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Quality Assurance Material Submission and Review

Material Submission and Review

Managed Care Entities (MCEs) must submit member notices, informational and educational materials, and marketing materials to OHA for review and approval by the Quality Assurance & Contract Oversight unit prior to use and distribution to members. 

  • For more information about this Contract requirement, please see Exhibit B, Part 3, Section 4 (f) in the 2022 CCO Contract or Exhibit B, Part 3, Section 4 (e) in the 2022 DCO Contract.

Submission guidance for member materials
Please refer to the Materials Submission Guide for information about which materials need to be submitted to OHA for review.

Language and formatting

Readability
Readability of member documents should be Grade 6 on the Flesch-Kincaid Grade Level scale.
  • Grade range: 6.0 to 6.9
  • Preferred scoring method: Microsoft Word readability analysis

Learn more about what we exclude during readability reviews in the Readability Scoring Guide

Language access and translation

All Oregon Health Plan member materials must include Language Access Statements, also called taglines, to ensure members know who to call to get materials in alternate formats, non-English languages, interpreters, and access other assistance. 

MCEs must send materials in a member’s preferred language for all prevalent, non-English languages in the service area. For all other languages, translations must be provided when a member request is received.

Fonts
  • Minimum font size for member materials: 12 point for regular text, 18 point for large text. Language Access Statements must be in at least 18 point.
  • Preferred font type: Sans serif standard typeface, including Arial, Verdana, and Tahoma. Condensed font is not preferred because narrow setwidths are difficult to read.
  • Color: The color contrast ratio must be at least 4.5:1 for regular text and 3:1 for large text. Check your font colors with WebAIM Contrast Checker.

Member materials frequently asked questions

Please see the entries below for answers to our most frequently asked questions. If you have a question that is not listed below, please contact HSD.QualityAssurance@dhsoha.state.or.us.

Text, emails, robocalls

Managed Care Entities (MCEs) may use text messaging or email to reach out to members, as long as plans adhere to Health Insurance Portability and Accountability Act (HIPAA) and Telephone Consumer Protect Act (TCPA) rules and guidelines. Each organization should check in with its own legal team.

Mass texts and emails need to follow the regular MCE Member Materials review process. Please check in with your materials coordinator for more information about this process or contact HSD.QualityAssurance@dhsoha.state.or.us.

FCC clarification on non-telemarketing healthcare calls

The Federal Communications Commission (FCC) issued a Declaratory Ruling and Order on July 10, 2015 which included the following guidance for non-telemarketing healthcare calls and texts:

  1. Voice calls and text messages must be sent, if at all, only to the wireless telephone number provided by the patient;
  2. Voice calls and text messages must state the name and contact information of the healthcare provider (for voice calls, these disclosures would need to be made at the beginning of the call);
  3. Voice calls and text messages are strictly limited to the purposes permitted in [listed below]; must not include any telemarketing, solicitation, or advertising; may not include accounting, billing, debt-collection, or other financial content; and must comply with HIPAA privacy rules;
    • Restricted [to calls and text messages] for which there is exigency and that have a healthcare treatment purpose, specifically: appointment and exam confirmations and reminders, wellness checkups, hospital pre-registration instructions, pre-operative instructions, lab results, post-discharge follow-up intended to prevent readmission, prescription notifications, and home healthcare instructions.
  4. Voice calls and text messages must be concise, generally one minute or less in length for voice calls and 160 characters or less in length for text messages;
  5. A healthcare provider may initiate only one message (whether by voice call or text message) per day, up to a maximum of three voice calls or text messages combined per week from a specific healthcare provider;
  6. A healthcare provider must offer recipients within each message an easy means to opt out of future such messages, voice calls that could be answered by a live person must include an automated, interactive voice- and/or key press-activated opt-out mechanism that enables the call recipient to make an opt-out request prior to terminating the call, voice calls that could be answered by an answering machine or voice mail service must include a toll-free number that the consumer can call to opt out of future healthcare calls, text messages must inform recipients of the ability to opt out by replying “STOP,” which will be the exclusive means by which consumers may opt out of such messages; and,
  7. A healthcare provider must honor the opt-out requests immediately.

The information above applies to robocalls and texts to wireless numbers only if they are not charged to the recipient, including not being counted against any plan limits that apply to the recipient (e.g., number of voice minutes, number of text messages).

Please see the Telephone Consumer Protection Act (TCPA) Omnibus Declaratory Ruling and Order for more information.

Reminder: Each organization should check in with its own legal team about HIPAA and TCPA requirements.

Taglines

All Oregon Health Plan member materials must include Language Access Statements, also called taglines, to ensure members know who to call to get materials in alternate formats, non-English languages, interpreters, and access other assistance. 

Here is an example of a tagline that meets requirements in English:

"You can get this letter in other languages, large print, Braille or a format you prefer. You can also ask for an interpreter. This help is free. Call #CustomerService# or TTY #TTY#. We accept relay calls."

MCEs should replace the highlighted text with appropriate phone numbers.

Translated tagline examples are available for use in Oregon Health Plan / Medicaid materials, translated into the top 15 languages reported by OHP members.  

Does my document need to include the statement translated into 15 or 24 languages?
You can translate the statement into as many languages as you want. At a minimum, it must be translated into the languages that are prevalent in your service area.

What happened to the previous requirement to include more taglines?

Previously, Section 1557 of the ACA and 45 C.F.R. § 92.8(d)(1) required plans to “post taglines in at least the top 15 languages spoken by individuals with limited English proficiency of the relevant State or States;”

However, this is one of the requirements that was repealed in the 2020 Final Rule.

Does a document that's been translated still need taglines?

Yes, you would need to include taglines in all of the prevalent languages in the service area, regardless of what language the document is in.

The intention of the tagline is that someone can still figure out who to call for help if they don’t speak the language of the overall document or if they need a different format.  For example: If a member’s preferred language is Vietnamese but they received a document in Russian by mistake, they could use the Vietnamese tagline to know who to call for help.  

Does a postcard still need taglines?

Postcards still need a language access statement in 18 pt font. Because space is limited, the expectation is including at least one tagline in the same language as the document.

Readability

Readability of member documents should be Grade 6 on the Flesch-Kincaid Grade Level scale.

  • Grade range is 6.0 to 6.9
  • Preferred scoring method: Microsoft Word readability analysis
  • References: OAR 410-141-3580 (6) (c); 42 CFR § 438.10
Tips for reducing readability scores
Use active voice.
Talk about one idea per sentence.
Use short words and short sentences.
Avoid jargon and acronyms.
Add punctuation to lists and headlines.

Learn more about what we exclude during readability reviews in the Readability Scoring Guide.
Document submissions

Do I need to submit every document for OHA approval?

No. OHA has provided Submission Guidance to clarify what types of documents need to be reviewed.

Do I need to resubmit a document that was already approved?

It depends on how long it's been since approval.

No resubmission needed

  • Document was approved within last 6 months.
  • Contact information or date changes; minor formatting changes.

Resubmission needed

  • Document was approved more than 6 months ago.
  • There were changes to the document's messaging.

Will OHA assign an approval number for documents?
OHA tracking numbers were retired in 2020 as we moved to using automatically generated SharePoint ID numbers. Some CCOs continue to use their own tracking numbers.

  • You are welcome to use whatever method works best for your team.
  • OHA will continue to use the automated SharePoint ID number to reference documents.

SharePoint help


  • OHA uses a SharePoint team site to track documents and issue approvals
  • MCE Materials Review SharePoint site **Requires login credentials**

  • How do I request permission for a new employee?
    Please send a request to
    tiffany.t.reagan@dhsoha.state.or.us with the following information:

    • Name
    • Email
    • Title
    • CCO-OHA Access Agreement number
    • Partner number (P#), if they already have one assigned

    Who do I contact if I have trouble logging into my account?
    Please call the DHS-OHA Service Desk at 503-945-5623 for help with password issues and login errors.

    Formatting

    Should I use brackets or carets to note variable data?

    You can use either symbol. Both are acceptable for our review process, as most variable data fall into our list of readability exclusions.

    Marketing


    OHA must review communications when:

    • They are intended to compel or entice1 a client’s enrollment in a CCO,
    • The client is not a member of the CCO, and
    • The provider is an employee, network provider, agent, or contractor of the CCO.

    Examples of material subject to OHA review
    If a CCO or provider used these phrases in material to clients not enrolled in the CCO, OHA would need to approve the material before it could be shared with the client/potential member.

    • “Choose CCO Y so you can get your care with Provider X.”
    • “Provider X will continue to provide you care if you select CCO Y.”
    • “OHP members must select CCO Y to be able to see Provider X.”

    Permitted communications
    State rules permit communications to create name recognition; and to express participation in or support for a CCO by the CCO’s subcontractors or founding organizations, as long as they do not attempt to attract, urge, pressure, or otherwise entice or compel a member to enroll in a CCO.


    Examples of permissible communications about CCO/provider affiliations

    • “Provider X is contracted with CCO Y.”
    • “CCO Y members may choose Provider X as their Primary Care Provider/Home.”
    • “Provider X looks forward to serving CCO Y members” or “CCO Y and Provider X look forward to serving Oregon Health Plan members.”