Medicare quality reporting in 2023 and beyond

Psychologists who see Medicare beneficiaries and are required reporters for the Merit-based Incentive Payment System (MIPS) will see minor changes to the quality payment program from reporting year 2022. The minimum performance threshold, which is the number of points a provider must earn to avoid a penalty (negative payment adjustments), remains at 75 points.

The Centers for Medicare and Medicaid Services (CMS) established MIPS under the Quality Payment Program to reward health care practitioners for the value and quality of services provided instead of the volume of patients seen.

Providers participating in MIPS are evaluated based on four categories. Given most psychologists’ exemptions from two of the categories—“promoting interoperability” and “cost”—a large amount of weight is placed on their performance in the “quality” category. APA has partnered with Healthmonix via the Mental and Behavioral Health Registry (MBHR)opens in new window, gathering leading experts in the field to develop quality measures that are evidence-based, address gaps in care, and track patient outcomes.

In addition to all of the standard MIPS quality measures, the MBHR includes approximately 14 specialty quality measures, exclusive to the MBHR, for psychologists and other behavioral health practitioners. Providers can report on quality measures that fit into your specialty and workflow by selecting the MBHR measures that match up with your patients and provided services.

The MBHR includes measures to screen for anxiety disorders and report anxiety disorder treatment response. It also includes measures related to impaired functioning, such as sleep quality, pain interference, and social role functioning, as well as a suite of quality process measures specifically for neuropsychology.

It can be difficult to receive high-performance scores or to know what a high score would be on the specialty quality measures. To help increase measure adoption and decrease worry over poor performance, providers who report specialty measures in their first two years will receive minimum scores of 7 points in the first year and 5 points in the second. After two years of reporting, CMS is aiming to provide benchmarks of data on what positive performance looks like and increased scoring potential for those who do perform well. CMS will likely eliminate measures that are not frequently reported by providers. Unfortunately, there are several MBHR measures that will no longer be available for use if psychologists and other behavioral health providers do not report on them in 2023.

If it is important to you to have specialty quality measures that are relevant to the mental health services you provide, please consider signing up for the MBHRopens in new window for MIPS reporting for 2023. If you are already a MBHR user, thank you, and we ask that you strongly consider selecting one or more of the MBHR measures that best fit with your practice to help establish benchmarks and ensure that these measures continue to be an option for MIPS reporting in the future.

In addition to access to relevant quality measures, the MBHR team at Healthmonix can guide you through the MIPS reporting process, including offering tips on workflow, while the comprehensive, user-friendly platform gives you real-time feedback on your MIPS performance to ensure your success and maximize your reimbursement.

CMS plans to transition away from the traditional MIPS program over the next several years, channeling providers into reporting on MIPS Value Pathways (MVPs), subsets of measures and activities that are related to a specialty or medical condition to “offer more meaningful participation in MIPS.” APA continues to encourage CMS to consider postponing the adoption of a general mental health/substance use disorder MVP and instead to engage in a data-driven approach to developing MVPs that reflect the quality measures and improvement activities being selected by mental and behavioral health providers. APA believes that it would be better to develop separate MVPs for more focused settings/specialties like long-term care or neuropsychology as opposed to a generalist model MVP that was recently proposed to APA and other behavioral health member organizations.

• Use the MBHR registryopens in new window to report for MIPS and select the QDCR Quality measures, including the four neuropsychology measures, to ensure that they receive benchmarks (which greatly impacts scoring) and to ensure that they aren’t removed due to lack of awareness/adoption.
• Vote for representatives from your state who will work to make changes to the federal law. CMS is bound by the 2015 Medicare Access and chip Reauthorization Act (MACRA) to implement the Quality Payment Program which includes MIPS.
• Provide responses to CMS through the public comment process on the annual proposed rule published each July (Calendar Year 2023 Medicare Physician Fee Schedule Final Ruleopens in new window).