General Comment
Re: CMS 10398 #99 (OMB Control No. 0938 1148) — Medicaid Certified Community Behavioral Health
Clinic (CCBHC) Services State Plan Amendment Coverage Template
Docket ID: CMS 2026 1519
The opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) proposed information
collection for the Medicaid CCBHC Services State Plan Amendment (SPA) Coverage Template is
appreciated. This comment is submitted by a behavioral health association that represents Certified
Community Behavioral Health Clinics (CCBHCs).
This association supports CMS’s efforts to streamline the SPA submission process and to ensure consistent
implementation of the new optional Medicaid CCBHC benefit under section 1905(a)(31) of the Social
Security Act. We offer the following comments to promote clarity, reduce unnecessary administrative burden,
and support stable implementation of the CCBHC model.
1. Certification Criteria Versioning and Transition Considerations
The SPA template requires states to assure that CCBHCs meet “the most recent version” of the CCBHC
Certification Criteria and to update certification processes as criteria change. However, the template and
supporting guidance do not address transition periods or the operational and financial impacts of revised
criteria on existing certified clinics.
This state’s CCBHCs operate under prospective payment systems (PPS) that are sensitive to changes in scope,
staffing, and service requirements. In the absence of clear transition policies, revisions to the Certification
Criteria could create uncertainty about compliance timelines, rate adequacy, and the potential for retroactive
application of new requirements. Such uncertainty poses operational and financial risks for clinics that are
already certified and actively delivering services under approved payment methodologies.
Recommendation: CMS should clarify that states may establish reasonable transition periods when updated
Certification Criteria are issued and that payment and compliance expectations tied to new criteria apply
prospectively. Clear federal expectations regarding transition policies will promote program stability and
continuity of care while preserving accountability and fidelity to the CCBHC model.
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2. Clarification of Ongoing Data Reporting Expectations
The Federal Register notice references the ongoing submission of data on service encounters and clinical
outcomes but does not specify minimum requirements or explain how these expectations align with existing
CCBHC reporting obligations. This state’s CCBHCs already report extensively across Medicaid, SAMHSA,
and state data systems as part of both statutory and programmatic requirements. Without additional
clarification, the ongoing data reporting requirement could be interpreted inconsistently across states or result
in duplicative or misaligned data collection efforts that increase administrative burden without providing
meaningful additional value for oversight or program improvement.
Recommendation: CMS should clarify that states are expected to leverage existing CCBHC reporting
frameworks to the greatest extent possible and avoid imposing duplicative or misaligned data collection
requirements through this SPA template. Clear alignment with existing reporting systems will improve
efficiency and reduce administrative burden. Furthermore, CMS should clarify that states may determine
which collection, reporting, and tracking will be included to meet the ongoing data requirement. Additionally,
CMS should further clarify that states determine what data on the provision of services should be submitted.
Clear alignment with existing reporting systems and explicit state discretion will improve efficiency and
reduce administrative burden.
3. State Flexibility for SPA Assurances and Evidence
The template includes required assurances but does not specify what documentation or evidence CMS will
consider acceptable.
Recommendation: CMS should clarify that states determine what evidence is sufficient to support SPA
assurances, provided it reasonably demonstrates compliance. Furthermore, CMS should clarify that states
determine service provider qualifications of service components.
4. Use of the SPA Template
The notice suggests states submitting coverage under section 1905(a)(31) must use this template, even if they
have existing SPA authorities addressing similar requirements.
Recommendation: CMS should clarify that states may continue to rely on existing SPA authorities that meet
statutory requirements.
Respectfully submitted

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