A CCBHC does not bill per service. Under PPS-1 it collects one payment per patient per day, at a rate equal to its own allowable annual costs divided by its own annual visit-days.1 medicaid.gov
That single sentence is the entire revenue model, and it is why a Certified Community Behavioral Health Clinic’s finance function looks nothing like a fee-for-service behavioral health practice’s. The rate is clinic-specific. It is built from a cost report the clinic files itself. And a clinic that gets its cost report wrong has locked in the error for a year, sometimes three.
By demonstration year four, PPS-1 daily rates ran roughly $188 to $389 and PPS-2 monthly rates ran $706 to more than $872, depending on state and clinic.3 aspe.hhs.gov
Four methods, two units of payment
States pick one methodology and apply it to every CCBHC in the state, for both fee-for-service and managed care. The state cannot change it mid-demonstration-year without CMS approval, and it cannot pay CCBHCs anything for in-scope services outside the PPS, outlier and quality bonus structure.1 medicaid.gov
| Method | Unit | Special population rates | Crisis rates | Outlier payments | Quality bonus |
|---|---|---|---|---|---|
| CC PPS-1 | Daily | — | — | — | Optional |
| CC PPS-2 | Monthly | Optional | — | Required | Required |
| CC PPS-3 | Daily | — | Required | — | Optional |
| CC PPS-4 | Monthly | Optional | Required | Required | Required |
Source: CMS Section 223 CCBHC PPS Guidance, February 2024, Table 1.1 medicaid.gov
PPS-1 is the FQHC-style option: one fixed daily amount for every CCBHC service delivered that day, regardless of intensity. PPS-2 pays once for any month in which the clinic delivers at least one qualifying service, and a state may count up to 12 monthly visits per person per year. PPS-3 and PPS-4 are the 2024 additions, layering separate crisis-service rates on the daily and monthly bases.1 medicaid.gov2 medicaid.gov
Preference among the newest cohort is lopsided. Seven of the ten states added in 2024 chose PPS-1, Maine and Rhode Island chose PPS-2, and New Hampshire is the only state to have selected PPS-3 or PPS-4 at all.3 aspe.hhs.gov
What a cost report actually drives
Everything. The rate formula has two inputs — allowable cost and visit count — and the cost report produces both.
Costs must be sorted into direct staff, direct other, facility and administrative overhead, non-CCBHC costs, and costs Medicaid will not reimburse. A psychiatrist who treats patients and also runs a department gets split across two cost centers. Inpatient care, residential treatment, room and board and other non-ambulatory expenses come out. So does any satellite facility established after 1 April 2014. So does the shortfall on uncompensated care — the clinic is required to serve people who cannot pay, and forbidden from putting that gap in the rate.1 medicaid.gov
Costs of Designated Collaborating Organizations go in, and DCO encounters count as CCBHC encounters for PPS purposes. That is a real lever: a clinic that formalizes a partner relationship as a DCO pulls those costs and visits into its own rate calculation.1 medicaid.gov
The filing calendar is tight. CCBHCs submit the annual cost report to the state no later than six months after the demonstration year ends. States then have until nine months after year end to pass it to CMS — whether or not they rebased anything.1 medicaid.gov
A clinic that undercounts allowable cost is not disputing a claim. It is setting the price of every encounter it will bill for the next twelve months.
Rebasing is the discipline, and there is no true-up
States update rates every year, by one of two routes: trend the existing rate forward by the Medicare Economic Index, or rebase it against actual cost and visit data. Rebasing is mandatory for demonstration year three using DY2 data, and at least once every three years after that.1 medicaid.gov
What does not happen is a settlement. Annual reconciliation to actual cost is prohibited. If a state pays a CCBHC more than the clinic’s actual cost, it cannot claw the difference back, adjust the final rate retrospectively, or net it out of next year’s rate.1 medicaid.gov
That asymmetry defines the risk. Overperformance on cost control is kept. Undercosting is carried until the next rebase.
The direction of travel is not automatic either. Average PPS-1 rates fell between DY1 and DY2 in Minnesota ($433 to $383), Nevada ($225 to $187) and New York ($318 to $271), inflation adjusted.3 aspe.hhs.gov Rebasing corrects in both directions.
| State | Model | Sample rate |
|---|---|---|
| Alabama | PPS-1 | $342.68 / day |
| Illinois | PPS-1 | $267.21 / day |
| Indiana | PPS-1 | $227.70 / day |
| Iowa | PPS-1 | $264.86 / day |
| Kansas | PPS-1 | $335.00 / day |
| New Mexico | PPS-1 | $335.45 / day |
| Vermont | PPS-1 | $194.00 / day |
| Maine | PPS-2 | $738.00 / month |
| Rhode Island | PPS-2 | $1,166.00 / month |
| New Hampshire | PPS-3 | $316.90 / day standard; $2,082.98 ARP mobile crisis |
Sample rates from state demonstration applications, not final paid rates. Source: ASPE Report to Congress, 2025, Exhibit VI.2.3 aspe.hhs.gov
Quality bonus payments: optional on daily, required on monthly
QBPs are optional under PPS-1 and PPS-3 and required under PPS-2 and PPS-4.2 medicaid.gov Where a state runs a QBP program, CMS requires the first seven “comparative” measures. Those include depression remission at six months, time to services, follow-up after hospitalization for mental illness in adult and child versions, and initiation and engagement of SUD treatment.1 medicaid.gov
Two design rules matter operationally. A clinic must attain or exceed a state-defined threshold to be paid, and no payment may be made for reporting alone. States can tier payments by level of achievement, weight them by measure, or set thresholds as year-over-year improvement rather than an absolute number.1 medicaid.gov
The money is real where states use it. CMS’s own worked example runs tiered bonuses expressed as a percentage of the clinic’s CCBHC claims for the performance year, with a maximum equivalent to 15% of those claims.1 medicaid.gov Uptake is another matter: of the seven PPS-1 states in the 2024 cohort, only Iowa planned to offer QBPs from the outset.3 aspe.hhs.gov
One accounting detail is easy to miss. When the PPS rate is calculated, the QBP is not treated as a revenue offset against cost.1 medicaid.gov
Why the revenue cycle is structurally different
A fee-for-service behavioral health biller optimizes the claim: code selection, units, modifiers, medical necessity, appeal. Under a CCBHC PPS, none of those move the payment amount. The rate is fixed before the year starts, and the same amount arrives whether the client received a 15-minute check-in or a full day of team-based care.
Three consequences follow. Coding accuracy stops driving revenue and starts driving next year’s rate, through the visit counts and cost allocations in the cost report. Volume and cost move in opposite directions — more visit-days spread the same cost base across a larger denominator, which cuts the rate at the next rebase. And the highest-value finance work shifts from denial management to cost capture, because the only lever on the rate is what the clinic can defend as an allowable CCBHC cost.
There is one FQHC wrinkle worth knowing. A clinic that is both an FQHC and a demonstration CCBHC bills the CCBHC PPS whenever it delivers any of the nine statutory services. It earns a separate FQHC payment only if it also delivers a distinct non-CCBHC FQHC service in the same encounter. Where every service in the encounter is both, the state pays the higher of the two rates.1 medicaid.gov
Where the program stands
Thirty states have now been selected for the section 223 demonstration.5 medicaid.gov On 28 May 2026, HHS named the second BSCA cohort — Alaska, Colorado, Hawaii, Louisiana, Maryland, Mississippi, Montana, North Dakota, Washington and West Virginia — with demonstrations starting between 1 July 2026 and 1 July 2027.6 hhs.gov4 medicaid.gov More than 500 CCBHCs now operate across 46 states, the District of Columbia and Puerto Rico, counting clinics funded by SAMHSA expansion grants alongside demonstration and state plan clinics.6 hhs.gov
The demonstration is no longer the only route. Section 209 of the Consolidated Appropriations Act of 2024 created a permanent CCBHC state plan option at section 1905(a)(31) of the Social Security Act.5 medicaid.gov The demonstration for the six remaining original states was authorized through 30 September 2025, and all six planned to continue the model under state plan authority.3 aspe.hhs.gov The PPS mechanics above increasingly describe a standing Medicaid benefit, not a time-limited pilot.
What follows the enhanced federal match is the open question. Oklahoma flagged the state-share increase after the demonstration FMAP ends as a sustainability risk, and Missouri’s legislature appropriated general revenue to cover it.3 aspe.hhs.gov The rate methodology survives the transition. Whether the funding does is a state-by-state answer.
Sources & notes
- Centers for Medicare & Medicaid Services.Section 223 CCBHC Demonstration — Prospective Payment System (PPS) Guidance, updated February 2024. Retrieved Aug 23, 2026.
- Medicaid.gov.CCBHC Prospective Payment System (PPS) & Quality Bonus Payments (QBPs). Retrieved Aug 23, 2026.
- HHS Office of the Assistant Secretary for Planning and Evaluation (Mathematica, RAND, AHP).Certified Community Behavioral Health Clinic Demonstration Program: Report to Congress, 2025. Retrieved Aug 23, 2026.
- Medicaid.gov.Certified Community Behavioral Health Clinic (CCBHC) Demonstration — news and updates. Retrieved Aug 23, 2026.
- Medicaid.gov.CCBHC Demonstration Background. Retrieved Aug 23, 2026.
- U.S. Department of Health and Human Services.HHS Welcomes 10 New States into CCBHC Medicaid Demonstration Program. Retrieved Aug 23, 2026.
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