CCBHC Staffing Requirements: Who a Certified Community Behavioral Health Clinic Must Employ

A Certified Community Behavioral Health Clinic is a clinic certified by its state as a CCBHC, or that has attested to SAMHSA as part of the SAMHSA CCBHC Expansion grant program.

Certification runs for no longer than three years before recertification or a new attestation, so the staffing plan you certify with is on a renewal clock from day one.

To qualify at all, a clinic must be a nonprofit organization, part of a local government behavioral health authority, or an IHS/tribal or urban Indian organization entity.

Certification tests the clinic against a defined service array of nine required services:

• crisis services
• screening, assessment and diagnosis
• person- and family-centered treatment planning
• outpatient behavioral health services
• outpatient primary care screening and monitoring
• targeted case management
• psychiatric rehabilitation
• peer and family supports
• intensive community-based care for armed forces members and veterans

Staffing is the first of the six program areas the criteria are grouped into: a staffing plan driven by a local needs assessment, plus licensing and training.

SAMHSA released the updated 2023 CCBHC Certification Criteria in March 2023, and most CCBHCs had to come into compliance by July 1, 2024 — though clinics and states are often on different implementation deadlines.

The criteria PDF was updated in August 2025 to align with relevant administration policies, so a file dated 2023 can still be the current version.

The program has also spread unevenly, which matters for whether this build is on your roadmap at all.

The Section 223 CCBHC Medicaid Demonstration started in 2017 with 67 CCBHCs in eight states, paid through a prospective payment system for the nine required services.

Per SAMHSA's map (page updated July 6, 2026), the demonstration states are Alabama, Illinois, Indiana, Iowa, Kansas, Kentucky, Maine, Michigan, New Hampshire, New Mexico, Rhode Island and Vermont, and ten more — Alaska, Colorado, Hawaii, Louisiana, Maryland, Mississippi, Montana, North Dakota, Washington and West Virginia — were approved to launch on July 1, 2026.

Other routes exist alongside the demonstration.

Pennsylvania withdrew from it in 2019 and Nevada moved its CCBHC program out of the demonstration into its permanent state Medicaid program in 2023; independent state CCBHC programs are funded through Medicaid state plan or section 1115 authority rather than the Section 223 demonstration, and the 2024 Consolidated Appropriations Act established a permanent state option for CCBHC services in Medicaid.

SAMHSA counts over 500 CCBHCs operating across those routes, and its map lists Delaware, South Dakota and South Carolina as the states with no CCBHCs — check where your state stands before you plan headcount against certification.

Criterion 1.a.1 is the anchor: a community needs assessment and a staffing plan responsive to it must be completed before certification.

Both must be updated regularly, but no less frequently than every three years — the assessment and the plan are standing documents with a renewal clock, not a one-time application exhibit.

What the plan has to satisfy is set above the federal floor.

The staffing plan must meet the requirements of the state behavioral health authority and any accreditation standards the state requires, and the criteria say certifying states should specify which staff disciplines they will require as part of certification.

The discipline list you actually hire to is therefore your state's, not the federal example list — your state behavioral health authority's CCBHC page is the first document to open, before any job description gets written.

Two more staffing criteria are easy to miss.

Criterion 1.a.4 requires liability/malpractice insurance adequate for the staffing and scope of services provided, which turns every discipline you add and every service you launch into an insurance conversation.

And providers must hold all state-required licenses or certifications, while staff working toward licensure may be used only if they receive the supervision applicable state laws require — clinicians working toward licensure are allowed in the build, but the supervision structure around them is not optional.

Both requirements have employer-side coverage: malpractice insurance for employed clinicians covers the policy decisions, and credentialing new clinicians covers the license verification behind the licensure requirement.

Criterion 1.a.3 sets the management floor: at a minimum, the management team must include a CEO or equivalent/Project Director and a psychiatrist as Medical Director.

The Medical Director need not be a full-time employee of the CCBHC, and depending on the size of the clinic, both positions may be held by the same person.

A part-time medical directorship and a combined leadership role in a smaller clinic are both within the criteria as written.

If the clinic is unable to hire a psychiatrist after reasonable efforts, the criteria allow a fallback: a medically trained behavioral health professional who can prescribe and manage medications independently under state law may serve as Medical Director, and the CCBHC must then obtain psychiatric consultation regarding behavioral health clinical service delivery.

Whether a given clinician counts as prescribing "independently" — a psychiatric nurse practitioner, for example — is decided by your state's practice-authority law, so confirm the state question before you rest the medical director role on a non-psychiatrist.

Prescribing capacity is a named requirement beyond the director's chair, too.

The CCBHC must have, employed or by formal arrangement, a medically trained provider who can independently prescribe under state law, including buprenorphine and other FDA-approved medications used to treat opioid, alcohol and tobacco use disorders — methadone is not included unless the CCBHC is also an Opioid Treatment Program.

The clinic must also have staff, employed or under contract, who are licensed or certified substance use treatment counselors or specialists.

And if the Medical Director is not experienced in treating substance use disorders, the CCBHC must have experienced addiction medicine physicians or specialists on staff, or arrangements for addiction-medicine consultation.

Everything else on the staffing list is a menu, not a mandate.

The criteria enumerate example staff types — psychiatrists, nurses, licensed clinical social workers, licensed mental health counselors, psychologists, marriage and family therapists, occupational therapists, case managers, peer specialists/recovery coaches, licensed addiction counselors, family peer specialists, medical assistants and community health workers — as a combination the clinic draws on, not a required roster, and they set no staff-to-client ratios.

Which disciplines are actually required is your certifying state's call.

Two items on the example list map straight to required services.

Case managers line up with targeted case management, and peer specialists and family peer specialists with peer and family supports — both are among the nine required services, so those encounters have to be delivered by someone, whether your employees or a Designated Collaborating Organization's.

If you are scoping the peer hire, hiring peer specialists covers the role; case managers have their own hiring hub.

And when the search is for the psychiatrist chair itself, the psychiatrist hiring hub is the starting point.

A Designated Collaborating Organization (DCO) is an entity that is not under the CCBHC's direct supervision but is engaged in a formal relationship with the CCBHC — a contract, MOA or MOU — to deliver one or more required services, or elements of them.

Forming one does not lower the bar: the DCO's services must meet the CCBHC criteria.

How far you can lean on DCOs is capped.

The CCBHC must deliver directly the majority — 51% or more — of encounters across the required services, excluding crisis services, rather than through DCOs.

And the criteria define what "directly provides" means: employees or contract employees within the management structure and under the direct supervision of the CCBHC deliver the service.

Three hiring consequences follow.

First, a DCO's clinicians are not your employees and do not build your direct-delivery share — a plan that hands most encounters to partner organizations fails the arithmetic no matter how good the partners are.

Second, a contract clinician you manage inside your structure counts as direct provision, which is what makes part-time and contracted coverage workable within the criteria.

Third, crisis services sit outside the 51% calculation: criterion 2.C requires crisis management services available and accessible 24 hours a day, seven days a week, delivered directly or through a DCO.

Run the arithmetic before you sign any partnership: encounters by service, who delivers each, and whether the directly delivered share still clears 51% once crisis encounters are excluded.

The DCO model lets you cover a required service you cannot yet hire for — it does not let you skip building the core.

Training is where the staffing criteria become concrete and auditable, and it runs on two tracks.

At orientation and at reasonable intervals thereafter, the CCBHC must provide training to all direct-contact employed and contract staff on:

• evidence-based practices
• cultural competency
• person- and family-centered recovery-oriented planning
• trauma-informed care
• continuity of operations
• primary-care integration
• co-occurring disorders

At orientation and annually thereafter, the CCBHC must provide training on risk assessment; suicide and overdose prevention and response; and the roles of family and peer staff.

These trainings may be provided online, which makes the annual repeat a scheduling problem rather than a facilities problem — calendar it per hire, including contractors.

Documentation is part of the requirement, not an afterthought.

The CCBHC must assess each staff member's competence, keep written in-service training records for the duration of employment, and document completed training and demonstrated competency in personnel records.

Build the records into your onboarding flow so each hire's file is complete from the first week — reconstructing training records at recertification is far harder than keeping them as you go.

Onboarding a new clinician shows how to structure the first-90-days calendar these trainings drop into.

The staffing area also reaches language access.

CCBHCs must take reasonable steps to provide people with limited English proficiency meaningful access, with interpretation or translation services readily available and appropriate for the population — the criteria name bilingual providers, onsite interpreters, and language video or telephone lines as examples.

Bilingual providers are the staffing answer to that requirement; contracted interpretation is the procurement answer.

Either way, put it in the staffing plan next to the rest of your service capacity.

Sequence the work state-first.

Open your state behavioral health authority's CCBHC requirements and its required-discipline list before anyone writes a job description, then size the plan against the needs assessment.

The federal criteria give you the fixed points to plan around: the CEO/Project Director and Medical Director roles, an independently prescribing provider with capability for opioid, alcohol and tobacco use disorder medications, licensed or certified substance use counselors, and a training calendar that starts at orientation and repeats annually.

Then use the flexibility the criteria explicitly allow.

Because of workforce shortages, the criteria state that some services may be provided by contract or part-time staff as needed, that providers may be shared across locations in multi-site organizations, that telehealth is available, and that providers working toward licensure are not precluded — with the supervision state law requires.

The interaction to watch is with the direct-delivery test: a contract clinician counts as direct only within your management structure and under your direct supervision, so a staffing-agency arrangement you do not supervise day to day starts to look like a DCO relationship for the 51% arithmetic.

Be precise about the leadership bench, too.

The criteria's named management roles are a CEO or equivalent/Project Director and a psychiatrist Medical Director — a separate "clinical director" is not among the requirements.

Splitting day-to-day clinical oversight into its own role is your organizational design decision; if you make it, hiring a clinical director covers what that role involves and how it differs from the medical director post.

Finally, budget the whole build rather than the licensed core alone.

Malpractice coverage has to keep pace with staffing and scope under criterion 1.a.4, the training requirements cover direct-contact contract staff as well as employees, and the personnel-record system has to exist from your first hire, not after it.

When the plan is ready to recruit against, the behavioral health hiring hub collects the role hubs and employer guides — psychiatrists, peer specialists, substance use counselors and the rest — in one place.