CMS to Mandate State Reporting of Behavioral Health Quality Data

The U.S. Centers for Medicare & Medicaid Services (CMS) could require states to report additional health quality data — including more behavioral health quality data.

A proposed rule released late Thursday, if finalized, would make it mandatory for states to report behavioral health measures on the Core Set of Adult Health Care Quality Measures for Medicaid. States were doing so under a voluntary basis, but CMS is seeking to make it mandatory moving forward.

“Data reported in 2024 will reflect care delivered in calendar year 2023,” a related CMS announcement states. “Nationwide reporting of the measure sets will create opportunities to develop a national view of quality in the Medicaid and CHIP programs — a long-sought goal for public health advocates.”


The other measures impacted by the proposed rule include the Core Set of Children’s Health Care Quality Measures for Medicaid and CHIP, along with the Core Sets of Health Home Quality Measures for Medicaid.

“CMS will use every lever available to ensure a high quality of care for everyone with Medicaid and CHIP coverage,” CMS Administrator Chiquita Brooks-LaSure said in the announcement. “By requiring states to report the core sets of quality measures, we can ensure that our policies are supported by data representing all of our beneficiaries.”

The 60-day comment period for the proposed rule ends on Oct. 21, 2022. The rule in full is available on the Federal Register.


CMS had identified a core set of 20 behavioral health measures for voluntary reporting by state Medicaid and CHIP agencies. Some examples include:

— Antidepressant Medication Management

— Screening for Depression and Follow-Up Plan (with different measures depending on age)

— Follow-Up After Hospitalization for Mental Illness (again, with different measures depending on age)

— Adherence to Antipsychotic Medications for Individuals With

— Concurrent Use of Opioids and Benzodiazepines

Also of note: The proposed rule seeks to better define “behavioral health” and “behavioral health measures,” as federal definitions currently vary depending on the source.

“We currently do not have a definition of behavioral health for use in the Adult Core Set for voluntary reporting and not all measures that are relevant to behavioral health are included in the behavioral health domain of the Adult Core Set, because such measures span multiple domains,” the 85-page proposed rule explains. “For example, the ‘Screening for Depression and Follow-up Plan’ measure is in the ‘Primary Care Access and Preventative Care’ domain on the Adult Core Set because it is provided in the primary care setting. However, we believe this is clearly a behavioral health measure as well.”

Children’s mental health

At the same time, CMS announced two new guidance documents for state Medicaid programs focused on youth mental health.

The two new documents for state Medicaid programs highlight the requirement for covering youth behavioral health services. CMS also included a guidance document about expanding school-based health care, especially mental health services. 

“As we begin the school year, a top priority of the Biden Administration is to ensure all children have access to the full range of care and support they need to stay healthy and thrive – including mental health services,” U.S. Department of Health and Human Services Secretary Xavier Becerra said in a press release. “For the millions of children who are covered by Medicaid and CHIP, this means working with states to ensure they are pulling every lever to strengthen and expand comprehensive access to mental health care for children.”

At the end of July, the White House pledged nearly $300 million to expand mental health services in schools.

Legislative efforts, including the bipartisan gun and mental health reform bill passed in June, have put out several additional resources and programs to deepen mental health resources in schools as well.

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