SAMHSA Seeks Public Comment on Independent Accreditation System for CCBHC Expansion Grant Recipients

The Substance Abuse and Mental Health Services Administration (SAMHSA), an agency within the US Department of Health and Human Services (HHS), has issued a request for information (RFI) seeking public comment to inform the development, implementation, and oversight of an independent accreditation system for Certified Community Behavioral Health Clinic Expansion (CCBHC-E) grant recipients. SAMHSA aims to establish a process for evaluating and approving accrediting bodies, transition certain CCBHC-E grant recipients to independent accreditation, develop a federal oversight framework, and provide technical assistance to states, providers, and accrediting organizations. Responses to this RFI will inform SAMHSA’s development of an accreditation system that promotes quality, reduces administrative burden, and ensures consistent national standards.

Part of a Broader Congressional Mandate

In the Joint Explanatory Statement accompanying the fiscal year 2026 Labor, HHS, and Education Appropriations Bill (Senate Report 119-55), Congress directed SAMHSA to “examine and approve accreditation products that certify CCBHCs in having met requirements as established by SAMHSA,” with CCBHC grantees receiving independent accreditation from an approved entity as part of their participation in the program. The directive moves away from self-attestation as a mechanism for meeting CCBHC requirements, with the stated goals of reducing paperwork and administrative burden. Congress also permitted SAMHSA to use program funds to establish the accreditation process and expand the audiences eligible for training and technical assistance, including demonstration CCBHCs and CCBHCs participating in state-led implementation efforts under a Medicaid State Plan Amendment, waiver, or other Medicaid authority.

Development of a National Framework for Independent CCBHC Accreditation

SAMHSA is currently developing a national framework for independent CCBHC accreditation, which is expected to address four key areas:

1. Approval of accrediting bodies. SAMHSA will evaluate and approve independent accrediting bodies through a formal application and review process to ensure alignment with SAMHSA’s established standards.
2. Transition from self-attestation. CCBHC-E grant recipients that are not certified by their state under a Medicaid CCBHC program will be transitioned from self-attestation to independent accreditation.
3. Federal oversight structure. SAMHSA will establish a structured system for ongoing federal oversight and coordination of approved accrediting bodies to ensure continued adherence to federal standards and to address disputes, appeals, and conflicting determinations.
4. Technical assistance. SAMHSA will provide targeted technical assistance and implementation support to states, CCBHCs, accrediting bodies, and other stakeholders to ensure effective operation of the accreditation system.

Key Areas for Public Comment

SAMHSA seeks public input on a range of topics, and respondents may address any or all of them and provide additional information beyond the questions listed. The primary areas of focus are:

• Standards and requirements for accrediting bodies
  • What elements should SAMHSA include in the standards governing accrediting bodies and their CCBHC accreditation processes?
  • What specific aspects of the CCBHC model should be emphasized in accreditation?
  • What expectations should SAMHSA establish for accrediting bodies in terms of their processes, basis for decision-making, fees, and time frames for communications?
  • What staffing, qualifications, and expertise should be required for accrediting bodies and/or for individuals conducting accreditation reviews?
• Accreditation process, oversight, and compliance
  • How can accreditation support continuous quality improvement at both the clinic and state levels?
  • How can SAMHSA reduce administrative burden and cost for CCBHCs and states while supporting efficient and high-quality accreditation processes?
  • How should SAMHSA structure oversight of accrediting bodies, including monitoring, reporting, and coordination with states and providers?
  • What data infrastructure would help support a federal accreditation system?
  • How should SAMHSA approach appeals, disputes, or conflicting determinations between state certification and independent accreditation findings?
  • How should SAMHSA address situations where CCBHCs are found out of compliance through accreditation?
    • Under what circumstances should SAMHSA prioritize remediation and within what time frames?
    • Under what circumstances should accrediting bodies deny accreditation?
    • Should failure to achieve or maintain accreditation affect CCBHC-E grant funding, and if so, how?
  • How should designated collaborating organizations be evaluated and included in accreditation site visits?
• Timing and logistics of implementation
  • What considerations should inform the timing of SAMHSA’s application and approval process for accrediting bodies?
  • How much time would providers need to prepare for accreditation, and what factors should SAMHSA consider when determining launch timelines?
  • What timing considerations should apply to CCBHC-E grant recipients not certified by their states?
  • Should SAMHSA consider provisional attestation, phased implementation, or other transition strategies for introducing accreditation?
• State coordination
  • How can SAMHSA best partner with CCBHC-certifying states during accreditation implementation?
  • How should SAMHSA address scenarios where state certification decisions differ from accreditation findings?
• Technical assistance and support
  • What technical assistance and support would be most helpful for CCBHCs, states, accrediting bodies, and other stakeholders?
  • What forms of technical assistance — such as consultation, webinars, readiness tools, or checklists — would be most valuable?
• Additional feedback
  • What additional considerations, concerns, or recommendations should SAMHSA consider in developing and implementing an independent CCBHC accreditation system?
  • Are there experiences or examples from accreditation or certification processes in other sectors that may inform SAMHSA’s approach?

What This Means for Stakeholders

SAMHSA’s RFI signals a shift in how CCBHC-E grant recipients will be required to demonstrate compliance, moving away from self-attestation and toward independent, externally validated accreditation. Stakeholders across the behavioral health sector should participate in the comment process to ensure their operational realities are reflected in the final accreditation system. SAMHSA intends to use the responses to this RFI to develop the standards, processes, oversight mechanisms, and technical assistance strategies for the independent CCBHC accreditation system. Input received may also be used to develop future guidance, program requirements, or related policy materials.

For CCBHCs, states, and accrediting bodies, this RFI represents a critical opportunity to shape a regulatory framework that will govern program participation and funding eligibility. The shift from self-attestation to independent accreditation will have significant operational and financial implications, and early engagement in the comment process is strongly advisable.

Written comments will be accepted through 11:59 PM ET on July 26, 2026. Comments may be submitted electronically at www.regulations.gov or by email to CCBHCAccreditation@samhsa.hhs.gov.

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The Goodwin Healthcare team will continue to monitor SAMHSA regulatory updates. For more information on the issues discussed in this alert, please contact the authors or reach out to Goodwin’s Healthcare team, or contact the Goodwin lawyer with whom you typically consult.

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