This year, the Centers for Medicare and Medicaid Services’ officially added psychologists who see Medicare patients to the Merit-based Incentive Payment System (MIPS) — a new quality payment program used to determine reimbursements for providers.
To help psychologists report quality measures for MIPS and other quality-payment programs, and track patient outcomes, APA created the Mental & Behavioral Health Registry (MBHR).
The MBHRopens in new window is a valuable tool for your practice, and APA is here to help you navigate how, when and why you should use the registry. Read on for answers to psychologists' most commonly asked questions about the registry and quality reporting.
I work in a group practice. How do I report MIPS measures?
Psychologists in group practices can report MIPS measures as an individual provider or join the other clinicians in the practice to report as a group. A group practice includes two or more eligible clinicians. Licensed clinical social workers and mental health counselors are not eligible clinicians in MIPS.
As individual providers, most psychologists will likely be exempt from MIPS reporting under the low-volume threshold. Psychologists reporting as a group would have to include data for the clinicians who as individuals would have been exempt under the low-volume threshold.
Are psychologists able to use other measures to meet MIPS reporting requirements, including measures developed by the Patient-Reported Outcomes Measurement Information System (PROMIS)?
To meet MIPS reporting requirements eligible clinicians, including psychologists, must report six quality measures that have been approved by CMS. These can include MIPS measures that are incorporated in the program as well as measures that have been approved by CMS to be included in a qualified clinical data registry. The MBHR has six measures that are only available to individuals who use the registry. These include two PROMIS measures that are new for 2019.
The MBHR can also support electronic clinical quality measures, quality and outcomes data generated through electronic health records.
I’m a neuropsychologist. What MIPS measures should I use?
The MBHR Advisory Committee recognizes that measures relevant to neuropsychologists is an important measurement gap and is working to incorporate neuropsychologists and test technicians into the measurement development process.
Currently, the quality measures that correspond to services typically billed by neuropsychologists are:
- #181 Elder Maltreatment Screen and Follow-Up Plan.
- #282 Dementia: Functional Status Assessment.
- #283 Dementia: Management of Neuropsychiatric Symptoms.
- #286 Dementia: Counseling Regarding Safety Concerns.
- #288 Dementia: Caretaker Education and Support.
Eligible clinicians are expected to report on six quality measures. If, however, there are fewer than six quality measures available that fit your practice, then the number of possible points the clinician is expected to earn in the MIPS quality performance category will be lowered.
How will my patients’ privacy be protected?
APA has partnered with a CMS-approved software company that specializes in developing health care-related data registries for specialty societies such as APA. They are responsible for securely housing the data and have to adhere to strict compliance with the Health Insurance Portability and Accountability Act and other privacy laws. Their privacy policy can be found on their websiteopens in new window.
How much time does it take to report using the MBHR?
The amount of time it takes depends on various factors, including the mode of data entry you use (uploaded Excel sheets, manual entry, electronic health records); how many patients you have and how many services you provide; how well you integrate data collection within your clinical work flow; and how often you enter data into the system. In addition, some measures only get reported once a year, while others may be collected once a quarter.
I am exempt from MIPS reporting. If I find them to be useful clinically, can I still use the MBHR for access to the measures without having the registry submit my data to MIPS?
Yes. Psychologists and other providers can use the MBHR for their own personal practice without sending MIPS data to CMS. Visit the website to view pricing optionsopens in new window.
Sign up for the Mental and Behavioral Registryopens in new window.
Visit APA Services to learn more about how APA developed the registry, tracking outcomes and value-based payment programs.

