MedicaidAdministrativeHigh impact
MMP 26-29: Certified Community Behavioral Health Clinic (CCBHC) Demonstration Direct Payment Transition
Michigan Medicaid - MDHHS·MI · Psychiatry·Claims & Billing
Effective date
Oct 1, 2025
We identified it
Aug 1, 2026
Summary
Michigan Medicaid updates Certified Community Behavioral Health Clinic (CCBHC) Demonstration requirements effective October 1, 2025. CCBHCs must be certified by MDHHS, enroll with a Type 2 NPI under specialty programs, provide nine core behavioral health services (no prior auth required when medically necessary), and deliver 51% or more services directly rather than through contracted collaborators. The policy establishes new enrollment, certification, eligibility, and service delivery standards for Medicaid, Healthy Michigan Plan, and MIChild beneficiaries.
Action Required
By October 1, 2025: (1) Billing team must verify CCBHC clinic certification status with MDHHS—only certified demonstration sites are eligible for Medicaid reimbursement. (2) Ensure clinic has Type 2 (Organization) NPI specific to CCBHC services and is enrolled in CHAMPS under 'specialty programs' enrollment type with no subspecialty required. (3) Update billing system to eliminate prior authorization requirements for all nine CCBHC core services when medically necessary and patient has qualifying mental health or SUD ICD-10 diagnosis. (4) Configure system to track T1040 HCPCS codes (daily visits) to ensure and document that 51% or more of services are delivered directly by clinic staff rather than through Designated Collaborating Organizations (DCOs)—calculation includes all payer types. (5) Update encounter/service documentation templates to capture mental health or SUD ICD-10 diagnosis; flag that crisis services may be provided without diagnosis but will not generate PPS-1 payment without qualifying diagnosis. (6) Clinical/administrative staff must notify MDHHS-CCBHC-COMPLIANCE@michigan.gov within 7 days of any significant policy, practice, or cost report changes that impact certification. Failure to comply will result in loss of CCBHC provider status and Medicaid reimbursement denial.