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Frequently Asked Questions

Frequently Asked Questions

Learn more about the development and benefits of the Mental and Behavioral Health Registry (MBHR), including finding answers to questions about federal regulations and rules, and how to enroll.

A clinical data registry records information about the health status of patients and the health care they receive over varying periods of time, and typically focuses on patients who share a common reason for needing health care.

A QCDR is an entity approved by the Centers for Medicare and Medicaid (CMS) that collects medical and/or clinical data for the purpose of patient and disease tracking to foster improvement in the quality of care provided to patients.

CMS encourages specialty societies, such as the APA and APA Services Inc. (APASI), to develop their own registries to allow their members to report to the Merit-based Incentive Payment System (MIPS). This also allows psychology to take a leadership role in determining quality mental and behavioral health care.

Psychologists were recognized as MIPS eligible clinicians starting in 2019. Those who are not exempt from MIPS via the low-volume threshold will be required to participate or will have their 2021 reimbursements penalized. In 2020, psychologists who bill Medicare will continue to be expected to report unless they fall under the low-volume threshold. Psychologists can check their eligibility status on the CMS website.

Many psychologists who bill Medicare will be exempt from MIPS reporting under the Low-Volume Threshold (LVT), which was created to ease the burden on small practices. If you bill for 200 or fewer beneficiaries, provided 200 or fewer services, or reported $90,000 or less in allowed charges, you will fall under the LVT. You only need to meet one of these criteria to be exempt.

Yes, psychologists can report MIPS data as an opt-in eligible clinician, if they exceed one or more of the LVT options. For example, if billing 200 or more therapy sessions to Medicare in 2019, one would be eligible to opt-in and possibly receive a positive payment adjustment in 2021.

The MBHR allows practitioners to track quality outcomes on their clients and patients, providing rapid feedback on the progress of those they serve, while enabling benchmarking against practitioners doing similar work. The MBHR also provides resources related to clinical practice guidelines, evidence-based practices and continuing education opportunities. It can also meet psychologists’ other data needs, such as meeting licensure renewal, credentialing or board certification requirements, and negotiating with quality-based reimbursement payment programs (pay-for-performance).

The Mental and Behavioral Health Registry includes 24 MIPS measures and 10 non-MIPS measures, unique to the MBHR, that can be submitted directly to CMS. The MBHR is the only registry option that includes measures that enable professionals to screen for, and measure treatment progress for, anxiety disorders. Measures that are only available when using the MBHR include measures on anxiety, pain interference, social role functioning, sleep quality, posttraumatic stress disorder, alcohol use, and ADHD. Measure identification is being steered by an advisory committee of experts in the field of outcome measurement, psychotherapy, clinical research and quality improvement.

There are multiple ways to upload data in the registry, so you do not need an EHR to use the registry; however, certain EHRs are compatible with the registry. For example. APA has partnered with Healthmonix and TherapyNotes, a popular EHR, to allow for seamless reporting to MIPS.

You can check your eligibility status on the CMS website.

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.

The MBHR Advisory Committee recognizes that measures relevant to neuropsychologists is an important measurement gap and are 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 listed below and additionally include all 10 MBHR measures:

  • #130 Documentation of Current Medications in the Medical Record.
  • #134 Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan.
  • #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.

APA has partnered with a CMS-approved software company that specializes in developing health care-related data registries for specialty societies such as the APA. They are responsible for securely housing the data and must adhere to strict compliance with the Health Insurance Portability and Accountability Act and other privacy laws. Their privacy policy can be found on their website.

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.

Yes. Psychologists and other providers can use the MBHR for their own personal practice without sending MIPS data to CMS. Pricing options are available on our website.

Date created: June 2018