Overview
Oregon Health Authority (OHA) is revising Medicaid rules related to how unlicensed, board-registered associates who work in behavioral health – clinical social work associates, board-registered marriage and family therapist associates, and board-registered professional counselor associates – can provide and bill for Medicaid-covered services in Oregon. If implemented, this policy change would affect all behavioral health associates working in Oregon.
Starting Oct. 1, 2026, behavioral health associates will be required to either ecome licensed or to work for an agency that has an OHA-issued Certificate of Approval (COA). Outpatient behavioral health clinics receive a COA after they demonstrate their organization meets OHA regulatory requirements. This will end the current policy, which has allowed board-registered behavioral health associates to bill Medicaid in private practice and settings that do not have a COA.
View the memo from OHA about this change
Why Make This Change?
OHA is making this change to ensure Oregon Health Plan (OHP/Medicaid) members with the most complex behavioral health conditions can receive the care they need and deserve. The new policy will help community mental health programs, which serve a large volume of Medcaid members with complex behavioral health conditions, have the workforce needed to serve their clients. This change will also ensure unlicensed behavioral health professionals receive the training and experience needed to serve all OHP members - and particularly those with more complex conditions.
Which Providers Will This Policy Affect?
This policy change will affect most behavioral health associates caring for OHP members in Oregon, regardless of whether clients are enrolled in Medicaid through a coordinated care organization (CCO) or are Open Card (fee-for-service) members. However, associates working in the following settings will be exempt from the new policy due to other, preexisting government oversight:
Community Engagement
Substantial public feedback and data analysis informed OHA's decision to move forward with this policy change. OHA considered the public's input from a variety of sources, including online survey responses from 2,180 providers and 262 OHP members as well as 107 individual pieces of correspondence that were directly shared with OHA on this matter. Other sources of feedback included the Oregon Health Policy Board and its Health Equity Committee, which also received public comment on the issue.
Members of the public will have additional opportunities to provide comment when the RAC meets this spring.
A detailed analysis of the OHP member and provider survey results will be released in March 2026.
COA Application Processing Update
After OHA first announced that it was pursuing this policy change in January 2025, more clinics and organizations have expressed interest in obtaining COAs. Unprecedented increased interest in COAs means OHA needs more time than usual to review and approve applications. OHA is processing COA applications as quickly as possible.
To give providers, members and OHA more time to prepare for this change, OHA is postponing the policy's effective date by 90 days. While rule changes will be finalized by July 1, the resulting policy won't become effective until October 1.
Recommendations for Providers
Providers who do not plan to obtain a COA or who may not have an approved COA by October 1 should notify their Medicaid clients immediately so OHP members can make alternative care plans.
If you are a provider interested in obtaining a COA, please email LCApplications@oha.oregon.gov and you will be guided through the process.
Recommendations for OHP Members
Only members who currently receive care from behavioral health associates who do not already work for a clinic that has a Certificate of Approval will be impacted. Starting October 1, those members will need to either see their current provider in a new setting or find a new provider.
If you are an OHP member who is unsure if this policy change affects you:
- Ask your provider if they are a board-registered behavioral health associate.
- If they are, ask your provider if they will be able to continue caring for you when the new policy goes into effect October 1.
- If not, first contact your
coordinated care organization (CCO) to request their help in identifying a new provider.
- For additional assistance, contact:
Next Steps
This page will be updated with information about the upcomiing Rules Advisory Committee (RAC) meeting when it is scheduled.
If you have questions or feedback about this proposed rule, please email the OHA Director's Office.