2025 Updates on the Mental and Behavioral Health Registry and Merit-based Incentive Program

For the eighth consecutive year, APA’s Mental and Behavioral Health Registry (MBHR) has maintained its status as a Centers for Medicare and Medicaid Services (CMS)-approved Qualified Clinical Data Registry, which enables Medicare-participating psychologists to easily track patient outcomes and meet the quality reporting requirements for participation in the Merit-based Incentive Program (MIPS).

For 2025, the MBHR will continue to have APA-developed specialty measures related to anxiety, PTSD, alcohol use, psychosocial functioning, sleep, and cognitive assessment. APA is also excited to report that for 2025—in collaboration with MBHR Advisory Committee Member Lisa Lind, PhD—CMS has approved a new, APA-developed quality measure called the Trauma Screening and Re-Traumatization Measure (MBHR19).

The trauma screening measure was developed in response to feedback from our registry users, who wanted to have access to additional MIPS measures that are practical, useful, and clinically relevant for clinicians who work with Medicare beneficiaries in long-term care settings. APA strategically developed the trauma measure to overlap with known CMS goals of enhancing the quality of care of residents in nursing homes, with particular focus on trauma-informed regulations. Under these regulations, nursing facilities must ensure that residents who are trauma survivors receive culturally competent, trauma-informed care in accordance with professional standards of practice and accounting for residents’ experiences and preferences to eliminate or mitigate triggers that may cause retraumatization of the resident.

In November 2019, CMS introduced F-tags (federal regulation) related to trauma-informed care to ensure that nursing facility staff were reducing the risk of retraumatization by integrating care practices that are responsive to the psychological and emotional needs of residents, particularly those who have experienced trauma.

“Working in long-term care settings—primarily with older adults who often have entered rehab following a major medical event—measures are needed that have face validity, can be easily administered, and that can provide clinically relevant information to help guide the diagnostic and treatment process,” said Lind.

The development of meaningful behavioral health measures for Medicare providers, especially those in long-term care, will become even more important as CMS continues to transition away from MIPS toward the MIPS Value Pathway (MVP), which requires clinicians to report on a curated set of measures based on a specialty (e.g., neuropsychology) or condition (e.g., mental and substance use disorders). CMS has suggested that MIPS could be sunset within the next several years. However, few changes were made to the current MIPS program in the 2025 Medicare Physician Fee Schedule. CMS maintained the current performance threshold policies, leaving the MIPS performance threshold set at 75 points for the 2025 performance period. In addition, CMS finalized keeping the 75% data completeness criteria through the 2028 performance period.

Visit APA’s Mental and Behavioral Health Registry page for more information. For more information on how to sign up for the registry for 2025 MIPS reporting, visit the Mental and Behavioral Health Registryopens in new window webpage.