Proposed Rule Provides Opportunity to Advance Behavioral Health Quality

As my colleague, Maggie Clark, wrote about on Say Ahhh! earlier this week – we can’t improve what we don’t measure. This is why CMS’s recently proposed rule on reporting of quality measures in Medicaid and CHIP is critical to advancing behavioral health care quality. The proposed rule, open for comment through October 21, requires states to report on the Child Core Set, the behavioral health measures in the Adult Core set, and the Health Home Core Set Measures and to disaggregate certain measures by race, ethnicity, disability and other factors.

As the single largest payer of behavioral health care in the United States, Medicaid plays an essential role in serving individuals with mental health needs. In addition, covering about half of all children in the US, Medicaid (alongside the Children’s Health Insurance Program) is critically important for children and youth, including those with mental health conditions. As rates of children’s anxiety and depression rise, it is more important than ever that we measure the quality of behavioral health care, especially for Black and Latino children who continue to experience disparities in receiving mental health services.

As my colleagues have written about on Say Ahhh!, state reporting on child health quality measures (the Child Core Set), adult health quality measures (the Adult Core Set), and the Health Home Core Set, have been voluntary to date. However, under laws passed in 2018, reporting will become mandatory for certain measures starting with fiscal year 2024 state reporting. Under the proposed rule, which implements these requirements, states will be required to report the Child Core Set measures as well as the behavioral health measures included in the Adult Core Set (and the Health Home Core Set measures). This means that for the first time states will be required to report on behavioral health measures in Medicaid and CHIP – both those included in the Child Core Set and those in the Adult Core Set.

By way of background, in 2020 there were 18 behavioral health care quality measures for voluntary reporting by state Medicaid and CHIP agencies, consisting of five behavioral health measures within the Child Core Set and 13 behavioral health measures within the Adult Core Set. Yet, 33 states (including DC and Puerto Rico) reported on fewer than 15 of the behavioral health measures. Only two states (Iowa and New Hampshire) reported on all 18 measures. Without this data, we can’t improve on what we don’t measure.

While mandatory reporting is by no means the solution to the current mental health crisis – one that is now nearing a year since national children provider groups declared a national emergency in child and adolescent mental health – the proposed rule provides a key opportunity to advance behavioral health quality in Medicaid and CHIP and for stakeholders to weigh in on the importance of requiring states to report all of the behavioral health measures. In addition, as highlighted by my colleague Maggie Clark, ensuring that states report the measures on time and with detailed, disaggregated data will promote health equity and usher in improvements to the quality of care provided by Medicaid and CHIP.

To see which child behavioral health measures your state is currently reporting on and how it’s doing compared to other states, check out CCF’s State Data Hub.

[For individuals interested in submitting comments to CMS, they can do so through the Why My Care Counts portal.]

Anne Dwyer is an Associate Research Professor at the Georgetown University McCourt School of Public Policy’s Center for Children and Families.