The U.S. Centers for Medicare & Medicaid Services (CMS) has unveiled a proposed rule that could reshape how states handle Medicaid behavioral health quality reporting. Until now, states have been submitting behavioral health quality data voluntarily, but the new proposal aims to make this reporting mandatory, marking a critical advancement for accountability and transparency in behavioral health care under Medicaid and CHIP programs.
If finalized, the rule will require states to submit standardized behavioral health quality measures as part of the Core Set of Adult Health Care Quality Measures for Medicaid, beginning with data reflecting care delivered in calendar year 2023. This change ensures that Medicaid behavioral health quality reporting becomes more consistent and comprehensive across the nation.
Why Medicaid Behavioral Health Quality Reporting Matters
Medicaid behavioral health quality reporting provides essential data that can help policymakers, providers, and advocates better understand how behavioral health services are delivered and identify areas needing improvement. The Medicaid and CHIP programs cover millions of low-income individuals, many of whom rely on behavioral health services to manage mental illness, substance use disorders, and related conditions.
Behavioral health encompasses a wide range of conditions, including mental health disorders such as depression and schizophrenia, as well as substance use disorders. These conditions require specialized care and ongoing management, making the quality of behavioral health services a critical area of focus. Consistent and reliable data through behavioral health quality reporting will allow states and federal agencies to track progress, identify disparities, and allocate resources more effectively.
By making Medicaid behavioral health quality reporting mandatory, CMS seeks to create a national picture of care quality that supports informed decision-making and better resource allocation. CMS Administrator Chiquita Brooks-LaSure emphasized the importance of reliable data:
“We can ensure that our policies are supported by data representing all of our beneficiaries.”
Key Components of the Proposed Reporting Rule
The proposed rule affects not only adult behavioral health measures but also includes:
- The Core Set of Children’s Health Care Quality Measures for Medicaid and CHIP
- The Core Sets of Health Home Quality Measures for Medicaid
This expanded scope acknowledges the importance of Medicaid behavioral health quality reporting across the lifespan and various care settings. It also reflects a growing understanding that behavioral health challenges do not discriminate by age and that early intervention during childhood can profoundly affect long-term outcomes.
In addition to improving data collection, the rule aims to encourage states to strengthen their behavioral health programs and services by holding them accountable through standardized reporting. This accountability can drive improvements in service delivery and ultimately improve health outcomes for Medicaid and CHIP beneficiaries.
Core Behavioral Health Measures to be Reported
Among the behavioral health measures that will be part of the mandatory reporting are:
- Antidepressant Medication Management
- Screening for Depression and Follow-Up Plan, tailored by age
- Follow-Up After Hospitalization for Mental Illness
- Adherence to Antipsychotic Medications for Individuals With Schizophrenia
- Concurrent Use of Opioids and Benzodiazepines
These measures reflect critical aspects of behavioral health care quality and will be integral to Medicaid behavioral health quality reporting moving forward. Each measure targets a specific dimension of behavioral health care — from medication adherence to timely follow-up care — that is essential to ensuring effective treatment and recovery.
The consistent reporting of these measures across all states will enable CMS to analyze trends, identify gaps, and develop targeted interventions. For example, if data reveal that follow-up after hospitalization for mental illness is lacking in certain regions, policymakers can focus efforts on improving care transitions to reduce readmissions and support patient recovery.
Clarifying Behavioral Health Definitions
CMS recognizes that definitions of behavioral health and related quality measures vary across federal programs. The proposed rule seeks to better define these terms to support more coherent and effective behavioral health quality reporting. Some measures, like depression screening, currently fall under different domains but are clearly relevant to behavioral health.
This clarification is important because without a unified understanding of what constitutes behavioral health, data collection and interpretation can be inconsistent. By establishing clearer definitions, CMS aims to ensure that all relevant services and outcomes are captured within Medicaid behavioral health quality reporting, allowing for more meaningful analysis and comparisons.
Focus on Children’s Mental Health and School-Based Care
In addition to adult-focused measures, CMS is emphasizing youth behavioral health through two new guidance documents aimed at strengthening Medicaid coverage for children’s mental health services and expanding school-based health care.
Schools have become a vital setting for behavioral health services, especially for children and adolescents who might face barriers accessing traditional health care settings. By integrating mental health services into schools, states can improve early identification, provide timely interventions, and support children’s emotional and behavioral development.
This complements the push to improve Medicaid behavioral health quality reporting by ensuring data includes the full spectrum of services supporting child and adolescent mental health. It also aligns with broader efforts to address mental health disparities among youth and improve long-term health outcomes.
Federal Investment and Legislative Support
The Biden Administration has pledged nearly $300 million to expand mental health services in schools, further reinforcing efforts to improve behavioral health outcomes. Bipartisan legislation passed earlier this year also supports enhanced mental health resources in educational settings.
These initiatives underscore the growing national focus on behavioral health and the role of Medicaid behavioral health quality reporting in tracking progress. Federal funding and legislative backing help create the infrastructure and programs necessary to meet the behavioral health needs of communities, while consistent reporting ensures that the impact of these investments is measurable and accountable.
What’s Next?
The comment period for this proposed rule closes on October 21, 2022. Stakeholders have a vital opportunity to provide feedback that could shape the future of Medicaid behavioral health quality reporting.
Once implemented, the mandatory reporting will help establish clear benchmarks, foster accountability, and drive improvements in behavioral health services nationwide. States will need to enhance their data collection systems and work closely with providers to meet the new reporting requirements.
Conclusion
The CMS proposal to mandate behavioral health quality reporting is a pivotal step toward improving behavioral health care for millions of Americans. By standardizing data collection and expanding coverage across all age groups and settings, this initiative promises more transparent, data-driven policy and better health outcomes.
For anyone involved in Medicaid, behavioral health care, or public health policy, staying informed and engaged in this process is critical to advancing quality and access for the populations served. Consistent behavioral health quality reporting will provide the foundation for ongoing improvements in care, equity, and overall wellbeing.
