Behavioral Health Practice Guide: Oregon EHR, Billing, and Compliance (2026)

OHA Licensing and Certificate of Approval

Oregon behavioral health programs are licensed by the Oregon Health Authority (OHA) Behavioral Health Division through the Licensing and Certification unit. Outpatient behavioral health clinics receive a Certificate of Approval (COA) after demonstrating their organization meets OHA regulatory requirements. Providers interested in obtaining a COA submit applications to LCApplications@oha.oregon.gov.

2026 Licensing Change for Associates

Starting October 1, 2026, behavioral health associates will be required to either become licensed or work for an agency that holds an OHA-issued COA. This applies to:

• Clinical social work associates
• Board-registered marriage and family therapist associates
• Board-registered professional counselor associates

This change ends the current policy allowing board-registered behavioral health associates to bill Medicaid in private practice settings that do not have a COA. It represents a significant shift that will affect how associate-level clinicians practice and bill in Oregon — organizations must plan for either obtaining a COA or transitioning associates to fully licensed status.

Individual Practitioner Licensing

Individual practitioners are licensed through profession-specific boards: the Board of Psychology, the Board of Licensed Professional Counselors and Therapists, the Board of Licensed Social Workers, and the Mental Health and Addiction Counseling Board of Oregon (MHACBO). MHACBO certifies and registers addiction counselors and prevention specialists.

Oregon Health Plan and Coordinated Care Organizations

The Oregon Health Plan (OHP) — Oregon's Medicaid program — operates through 16 Coordinated Care Organizations (CCOs) that integrate physical, behavioral, and dental health care under a single organization. This is a distinctive model that gives CCOs responsibility for the full spectrum of care, including behavioral health.

Major CCOs

• Health Share of Oregon — Portland metro area (largest CCO by enrollment)
• CareOregon — serves multiple regions including Portland metro
• Trillium Community Health Plan — Lane County and other regions (expanding in 2026 after PacificSource's exit from Lane County)
• PacificSource Community Solutions — Central Oregon, Columbia Gorge, Marion and Polk counties
• Eastern Oregon Coordinated Care Organization (EOCCO) — eastern Oregon
• AllCare CCO — southern Oregon
• InterCommunity Health Network (IHN-CCO) — Benton, Lincoln, and Linn counties
• Jackson Care Connect — Jackson County (consistently highest-rated by members)
• Columbia Pacific CCO — Clatsop, Columbia, and Tillamook counties
• Umpqua Health Alliance — Douglas County
• Yamhill Community Care Organization — Yamhill County
• Advanced Health — Coos and Curry counties

2026 CCO Changes

PacificSource will no longer be a CCO in Lane County in early 2026. Most OHP members in Lane County covered by PacificSource will transition to Trillium Community Health Plan. OHA has renewed contracts for most CCOs in 2026 and increased CCO payments by an average of 10.2% to address financial pressures and maintain provider networks — CCOs collectively had only a 0.02% profit margin through mid-2025.

Billing, Directed Payments, and Authorization

Behavioral Health Directed Payments (2026)

One of the most significant 2026 changes for Oregon behavioral health providers is the behavioral health directed payment requirement. CCOs must pay at least 110% of the OHP open card rate to qualifying behavioral health providers. In 2026, this enhanced rate applies specifically to providers who qualify as Team-Based High Acuity Medicaid Providers, as defined by OHA.

OHA is narrowing eligibility to focus on providers offering team-based care for people with the most complex behavioral health conditions. An annual attestation process, effective January 1, 2025, is required for qualified providers to receive the three behavioral health directed payments within CCO contracts. OHA is also offering additional CCO funding if behavioral health costs exceed revenue in 2026, while requiring refunds if behavioral health costs are below targets.

Timely Filing

Timely filing requirements vary by CCO:

• CareOregon: valid claims must be received within 120 days — exceptions for retroactive enrollments and Medicare/TPL primary payer situations
• OHP fee-for-service: claims must be filed within 12 months of the date of service under OAR 410-120-1300
• Other CCOs: timely filing periods vary — contact the specific CCO for their requirements

Claims Routing

If the patient is enrolled in a CCO, behavioral health claims go to the CCO — not to OHP fee-for-service. Rates and billing rules are CCO-specific, which means practices serving patients across multiple CCOs must configure their EHR for multi-payer routing. For coding guidance, see our mental health billing codes guide.

SUD Licensing and Measure 110

Substance use disorder treatment programs in Oregon are licensed by OHA Behavioral Health Division through the same COA framework as mental health programs. Individual SUD counselors and prevention specialists are certified through MHACBO (Mental Health and Addiction Counseling Board of Oregon).

Measure 110 and the BHRN System

Ballot Measure 110 (Drug Addiction Treatment and Recovery Act), approved by Oregon voters in November 2020, created the Behavioral Health Resource Network (BHRN) system funded by cannabis tax revenue — approximately $800 million in total dedicated funding. The legislative history includes:

• SB 755 (2021): established Behavioral Health Resource Networks
• HB 2513 (2023): clarified BHRN roles
• HB 4002 (2024): recriminalized possession of controlled substances
• SB 610 (2025): shifted the Oversight and Accountability Council (OAC) from decision-making to advisory capacity, with grant authority transferring to OHA effective January 2026

EHR Data Integration Requirements

OHA is implementing two new data systems that will integrate with electronic health records and collect more complete data on BHRN clients. All Measure 110 grantees will be required to submit data through these systems by November 2026. A December 2025 state audit found that the program "lacks stability, coordination, and clear results," driving the push for better data collection and accountability.

SUD providers must comply with federal 42 CFR Part 2 requirements for substance use disorder record confidentiality, including the 2024 final rule changes.

Telehealth Rules

Oregon has strong telehealth protections for behavioral health providers, including permanent payment parity and comprehensive modality coverage.

Payment Parity

Oregon law requires that health benefit plans and dental-only plans must pay the same reimbursement for a health service regardless of whether it is provided in person or via telemedicine. This permanent payment parity requirement applies across all permissible telemedicine modalities.

Modalities and Coverage

Oregon Medicaid reimburses for all four telehealth modalities: live video, store-and-forward, remote patient monitoring, and audio-only. Carriers may use telemedicine providers to satisfy up to 30% of network adequacy requirements for behavioral health care services, acknowledging the role of telehealth in addressing access gaps.

Behavioral Health Parity Reporting

Senate Bill 824 (2025) restored and made permanent the quantitative data reporting requirements for behavioral health parity under ORS 743B.427. This legislation removed previous sunset language and ensures ongoing carrier reporting to the Department of Consumer and Business Services (DCBS). All reported data is confidential and not subject to public disclosure.

EHR systems must support telehealth documentation, modality-specific coding, and the ability to track telehealth utilization data that supports parity compliance analysis.

Reimbursement Landscape

Oregon's behavioral health reimbursement is shaped by the CCO model, directed payments, and the state's commitment to maintaining behavioral health provider networks. Key features of the 2026 landscape:

• CCO rate increase: An average 10.2% increase in CCO payments for 2026, designed to help CCOs maintain provider networks after near-zero profit margins
• Directed payments: 110% of OHP open card rate for qualifying Team-Based High Acuity Medicaid Providers
• Behavioral health cost corridors: OHA offers additional CCO funding if behavioral health costs exceed revenue, with refund requirements if costs are below targets
• OHP fee schedule: Published by OHA for fee-for-service claims, with CCO rates potentially varying from FFS rates

Major commercial payers in Oregon include Regence BlueCross BlueShield, Providence Health Plan, Moda Health, Kaiser Permanente, and PacificSource Health Plans. For revenue cycle management strategies, see our behavioral health revenue cycle guide.

EHR and PDMP Requirements

EHR Adoption and Optimization

Oregon has established health IT requirements through the Health Information Technology Oversight Council (HITOC) and OHA's Office of Health Information Technology and Analytics Infrastructure. CCOs report annually on their progress in supporting EHR adoption, use, and optimization among their provider networks, as well as their use of and support for health information exchange.

The Measure 110 BHRN data system requirements — requiring all grantees to submit data through EHR-integrated systems by November 2026 — add a state-specific EHR capability requirement for SUD and behavioral health providers participating in the BHRN system.

PDMP Integration

Oregon's Prescription Drug Monitoring Program requires prescribers to query controlled substance history. OHA's HIT Commons has supported PDMP integration initiatives to bring PDMP data into clinical workflows. EHR integration with Oregon's PDMP supports both clinical decision-making and compliance with prescribing requirements.

CCO Reporting

Behavioral health providers contracting with CCOs face reporting requirements that vary by CCO. OHA publishes reporting templates and contract-related documents for behavioral health providers. EHR systems must support quality measure tracking, outcomes reporting, and data submission to CCOs for contract compliance.

42 CFR Part 2 Compliance

Oregon SUD providers must comply with federal 42 CFR Part 2 requirements. The state's CCO integration model — which combines physical, behavioral, and dental health under one organization — creates particular data-sharing considerations under Part 2. EHR systems must control what SUD data is shared with CCOs and downstream providers.

Workforce Initiatives

Oregon has not yet enacted PSYPACT or the Counseling Compact, putting it behind most states in interstate licensure compact participation. However, the state has developed its own workforce programs:

Interstate Compact Status

• PSYPACT: The Oregon Board of Psychology requested 2025 legislation, but the proposal was not approved as a board-introduced bill. House Bill 3339 was introduced by Representative Diehl in 2025 as an alternative vehicle.
• Counseling Compact: The Board of Licensed Professional Counselors and Therapists similarly requested 2025 legislation, which was not approved. House Bill 3351 was introduced by Representative Diehl in 2025.

The absence of compact membership means Oregon behavioral health practices cannot leverage interstate telehealth in the same way that providers in PSYPACT and Counseling Compact states can. Out-of-state clinicians must obtain full Oregon licensure to serve Oregon patients.

Behavioral Health Workforce Initiative

OHA operates the Behavioral Health Workforce Initiative, which develops a diverse behavioral health workforce through:

• Scholarships for behavioral health education
• Loan repayment programs for behavioral health professionals
• Retention programs to reduce workforce turnover
• Peer workforce development programs
• Grants to licensed behavioral health providers for clinical supervision of residents

These programs can offset some of the recruitment challenges created by the lack of interstate compact participation.

Parity and Regulatory Environment

Oregon has taken meaningful steps to strengthen behavioral health parity enforcement through permanent reporting requirements and CCO accountability mechanisms.

• SB 824 (2025): Restored and made permanent quantitative data reporting requirements for behavioral health parity under ORS 743B.427, ensuring carriers must provide ongoing parity compliance data to DCBS.
• CCO behavioral health cost corridors: OHA's 2026 approach of providing additional funding for CCOs with high behavioral health costs while requiring refunds from CCOs with low costs creates a structural incentive to invest in behavioral health services rather than under-providing them.
• Directed payment requirements: The 110% minimum rate for qualifying providers establishes a reimbursement floor that addresses chronic behavioral health underpayment within the CCO system.
• Network adequacy: The provision allowing carriers to satisfy up to 30% of behavioral health network adequacy through telemedicine acknowledges access challenges while capping telehealth-only network strategies.

The Oregon Department of Consumer and Business Services (DCBS) oversees parity enforcement for commercial insurance. Behavioral health practices should track denial rates and reimbursement patterns by CCO and commercial payer to identify potential parity issues.

Top EHR Picks for Oregon Behavioral Health Practices

Oregon's 16-CCO billing landscape, directed payment attestation requirements, Measure 110 data integration mandates, and the October 2026 associate licensing deadline create unique EHR requirements. Based on these demands:

• Ease: strongest fit for Oregon practices needing AI-native productivity, multi-CCO billing automation, directed payment qualification tracking, and end-to-end operational automation for organizations scaling across CCO service areas.
• AZZLY Rize: practical choice for organizations prioritizing all-in-one BH/SUD workflow depth with integrated treatment planning, CCO-specific billing configuration, and faster onboarding — well suited for BHRN grantees preparing for the November 2026 data submission deadline.
• PIMSY: solid option for mid-size practices wanting balanced behavioral health workflow support with configurable multi-CCO billing and moderate implementation complexity.

Compare these and other options in our behavioral health EHR comparison and best EHR for mental health evaluations.

Frequently Asked Questions

How does Oregon license behavioral health programs?

OHA Behavioral Health Division issues Certificates of Approval (COA) for outpatient behavioral health clinics. Starting October 1, 2026, behavioral health associates must either become licensed or work for a COA agency. Individual practitioners are licensed through the Board of Psychology, Board of Licensed Professional Counselors and Therapists, Board of Licensed Social Workers, or MHACBO.

How does Oregon Medicaid billing work through CCOs?

OHP operates through 16 CCOs that integrate physical, behavioral, and dental care. Major CCOs include Health Share of Oregon, CareOregon, Trillium, PacificSource, EOCCO, AllCare, and IHN-CCO. Claims for CCO-enrolled members go to the CCO, not OHP FFS. Timely filing varies by CCO — CareOregon requires 120 days, OHP FFS requires 12 months.

What are Oregon behavioral health directed payments?

In 2026, CCOs must pay at least 110% of the OHP open card rate to qualifying Team-Based High Acuity Medicaid Providers. Annual attestation is required. OHA also offers additional CCO funding if behavioral health costs exceed revenue, while requiring refunds for low behavioral health costs.

What are Oregon's telehealth rules for behavioral health?

Oregon requires payment parity across all telehealth modalities. Medicaid reimburses for live video, store-and-forward, remote patient monitoring, and audio-only. Carriers may use telemedicine providers for up to 30% of behavioral health network adequacy. SB 824 (2025) made permanent the quantitative behavioral health parity reporting requirements.

How does Measure 110 affect behavioral health providers?

Measure 110 created BHRNs funded by approximately $800 million in cannabis tax revenue. HB 4002 (2024) recriminalized drug possession. SB 610 (2025) shifted the OAC to advisory capacity with grant authority transferring to OHA in January 2026. All grantees must submit data through new EHR-integrated OHA systems by November 2026.

Does Oregon participate in PSYPACT and the Counseling Compact?

Not yet. Both PSYPACT (HB 3339) and the Counseling Compact (HB 3351) were introduced in the 2025 legislature by Representative Diehl but have not been enacted. Oregon operates its own Behavioral Health Workforce Initiative with scholarships, loan repayment, and clinical supervision grants.