Billing Changes for Board-Registered Behavioral Health Associates

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. This policy change will affect all behavioral health associates working in Oregon.

Starting July 1, 2027, behavioral health associates will be required to either become 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 since 2016.

For more information, read OHA's February 2026 memo 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.

The decision to move forward with this change was informed by OHA's impact assessment. The assessment analyzed extensive public feedback and a variety of data, including:

• Online survey responses from 2,180 providers and 262 OHP members
  
• Individual correspondence directly shared with OHA
  
• Public comment to the Oregon Health Policy Board and its Health Equity Committee
  

To learn more about this decision, read OHA's April 2026 impact assessment

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:

• Clinics regulated by the U.S. Health Resources and Services Administration (HRSA), including Federally Qualified Health Centers, Rural Health Clinics and Tribal Behavioral Health Clinics
  
• School-Based Health Centers
  
• School-Based Health Services
  

COA Application Processing Update

Since 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 to review and approve applications. OHA is processing COA applications as quickly as possible.  

June 10, 2026, update: To give providers, members and OHA more time to prepare for this change, the new policy will go into effective one year after the rule changes are filed on July 1, 2026.This means associates will not be required to work for a COA holding organization until July 1, 2027.  

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 July 1, 2027.
• If not, first contact your coordinated care organization (CCO)  to request their help in identifying a new provider.
• For additional assistance, contact:
• OHP Client Services: 1-800-273-0557 or Ask.OHP@odhsoha.oregon.gov
  
• OHA Ombuds Program: 1-877-642-0450 or OHA.OmbudsOffice@odhsoha.oregon.gov
  

Rulemaking Update

To discuss these rule changes, OHA held a Rules Advisory Committee (RAC) on April 13, 2026, and also held a public hearing on May 19, 2026. Materials from these events are available on the OHA Rules Advisory Committee Meeting Archive web page.

OHA continues to accept and consider public feedback on this issue. The last day and time to submit public comment is 5 p.m. Pacific Time on June 18, 2026. Public comment can be shared through then by sending an email to medicaid.rules@oha.oregon.gov.