MedicaidAdministrativeHigh impact
BT2026151: IHCP clarifies billing guidance for providers enrolled as a CCBHC or CMHC
Indiana Medicaid (IHCP)·IN · Psychiatry·Reimbursement
We identified it
Sep 11, 2026
Summary
IHCP clarifies NPI usage and billing requirements for community mental health centers (CMHC) and certified community behavioral health clinics (CCBHC) with multiple service locations. Providers must use the correct NPI based on service type and location, include accurate service location addresses and place of service codes on all claims, and follow specific submission rules to ensure proper identification of where services are delivered.
Action Required
IMMEDIATE ACTION REQUIRED: Billing team must implement the following changes for all CCBHC and CMHC providers:
1. CCBHC PROVIDERS (All locations enrolled as CCBHC):
- Update billing system logic to automatically select the provider's registered CCBHC NPI (field 33a on CMS-1500) for ALL services within CCBHC scope of services delivered within the designated CCBHC geographic county coverage area
- For services outside CCBHC scope (residential services, AMHH, BPHC, CMHW) or services outside CCBHC geographic coverage area: use the CMHC NPI instead
- Flag: Do NOT bill multiple claims on the same date of service for different service locations at CCBHC - these will be denied
2. CCBHC PROVIDERS (Mixed locations - some CCBHC, some CMHC only):
- Route services within ANY CCBHC location's designated geographic coverage area through CCBHC NPI if service is in CCBHC scope
- Route services outside ALL CCBHC geographic coverage areas through CMHC NPI (for both CCBHC and non-CCBHC locations)
3. ALL CCBHC/CMHC CLAIMS - CRITICAL REQUIREMENTS:
- Include the billing provider's service location address in field 33 on CMS-1500 (or equivalent electronic field)
- Include a valid CMS Place of Service (POS) code matching the actual location where service was rendered
- For off-site services (e.g., in-home): Use originating clinic NPI/address in field 33, but enter the EXACT service location address in field 32 (or Service Facility Location ID for electronic claims). Inaccurate addresses will result in claim denial.
- Do NOT list multiple locations in field 32 on a single claim
4. VERIFICATION AND TESTING:
- Review current claim submissions to identify any incorrectly billed claims using wrong NPI for service type/location combination
- Contact providers with mixed CCBHC/CMHC locations to obtain their designated CCBHC geographic coverage area boundaries
- Test billing system rules to ensure NPI routing logic is correct before processing claims
5. PROVIDER COMMUNICATION:
- Notify all CCBHC and CMHC providers of these requirements
- Distribute the CCBHC encounter code list (available from myersandstauffer.com) to providers for reference
- Remind providers to verify service location ZIP Code+4 accuracy for off-site claims
CONSEQUENCES: Claims submitted with incorrect NPI, missing location address, invalid POS code, or inaccurate off-site location details will be denied. Multiple same-date-of-service CCBHC claims for different locations will be denied.