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The Milbank Memorial Fund is a private foundation that works to improve population health and health equity.
April 10, 2024
Policy Report
Vinayak Sinha
Emma Rourke
Mary Jo Condon
William Brandel
Publication
Nov 11, 2025
Oct 16, 2025
Sep 15, 2025
States are facing an unprecedented rise in the rates of behavioral health conditions. To address this health crisis, state officials are increasingly focused on identifying ways to improve access to high quality behavioral health care, including by defining and tracking how much payers spend to treat behavioral health conditions. Understanding how much is spent and on what services is the first step to knowing if spending is sufficient to support a growing workforce need. Several states plan to use the data to set targets for how much payers should spend on behavioral health clinical services. Other use cases include monitoring compliance with laws and regulations such as mental health parity, improving service delivery, and informing state budgeting.
Behavioral health spending includes payments from public and private payers to providers, state funds to support behavioral health service delivery, and payments from patients to providers. Today, 12 states measure how much payers spend on clinical care to treat behavioral health conditions, including three—Maine, Massachusetts, and Rhode Island—that measure across the clinical care continuum, from outpatient therapist visits to inpatient day programs. The three states’ approaches to measurement are largely similar. They typically define spending to treat behavioral health conditions using a combination of diagnosis codes, procedure codes, and provider taxonomy codes. Yet, there is variation across the states’ code sets—for example, the services and care settings included, the categories of non-claims payments used, and the technical specifications for the data. (Non-claims payments, such as prospective, per-patient payments, are not based on individual claims for services.)
Now, several states are calling for a more consistent approach to measurement. A shared definition implemented via a standardized methodology will support comparability, streamline measurement decision-making and implementation, and reduce administrative burden on data submitters. This brief offers recommendations for a definition and standardized methodology supported by a detailed code set to measure how much payers spend on behavioral health clinical services, which includes claims and non-claims spending. The methodology was designed with input from an Advisory Group of state behavioral health leaders and subject matter experts convened by Milbank Memorial Fund and FreedmanHealthCare.
Diagnosis
Services and Treatments
Provider
Care Setting
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