Finalized Changes to 2026 MIPS Value Pathway for Mental and Behavioral Health

April 10, 2026

The Centers for Medicare and Medicaid Services (CMS) finalized updates to the Quality Care in Mental Health and Substance Use Disorders MVP for the 2026 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 changes were finalized in the 2026 MVP for mental and behavioral health.

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 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 2026 performance year, you must register between April 1, 2026, and November 30, 2026, 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 are reporting at the group level, you will have the chance to attest to being a single-specialty group or a small multi-specialty group (15 or fewer clinicians).
- If you report at the group level and are part of a large multi-specialty group (more than 15 clinicians), you are required to report at the subgroup level in 2026.

If you are an Anatomy IT client, we will discuss whether to report an MVP during your kickoff call.

What Are the 2026 Changes to the MVP for Mental and Behavioral Health?

CMS finalized the following changes to the 2026 Quality Care in Mental Health and Substance Use Disorders MVP:

Removed 1 quality measure:

- 487: Screening for Social Drivers of Health *

Removed 5 improvement activities:

- 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 *
- 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 *

*These measures were also removed from traditional MIPS.

To see all the measures and activities included in the Quality Care in Mental Health and Substance Use Disorders MVP, click on the category names below.

Mental and Behavioral Health Measures (Specific to This MVP)

Quality

Quality Care in Mental Health and Substance Use Disorders MVP Quality Measures

Report 4 of the following (at least 1 outcome or high priority measure):

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)
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: Post-traumatic Stress Disorder (PTSD) Outcome Assessment for Adults and Children (outcome)

Improvement Activities

Quality Care in Mental Health and Substance Use Disorders Improvement Activities

Report 1 of the following:

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
BE_26: Promote Use of Patient-Reported Outcome Tools
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
EPA_7: Enhance Engagement of Medicaid and Other Underserved Populations
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

Cost

Foundational Layer (Applies to All MVPs)

Population Health

Population Health Measures

You will be automatically scored on both of the following population health measures, if applicable. CMS will assign you the higher of the two scores.

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

Promoting Interoperability

Promoting Interoperability Requirements

The PI requirements for an MVP are the same as those for traditional MIPS.

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.
Option 2: Health Information Exchange (HIE) Bi-Directional Exchange
Option 3: Enabling Exchange Under the Trusted Exchange Framework and Common Agreement (TEFCA)

You can optionally report on one of the following measures for up to 5 bonus points in the PI category:

Syndromic Surveillance Reporting
Clinical Data Registry Reporting
Public Health Registry Reporting
Public Health Reporting Using TEFCA

Is Reporting the Quality Care in Mental Health and Substance Use Disorders MVP in 2026 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 2026 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 2027 Medicare Physician Fee Schedule Proposed Rule this summer or by following the steps outlined here by CMS.

Next Steps

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Written By: Sarrah Hakim, MHSA