CCBHC Client/Patient Incentives

What is the maximum value of the incentives that can be offered to clients? Per SAMHSA, participation in the CCBHC program must be completely voluntary. As such, incentives cannot exceed $30 in value, as incentives as this amount (or less) does not provide an “undue inducement,” thus removing the voluntary nature of participation. In summary, incentives valued at $30 or less still provide for the “absence of coercion.” Additionally, SAMHSA states that incentives should be the minimum amount necessary to meet the programmatic and performance assessment goals of the grant. Incentives must be non-cash. Incentives must be built into the budget, if the CCBHC wishes to include them in the program. This information is referenced in the NOFO and at SAMHSA's website.

Within the program, which grant activities allow CCBHCs to provide an incentive to clients? Incentives cannot be given to patients/clients for intakes/initial NOMs interviews. SAMHSA states this directly on their website, “You may not use discretionary grant funds to make direct payments to individuals to induce them to enter treatment or prevention programs.”

Incentives can be provided for reassessment interviews; SAMHSA’s website states that the CCBHC program “allows for discretionary grant funds to pay individuals to participate in required data collection follow-up.”

In our work with CCBHCs, we have seen CCBHCs also provide incentives for completion of satisfaction surveys. To date, this practice has not been questioned by SAMHSA.

Is the incentive a maximum of $30 per client over the entire grant period, or is the $30 maximum incentive to be given per incident? Guidance for this question can be found in the NOFO in the section entitled, Appendix I – Standard Funding Restrictions. The guidance states, "A recipient or treatment or prevention provider may provide up to $30 non-cash incentive to individuals to participate in required data collection follow up. This amount may be paid for participation in each required follow-up interview" [emphasis added by CCBHC Support].

CCBHC Support is aware that there are many CCBHCs that interpret the guidance as only providing $30 maximum for the entire grant period, and so they break it up into smaller incentives, such as $10, $10, $10. However, the second sentence in the guidance above states that a program can provide the incentive for each interview. CCBCHs can make their own determination as to how they would like to implement client/patient incentives (either $30 total or $30 per incident). Guidance from the FOA does support that patients/clients can recieve more than one incentive (i.e., for each reassessment interview). For CCBHCs that wish to provide more than one $30 incentive, they can use the language from the FOA to support their decision should SAMHSA question their actions.