Oregon’s behavioral health system is experiencing accelerating demand, with needs that vary significantly across communities and specific services. To better support this evolving landscape, Oregon Health Authority (OHA) is narrowing the scope of its behavioral health directed payments beginning in 2026. This change is intended to give Coordinated Care Organizations (CCOs) greater flexibility to manage the behavioral health (BH) benefit in ways that are responsive to local needs, provider capacity, and system priorities. By adjusting requirements tied to directed payments, OHA is providing CCOs with more flexibility to structure provider contracts that reflect regional realities and support innovation in care delivery.
It is important to emphasize that the rates OHA pays CCOs were not cut as part of this change. Development of the 2025 and 2026 CCO rates reflects historical BH directed payment levels. The utilization trends applied to the 2026 rate development were increased to reflect the expectation for continued high demand for behavioral health services. These adjustments ensure that CCOs have the financial support to continue paying providers at levels consistent with past directed payments, even as the structure of those payments evolves.
As Oregon continues to face high demand for behavioral health services and limited financial resources, OHA is making important changes to how it supports behavioral health care for Oregon Health Plan (OHP) members.
Following are additional details in a Q&A format regarding the changes OHA implemented in CCOs’ 2026 capitation rates and contracts.
What’s Changing?
In 2025, OHA required CCOs at least pay at 110% of the OHP open card reimbursement rate to most behavioral health providers serving OHP members if their service revenue from Medicaid was over 50%. Beginning in 2026, this requirement will be focused on providers offering team-based care – see “Who Qualifies” Q&A below. The list of covered services at those providers is expected to be same as the list in the 2025 “Primarily Medicaid” BH directed payments guidance document. (See pages 4 & 5 in the document.) This change is designed to ensure that OHA’s limited resources are focused on supporting OHP members with the most complex behavioral health needs, who require more advanced, coordinated care.
Why Team-Based Care?
Individuals with complex behavioral health needs benefit most from care delivered by diverse, integrated teams of professionals. By directing payments to providers who offer this level of care, OHA is using its limited resource to help ensure that these members receive the high-quality, comprehensive support they need and deserve.
Were CCO Payment Rates Cut?
No, the capitation rates OHA pays to CCOs were not cut. In fact:
- The 2026 rate development is based on the 2024 directed payment levels, maintaining a similar overall funding level into 2026 to support behavioral health and other OHP services.
- Utilization trends were increased in the 2026 rate development to reflect continued high demand for behavioral health services.
- The overall CCO 2026 rates grew by an average of 10.2% based on accelerated service delivery in behavioral health and other services.
- These adjustments ensure that CCOs have the financial support to continue paying providers.
What’s changing is how directed payment protections are structured and who qualifies for them, not the overall funding level.
CMS Approval Still Required
The team-based care requirement is currently a proposal submitted to the federal Centers for Medicare & Medicaid Services (CMS) as part of Oregon’s 2026 Behavioral Health Directed Payment Preprint under 42 C.F.R. § 438.6(c).
- This proposal must receive formal CMS approval before it can be implemented.
- CMS has indicated additional scrutiny of all directed payments and additional limitations for directed payments effective after January 1, 2026 as required under HR 1.
- Until approved, the team-based care criteria and associated payment structure remain provisional. Without approval, CCOs would not have an enhanced payment requirement for team-based care providers.
- OHA will notify providers and CCOs once CMS has issued a final decision.
OHA’s Role and CMS Requirements
Under CMS regulations, OHA cannot intervene in rate negotiations between CCOs and providers unless there is an approved directed payment arrangement in place.
- Without CMS-approved directed payments, OHA cannot mandate specific reimbursement levels between CCOs and providers.
- OHA will continue to support CCOs and providers in aligning payment models with the goal of delivering high-quality, equitable behavioral health care.
Commitment to Equity
We understand concerns about how this change may affect access to culturally and linguistically appropriate care. Culturally and Linguistically Specific Services (CLSS) and Co-occurring Disorder (COD) enhanced payments will continue into 2026 with no changes, reinforcing OHA’s commitment to supporting providers who deliver culturally responsive and integrated care. OHA remains deeply committed to eliminating health inequities. We recognize that:
- Historically marginalized communities often experience more severe and complex health conditions.
- Ensuring access to high-quality, team-based care for those with the most complex needs is a critical step toward health equity.
- Culturally and linguistically appropriate services remain a priority in all aspects of OHA’s behavioral health strategy.
Who Qualifies for Directed Payments in 2026?
To qualify as a Team-Based High Acuity Medicaid Provider, a currently Medicaid enrolled behavioral health provider must meet one of the following.
A. Be a Community Mental Health Program offering one or more of the following:
- Assertive Community Treatment (ACT)
- Early Assessment and Support Alliance (EASA)
- Intensive In-Home Behavioral Health Treatment (IIBHT)
OR
B. Meet all of the following:
- Hold a Certificate of Approval from OHA;
- Derive at least 50% of annual behavioral health revenue from services to OHP members; and
- Provide integrated, team-based care that includes the following, as clinically indicated:
- On-staff psychiatric provider
- Integrated peer support
- Case management services
OHA expects to release the 2026 “Primarily Medicaid” BH directed payments guidance document in November or early December.
OHA will be putting together a training for impacted providers and CCOs, along with an updated attestation template for providers and CCOs. In the meantime, if you have questions or would like to discuss how your organization can prepare for this change, please send inquiries to Actuarial.Services@odhsoha.oregon.gov.
Fee-for-service reimbursement for health care interpreter services, effective July 1, 2025
As of July 1, 2025, all fee-for-service providers can bill up to $67.35 per member per day to help offset the costs of providing health care interpreter services for open card (fee-for-service) members needing help with English. OHA will pay for this cost for encounters that meet the criteria outlined in the updated guidance. Updates include:
- Listing providers not eligible for the add-on fee (based on the interpreter services rule)
- Providers can now bill the add-on fee for visits not using an interpreter on the OHA Health Care Interpreter Registry as long as the provider documents that they made a “Good Faith Effort” to find an interpreter using the registry, and were unable to find one
As a reminder, providers can submit fee-for-service claims to OHA for up to one year from the original date of service. This may be especially helpful for providers who have paid for interpreter services in the past but haven't yet billed OHA for the add-on fee.
 Recent rule revisions
Oregon Administrative Rule (OAR) 410-200-0115: Amended to allow the effective start date of coverage to be adjusted for OHP Bridge - Basic Health Program recipients who experienced a gap in coverage as they transitioned from Marketplace coverage in 2024 to BHP coverage in 2025.
Provider resources
How to complete the fee-for-service Trading Partner Agreement (10/15/2025)
News release: Health Licensing Office publishes FAQs for sign language interpreter educational, legal and medical licenses (10/9/2025)
News release: Measles detection in Marion County wastewater prompts OHA alert to health care providers (10/17/2025)
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