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In Lieu of Services


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).

Oregon can propose specific ILOS to Centers for Medicare & Medicaid Services (CMS) for approval on an annual basis. Approved ILOS are included in coordinated care organization (CCO) contracts and become available for CCOs to offer to members. 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 be used to offer services in community-centered ways or in non-clinical settings, supporting key services like certified Traditional Health Worker services and strengthening access to care.

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.
Questions? Please contact

Webinars and meetings

ILOS 101

This webinar covers ILOS basics, technical assistance, and frequently asked questions. (October 2023)

Introduction for CCOs to ILOS

This webinar that covers an overview of ILOS, CCO Contract changes, ILOS use cases, and frequently asked questions. (September 2021)

​Join us for an opportunity to ask questions and discuss ILOS concepts with OHA staff.

Previous sessions

​OHA staff, coordinated care organizations (CCO) and their community partners are invited to collaborate in developing Oregon’s proposed 2025 in lieu of services (ILOS).

OHA requests your ideas and feedback through a series of topic-based discussions in November and December 2023 called ILOS pre-design and design sessions.

ILOS pre-design and design sessions will be held virtually through Zoom. Registration is required to attend. See below the session dates, times and registrations.

Pre-design sessions

November 2023: Recording | ILOS pre-design sessions 2023

Design sessions

CCOs, community partners, and OHA staff

  • November 29, 2023 - POSTPONED
  • December 6, 2023 - POSTPONED

  • December 8, 2023, 10:30 a.m.- noon Pacific
    • Topic: Respite ILOS

  • December 11, 2023, 2-3:30 p.m. Pacific - Registration link
    • Topic: Community paramedicine ILOS

Download and share the UPDATED ILOS design session timeline