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In Lieu of Services Technical Assistance

In Lieu of Services (ILOS) are services determined by the state to be medically appropriate and cost-effective substitutes for covered services or settings under the State Medicaid Plan. ILOS must meet requirements outlined in 42 CFR 438.3(e)(2). Coordinated care organizations (CCOs) are not required to offer ILOS to members. A member cannot be required to use the alternative service or setting.

Supporting health system transformation

ILOS can support key services, such as the Diabetes Prevention Program and traditional health care workers, and enables covered services to be provided in non-traditional settings.

ILOS also connects to the larger vision for CCO 2.0 and key transformation objectives by:

  • Improving access to services in a more culturally responsive manner;
  • Enhancing care coordination for high-need/traditionally underserved members; and
  • Reducing hospital care, nursing facility care, and emergency department utilization.

ILOS technical assistance

ILOS 101 webinar

Learn about the background and basic criteria of ILOS. CCO Operations Director Dave Inbody will present highlights of ILOS guidance updates, share upcoming opportunities and answer questions. Anyone interested in learning about ILOS is welcome to attend. 

  • Thursday, October 12, 2023
  • 1–2 p.m. Pacific Time
  • Register in advance (required): After registering, you will receive a confirmation email from Zoom containing information about joining the meeting.

ILOS billing office hours

An overview of billing guidance released in the ILOS Billing Guide and time to talk through specific ILOS billing questions with Mary Durrant (OHA Claims and Encounter Data Services Unit) and Dave Inbody (OHA Health Systems Division). This session will be most helpful for CCO staff working on ILOS. 

  • Monday, October 30, 2023
  • 1–2 p.m. Pacific Time
  • Register in advance (required): After registering, you will receive a confirmation email from Zoom containing information about joining the meeting.

CCO ILOS technical assistance

Individualized technical assistance is available to CCOs interested in implementing ILOS. Please reach out to Bethany Linscott-Lowe ( and Hannah Bryan ( with any questions or to set up a meeting.

ILOS guidance

For ILOS guidance including a coding resource guide, FAQ and more, see the Health System Division ILOS webpage.

ILOS resources

Webinar: CCO Introduction to In Lieu of Services: Recording / Slides

SHARE, HRS and ILOS comparison document (updated September 2023): This document provides an overview of CCO spending programs to meet members’ and communities’ needs, including examples of allowable interventions.

Moving Upstream: Investing in the Social Determinants of Health and Equity through HRS, SHARE and ILOS
CCO staff and key partners attended the September 2023 annual convening on investing in social determinants of health and equity (SDOH-E) through OHA Medicaid spending initiatives. 


For questions related to ILOS technical assistance, contact the OHA Transformation Center at

For ILOS program questions, please see the Health System Division ILOS webpage.