The Centers for Medicare and Medicaid Services (CMS) introduced the Quality Care in Mental Health and Substance Use Disorders in 2024, and it continues to be available for reporting in the 2025 performance year.
Although MVP reporting is currently voluntary, CMS has expressed the intention of sunsetting traditional MIPS and transitioning to MVPs entirely in the future. In the 2025 MIPS proposed rule, CMS requested feedback on the possibility of making MVPs mandatory as early as 2029.
Anatomy IT will continue to advocate for MVPs to be optional and for improvements to this MVP to make it possible for all mental and behavioral health specialists to be successful.
In this blog, we’ll break down what MVPs are, how to report them, and what measures and activities are included in the Quality Care in Mental Health and Substance Use Disorders MVP.
What is a MIPS Value Pathway (MVP)?
CMS introduced MVPs as an alternative reporting option to traditional MIPS in 2023. According to CMS, MVPs aim to simplify MIPS, reduce reporting burden, and help patients make more informed decisions when choosing their clinicians.
Each MVP has its own specific set of quality measures, improvement activities (IAs), and cost measures, and you are limited to those measures and activities when reporting the MVP. The Promoting Interoperability (PI) category is included as part of a “foundational layer,” meaning that PI requirements are the same for every MVP. Also included in the foundational layer is a population health measure, which contributes to your overall Quality score.
Can I Report an MVP Through a Registry?
Since 2023, Qualified Registries (QRs) and Qualified Clinical Data Registries (QCDRs), such as the American Psychological Association’s Mental and Behavioral Health Registry (MBHR) QCDR, have been required to support all measures in the Quality, IA, and PI categories of the MVPs relevant to their clinicians. They are not required to support the Cost category, Population Health measures, QCDR measures, or the CAHPS for MIPS Survey.
While registries must support MVPs relevant to their clients, you will only be able to report MBHR QCDR measures through the MBHR.
How Are MVPs Different from Traditional MIPS?
The table below highlights the differences by category between reporting traditional MIPS versus reporting an MVP.
If you choose to report both traditional MIPS and an MVP, CMS will assign you the higher of the two scores.
How Do I Report an MVP?
To report an MVP for the 2025 performance year, you must register between April 1, 2025, and December 1, 2025, at 8 pm ET. Registration is available through your QPP account.
At the time of registration, you must include the following information:
- The MVP you are choosing to report,
- Any administrative claims measures you would like to be included as 1 of your 4 required Quality measures,
- Whether you are planning to count the CAHPS for MIPS Survey measure towards 1 of the 4 required Quality measures, and
- Your participation level (group, subgroup, individual, APM).*
**If you report at the group level and are part of a multispecialty group, you will be required to report at the subgroup level starting in 2026.*
If you are an Anatomy IT client, we will discuss whether to report an MVP during your kickoff call.
What Measures Are Included in the MVP for Mental and Behavioral Health?
Click on the category names below to see the measures and activities included in the Quality Care in Mental Health and Substance Use Disorders MVP.
Mental and Behavioral Health Measures (Specific to This MVP)
Quality Care in Mental Health and Substance Use Disorders MVP Quality Measures
- 9: Antidepressant Medication Management
- 134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan
- 305: Initiation and Engagement of Substance Use Disorder Treatment (high priority)
- 366: Follow-Up Care for Children Prescribed ADHD Medication (ADD)
- 370: Depression Remission at Twelve Months (outcome)
- 382: Child and Adolescent Major Depressive Disorder (MDD): Suicide Risk Assessment (high priority)
- 383: Adherence to Antipsychotic Medications For Individuals with Schizophrenia (outcome)
- 468: Continuity of Pharmacotherapy for Opioid Use Disorder (OUD) (high priority)
- 487: Screening for Social Drivers of Health (high priority)
- 502: Improvement or Maintenance of Functioning for Individuals with a Mental and/or Substance Use Disorder (outcome)
- 504: Initiation, Review, And/Or Update To Suicide Safety Plan For Individuals With Suicidal Thoughts, Behavior, Or Suicide Risk (high priority)
- 505: Reduction in Suicidal Ideation or Behavior Symptoms (outcome)
- MBHR2: Anxiety Response at 6-months (outcome)
- MBHR7: Posttraumatic Stress Disorder (PTSD) Outcome Assessment for Adults and Children (outcome)
- AHE_1: Enhance Engagement of Medicaid and Other Underserved Populations
- AHE_3: Promote use of patient-reported outcome tools
- AHE_5: MIPS Eligible Clinician leadership in clinical trials or community-based participatory research (CBPR)
- AHE_9: Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols
- AHE_12: Practice Improvements that Engage Community Resources to Address Drivers of Health
- BE_12: Use evidence-based decision aids to support shared decision-making
- BE_16: Promote Self-management in Usual Care
- BE_23: Integration of patient coaching practices between visits
- BMH_2: Tobacco use
- BMH_5: MDD prevention and treatment interventions
- BMH_7: Implementation of Integrated Patient Centered Behavioral Health Model
- BMH_14: Behavioral/Mental Health and Substance Use Screening and Referral for Pregnant and Postpartum Women
- BMH_15: Behavioral/Mental Health and Substance Use Screening and Referral for Older Adults
- EPA_2: Use of telehealth services that expand practice access
- PM_6: Use of toolsets or other resources to close healthcare disparities across communities
- PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B (added in 2025)
- PSPA_32: Use of CDC Guideline for Clinical Decision Support to Prescribe Opioids for Chronic Pain via Clinical Decision Support
- PCMH: Electronic submission of Patient Centered Medical Home accreditation
- MVP: Practice-Wide Quality Improvement in MIPS Value Pathways
- Medicare Spending Per Beneficiary (MSPB) – Clinician
35-episode case minimum
- Depression
*20-episode case minimum** *
- Psychoses and Related Conditions
20-episode case minimum
Foundational Layer (Applies to All MVPs)
- 479: Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-Based Incentive Payment Systems (MIPS) Groups
- 484: Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions
All of the following attestations and measures are required (no exclusions):
- Use of CEHRT
- Actions to Limit or Restrict Interoperability of CEHRT
- ASTP/ONC Direct Review
- High Priority SAFER Guides Assessment
- Security Risk Analysis
- Provide Patients Electronic Access to Their Health Information
All of the following measures are required (unless claiming an exclusion):
- e-Prescribing
- Query of Prescription Drug Monitoring Program (PDMP)
- Immunization Registry Reporting
- Electronic Case Reporting
One of the following options is required:
- Option 1: Support Electronic Referral Loops by Sending Health Information + Support Electronic Referral Loops by Receiving and Reconciling Health Information
Exclusions are available for both measures in this option.
You can optionally report on one (only one) of the following measures for 5 bonus points in the PI category:
- Syndromic Surveillance Reporting
- Clinical Data Registry Reporting
- Public Health Registry Reporting
Is Reporting the Quality Care in Mental Health and Substance Use Disorders MVP in 2025 Worth It?
Yes. CMS is considering making MVP reporting mandatory starting in 2029. That means there are only a few MIPS performance years left to find flaws, gather data, and recommend improvements before MVPs become the only way in which you can participate in MIPS and avoid a penalty. By reporting the 2025 Quality Care in Mental Health and Substance Use Disorders MVP, you will:
- Gain invaluable experience to prepare you for mandatory MVP reporting,
- Not negatively impact your MIPS payment adjustment as long as you also report traditional MIPS (even if you score poorly in the MVP), and
- Be able to provide real-world feedback to CMS to help them improve the MVP available to you before MVP reporting becomes mandatory. You can communicate with us to describe your experience with the MVP or you can tell CMS directly by commenting on the 2026 Medicare Physician Fee Schedule Proposed Rule this summer or by following the steps outlined here by CMS.
Next Steps
- Share this information with your colleagues.
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- If you are an Anatomy IT client, contact your MIPS Expert if you have any questions.
- If you are not an Anatomy IT client, contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.
If you have any questions on this, let us know!
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Written By: **Sarrah Hakim, MHSA
About the Author: Sarrah is a Manager of Health Policy at Anatomy IT.