ODMHSAS Addresses CCBHC Funding Concerns

The Oklahoma Department of Mental Health and Substance Abuse Services (ODMHSAS) is providing clarity around recent reports of funding challenges facing mental health providers across the state. Concerns referencing $150 million in pending reimbursement claims have underscored the need for clarity, accuracy and context.

The Certified Community Behavioral Health Clinic (CCBHC) model operates under a prospective payment system (PPS), providing providers with a comprehensive monthly rate that covers the full range of patient acuity and payer status—including services for individuals with no insurance. Historically, payments for these uninsured individuals have been addressed through what are referred to as “pended payments.”

While ODMHSAS is committed to ensuring care for uninsured patients, it has not traditionally budgeted separately for pended payments. Instead, these payments have been managed at year-end using available funds. To enhance financial predictability for providers, Commissioner Allie Friesen previously directed the former Chief Financial Officer to develop an algorithm to assist providers in estimating and planning for anticipated pended payments. Unfortunately, this analysis was never delivered.

Several factors have contributed to the current rise in pended payment amounts, including systemic shifts such as the transition to managed care, broader state-level reforms, and increased service mandates placed on CCBHCs. ODMHSAS continues to work closely with providers and the Legislature to create a more structured, sustainable model for covering services delivered to Oklahomans without insurance.

The PPS model was designed to sustain core clinic operations, including care for the uninsured. In addition, the Enhanced Tiered Payment System (ETPS) serves as an incentive-based funding mechanism that rewards high-quality care and is available to all CCBHCs. Together, these two systems offer substantial funding opportunities to support service delivery and programmatic growth.

However, ODMHSAS acknowledges that significant and sometimes unrealistic mandates have made operating within the current model challenging for some providers. As a result, the Department is actively working to restore the model’s original fidelity—ensuring monthly rates are sufficient to meet operational needs. This transition will not be immediate, but ODMHSAS is committed to establishing a clear glide path that involves reevaluating provider expectations, stabilizing financial planning for CCBHCs, and improving transparency and communication.