A Step Backward for Providers, Clients and Oregon

Oregon Health Authority’s 2025 behavioral health proposals are sparking significant concern among mental health professionals and the clients they serve. The proposed reversal of a 2016 decision stands out as a particularly troubling development. This 2016 decision, which allowed board-registered associates to work for OHA-licensed entities, but not require the extra-cumbersome Certificate of Authority, is now under threat. The 2025 proposed policy seeks to force associates to work exclusively in Certificate of Authority (COA) agencies such as Community Mental Health Programs (CMHPs) or hospital-based programs. This move not only restricts employment options and wages for associates but also risks disrupting the quality and continuity of care for Oregon Health Plan (OHP) members. Some have even called it serious prejudice.

A Brief History: “Serious Prejudice” in 2016

In 2016, Oregon Health Authority (OHA) behavioral health system made a pivotal change to address a critical gap in mental health services. By allowing board-registered associates—those who have completed their master’s degree but are not yet fully licensed—to work at non-COA agencies, the state expanded employment opportunities and helped alleviate the severe shortage of mental health providers. According to the Oregon Health Authority (2016), “Behavioral health providers registered by Oregon regulatory boards as interns or licensed as non-clinical providers are eligible for and need to enroll as a provider of services in the Oregon Medicaid program and claim for services rendered to Oregon Medicaid recipients.” OHA went on to assert that not having these providers within the system was a “serious prejudice to the public interest, the Authority, Medicaid recipients and eligible providers.” (Oregon Health Authority, 2016)

This 2016 step further aligned Oregon Administrative Rules (OAR) with Federal Center for Medicare and Medicaid Services (CMS) rules such as 42 CFR § 438.214 which reads:

Nondiscrimination. MCO, PIHP, and PAHP network provider selection policies and procedures, consistent with § 438.12, must not discriminate against particular providers that serve high-risk populations or specialize in conditions that require costly treatment. (Provider Selection and Credentialing, 2025)

A MCO is equivalent to a CCO, or Coordinated Care Organization, which is the vehicle for healthcare for medicaid recipients in Oregon. Oregon Board registered Clinical Social Worker Associates (CSWA) are “high-risk population serving” providers who often, for the majority, serve the medicaid population within OHA-licensed-entities, within CCO contracts and CCO credentialing. Not to exclude Oregon Board licensed Marriage and Family Therapist Associates (MFTA) and Professional Counseling Associates (PCA) are also of this kind. They are preventing and treating suicide ideation, homicide ideation and domestic violence to just name a few things these hard working providers are actively doing in various settings throughout the State. Still, OHA wants to remove them from the provider network or give them a cumbersome path that will impact their job security, wage security and ability to serve their present populations in the least restrictive environments.

2025 OHA “Serious Prejudice” Proposal: A Restriction on Freedom

The proposed OAR reversion is an about-face from OHA’s assertions in 2016 that it was a “serious prejudice.” It threatens to undo this progress by mandating that associates no longer treat medicaid recipients under the Oregon Board recognized licenses but instead as Quality Mental Health Professionals (QMHP) within a Certificate of Authority (COA) organization. This move could be interpreted as a violation of said Federal law (42 CFR § 438.214) as it will remove the ability of a provider-type (CSWA, MFTA, PCA) to serve medicaid recipients and be reimbursed for their services within the Oregon Board protected titles.

To further contrast (Masters Degree attained, Oregon Board registered) associate mental health providers with QMHPs, the latter can be bachelor degree educated individuals. This includes registered nurses or occupational therapists who are licensed with the state and only have a bachelors degree. All Oregon Counseling Boards (OBLCSW & OBLPCT) would not accept this education type and training but OHA’s COA holders do. This becomes kinda worse when you learn that they also let non-board registered, bachelor degree attained (within a master’s program for counseling) individuals to also be a QMHPs (Oregon Health Authority, 2021). Here too, the Oregon Counseling Boards do not allow this as it could be interpreted as a watering down of the profession and absolutely not to the definition of CSWA, PCA or MFTA.

Legalities and the present watering down system aside, this change also eliminates the freedom of choice for associates. Forcing them into employment at specific programs, regardless of their career aspirations or preferred work environments, is a restriction on freedom. Such a restriction feels like a step backward, ignoring the diverse needs of both providers and clients in Oregon’s behavioral health system.

For associates, this policy is more than an inconvenience; it’s a significant limitation on their professional growth and livelihood. Outpatient Mental Health Agencies often offer a broader range of therapeutic approaches, specialized training, and innovative treatment models. By contrast, CMHPs may not always align with an associate’s career goals or preferred modalities of care. Furthermore, the pay at CMHPs is sometimes half of what associates might earn at Outpatient Mental Health Agencies, and the work hours for full-time positions are often 10 hours longer per week. Removing the option to work in OHA-licensed (non-COA) organizations effectively denies associates the opportunity to choose the path that best suits their professional development and their ability to survive in today's climate.

Serious Prejudice “Strengthening”

Beyond not aligning with many of its ideals, goals and values, OHA has not fully done the “Community Engagement” part of its rule change process. The OHA Director’s Listening Tour was broad and largely consisted of CCOs, CMHPs, Hospitals and Special Interest Groups with no mention of this specific proposal on any agenda or advertisements. Hardly sounds like a transparent community engagement process for a rule change. Surely providers and OHP members would have attended if it meant decisions could be made that could lead to loosing their jobs and/or providers. Instead the idea jumps over this OHA supposed procedural step and is presented as inevitable with strong pressure to adopt an un-established and potentially unlawful OAR.

There are contradictions aplenty. For example the OHA Director’s Listening Tour Report (2024, December) also plans to “Meaningfully addressing administrative burden in behavioral health.” Yet, OHA’s other listening report proposal, “Strengthening the community mental health workforce” (aka force all associate mental health providers into COA organizations), is the epitome of administrative burden and is also not the recommendation of the HB2235 legislative committee setup to address workforce shortages. It appears that OHA is misrepresenting the HB2235 committee on two fronts. Even the use of the word “Strengthening” is an further example of Orwellian doublespeak as seen by who can be a QMHP and as you will further read about with the impact on clients, schools and communities beyond the workforce themselves.

The Impact on Clients

Clients are the ones who will bear the brunt of this policy change. Many OHP members have formed strong bonds with their associate-level providers, who have been integral to their mental health journey. Forcing associates to leave OHA licensed agencies likely will result in clients losing their trusted providers, a disruption that can set back progress, erode trust in the system and cause significant mental/emotional damage.

Additionally, the quality of care may vary between organizations. Clients may find that the care they receive at CMHPs does not meet their specific needs such as specializations or competencies. They could face longer wait times due to staffing shortages or sparse treatment like monthly appointments. They might have to travel even further for care which is a burden of time and money on a weekly basis. This could lead to a decline in overall satisfaction, deterioration of mental health and outcomes for OHP members.

This policy change could also have profound implications for schools across the state. Stronger Oregon, a program present in more than 10 school districts, relies on associates and licensed providers to serve students. These professionals are critical in addressing the mental health needs of young people in a school setting, where early intervention can be most effective. If the proposed rule is passed, schools might lose these essential providers, forcing them to rely on fewer resources or less specialized staff. This could leave many students without access to timely and appropriate care, compounding the challenges faced by schools and families alike.

Why This Matters

Oregon’s behavioral health system is already strained, with too few providers to meet the growing demand for services. The 2016 decision to expand associate employment opportunities was a forward-thinking solution that addressed this challenge while supporting the increase of mental health providers serving OHP covered Oregonians. OHA-Licensed Agencies, without a COA, have also introduced innovative models that help retain the workforce by reducing burnout. Associates working in these settings often benefit from manageable caseloads, the ability to offer the quality of services that clients need, and a supportive environment. Reversing this decision not only removes vital employment options but also risks exacerbating provider shortages through burnout, restrictions on freedoms, forced relocation, decreases in compensation and disrupting care for some of Oregon’s most vulnerable populations.

A Call to Action

Oregonians are encouraged to take action by contacting their Oregon legislative representatives in the Senate and the House. You can use the COPACT’s (Coalition of Oregon Professional Associations for Counseling and Therapy) online system for electronically submitting a letter to your Oregon representative. There is a link for patients and providers.

Patient Action Alert
Provider Action Alert

You can also sign the petition via google forms: https://forms.gle/Ekcj5sXanNq5GHbT7

Associate’s deserve freedom of choice.

References:

Oregon Health Authority. (2024, December). OHA Director 2024 Statewide Listening Tour. https://www.oregon.gov/oha/Documents/OHA-2024-Listening-Tour-Report_12.2024.pdf

Oregon Health Authority. (2021). Specific staff qualifications and competencies (OAR 309-019-0125). Oregon Secretary of State. https://secure.sos.state.or.us/oard/view.action?ruleNumber=309-019-0125

Oregon Health Authority. (2016). DMAP 50-2016(T). Oregon Secretary of State. https://records.sos.state.or.us/ORSOSWebDrawer/Recordhtml/8023687

Provider Selection and Credentialing, 42 C.F.R. § 438.214 (2025). https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-438/subpart-D/section-438.214

Closing the Loophole: Advocating for Change in Oregon's Behavioral Health Access Rules

Oregon has long struggled to provide adequate mental health care to its residents, and current administrative rules governing Managed Care Organizations (MCOs) and Coordinated Care Organizations (CCOs) exacerbate the problem. Specifically, Oregon Administrative Rule 410-141-3515(14)(d)(C) requires that "Routine behavioral health care for non-priority populations: Assessment within seven days of the request, with a second appointment occurring as clinically appropriate." While this rule sounds promising on paper, its implementation exposes a glaring loophole that undermines the intent of timely access to care.

Misinterpretation of "Assessment"

Across the state, a few Community Mental Health Programs (CMHPs) have reportedly been found to misinterpret or misapply the term "assessment" in this rule. Instead of conducting a comprehensive intake assessment with a qualified mental health provider, CMHPs often perform a brief screening to verify whether an Oregon Health Plan (OHP) member qualifies for services. This cursory interaction is not the thorough evaluation needed to initiate appropriate treatment.

After this superficial screening, individuals are frequently placed on waitlists for months before receiving an actual intake assessment. Following this, clients may wait additional weeks or months for their second appointment, perpetuating delays in the delivery of meaningful care. This systemic failure creates a facade of compliance while leaving vulnerable individuals without the timely intervention they urgently need. Services they could get from a provider outside the closed system, if they allow that option.

Research and Standard Practice

Emerging research and clinical guidelines emphasize the importance of weekly mental health services in the initial stages of treatment. Standard practice for many mental health conditions involves frequent sessions of individual or family therapy to establish rapport, provide psychoeducation, and begin therapeutic interventions. Delaying this critical early care not only undermines treatment efficacy but also places an unnecessary burden on individuals and families already in distress.

Current rules allow for determinations of “clinically appropriate” service frequency, which can result in delays that diverge from established industry standards of care. In some cases, subsequent sessions—such as the second, third, or fourth—may be scheduled more than a month apart, regardless of diagnosis. Questions arise regarding how these determinations are made and who is responsible for defining “clinical appropriateness.” Often, providers are required to adhere to these decisions, potentially normalizing practices that conflict with recommended care standards. It remains unclear whether responsibility lies with the Community Mental Health Program, Coordinated Care Organization (CCO), or other entities. This ambiguity raises potential liability concerns given that weekly sessions are standardized best practices and the divergence is not clinically supported.

The Impact on Mental Health Diagnoses

The consequences of these loopholes are profound, particularly for individuals with time-sensitive mental health diagnoses. Conditions such as major depressive disorder, anxiety disorders, post-traumatic stress disorder (PTSD), and early psychosis require timely and consistent intervention to prevent deterioration. Delayed care can lead to:

• Exacerbation of symptoms: Untreated mental health conditions can worsen over time, leading to increased distress, functional impairment, and even crises such as suicidal ideation or hospitalization.

• Higher long-term costs: Delayed intervention often results in the need for more intensive and expensive care later, including inpatient treatment or emergency services.

• Erosion of trust: Individuals seeking help may lose faith in the system, discouraging them from pursuing care in the future.

Legislative and Regulatory Solutions

To address this issue, Oregon’s legislature and the Oregon Health Authority (OHA) must act decisively to close the loophole in Rule 410-141-3515. Key recommendations include:

1. Clarify the Definition of "Assessment": The rule should explicitly require a comprehensive intake assessment conducted by a qualified mental health professional within seven days of the initial request for care. This will eliminate the ambiguity that allows CMHPs to substitute inadequate screenings.

2. Mandate Timely Follow-Up Care: Establish clear guidelines that require a second appointment to occur within a clinically appropriate time frame, defined as no more than two weeks following the initial assessment.

3. Enforce Accountability: Implement robust oversight mechanisms to ensure compliance by MCOs and CCOs. This includes regular audits, reporting requirements, and penalties for organizations that fail to meet access standards.

4. Expand Capacity: Invest in the mental health workforce and infrastructure to reduce wait times and ensure that timely access to care is feasible through a universal electronic referral tracking system.

A Model Example: CareOregon's Guidelines

One promising framework that Oregon can look to is the guidelines established by the CCO, CareOregon, for routine behavioral health care needs. CareOregon specifies the following timeline:

• Intake/Assessment within 7 days of the request

• Second appointment within 14 days of the request (or sooner if clinically indicated)

• Appointments 3-5 within 48 days of the request for services

• Appointments 2-5 as indicated above must be clinical vs administrative in nature

This model ensures a structured timeline that prioritizes clinical care over administrative delays, providing a roadmap for other CCOs and the state to follow. Importantly, it underscores the necessity of prompt and consistent engagement with qualified mental health providers, addressing both initial and ongoing treatment needs.

Adopting similar standards statewide would eliminate ambiguity, reduce wait times, and improve outcomes for individuals in need of mental health services. CareOregon’s approach demonstrates that meaningful change is possible with clear guidelines and accountability measures.

A Call to Action

Oregon’s mental health care system cannot afford to perpetuate a system that prioritizes appearances over outcomes. This loophole in the interpretation of "assessment" and “clinically appropriate” is emblematic of the larger challenges facing our state’s behavioral health infrastructure. By enacting these changes, we can move toward a system that provides genuine, timely, and effective care—a system that Oregonians deserve.

Use the link to communicate to the Policy Board of OHA your position. Choose your local CCO and let them hear your voice.

https://www.oregon.gov/oha/OHPB/Pages/cco-feedback-survey.aspx

Lets get OHA to focus on what matters.

Why Oregon Should Join the Counseling Compact: Expanding Access to Care and Reducing Costs

Oregon has a unique opportunity to improve access to counseling services, address workforce challenges, and save taxpayer dollars by adopting the Counseling Compact. This multistate agreement allows licensed professional counselors to practice across member states with greater ease, fostering mobility, efficiency, and innovation in the field. Here’s why Oregon must act now to join the Compact.

The Problem: Workforce Shortages and Licensing Barriers

Like many states, Oregon faces a shortage of licensed professional counselors, particularly in rural areas and underserved communities. Current licensing processes create barriers for out-of-state counselors who want to practice in Oregon, limiting the state’s ability to attract and retain talent. These barriers also restrict access to telehealth services, which have become critical for mental health care delivery.

The Solution: The Counseling Compact

The Counseling Compact addresses these issues by allowing licensed professional counselors to practice in all member states under a single multistate license. This reduces the need for duplicative licensing, encourages workforce mobility, and facilitates the use of telehealth technology to reach underserved populations. Importantly, the Compact upholds high professional standards to ensure the safety and well-being of clients.

Cost-Saving Benefits for Oregon

1. Reduction in Administrative Burdens:

   • Oregon’s licensing authority spends significant resources on processing out-of-state applications and managing compliance. Participation in the Compact would streamline these processes, reducing costs by leveraging a centralized database maintained by the Compact Commission.

   • States already participating in similar compacts have reported administrative cost savings of up to 20%.

2. Increased Workforce Participation:

   • By simplifying the path for out-of-state counselors to practice in Oregon, the Compact would help address workforce shortages, particularly in rural and underserved areas. This increased access to care reduces the long-term costs associated with untreated mental health conditions.

   • Telehealth capabilities enabled by the Compact would further extend the reach of Oregon’s counseling workforce, minimizing travel costs for both counselors and clients.

3. Retention of Military-Affiliated Professionals:

   • The Compact supports military families by making it easier for spouses of active-duty service members to maintain their counseling licenses across state lines. This helps Oregon retain skilled professionals who might otherwise leave due to licensing barriers.

Enhancing Access to Mental Health Care

By joining the Compact, Oregon can:

• Expand the availability of licensed counselors in areas with high demand and limited access.

• Promote telehealth services to bridge gaps in care for rural and remote communities.

• Ensure continuity of care for clients who relocate across state lines.

Ensuring Public Safety

The Counseling Compact includes robust safeguards, such as the sharing of disciplinary actions and licensure information among member states. These measures ensure that only qualified and ethical professionals practice in Oregon, maintaining high standards of care.

What’s at Stake?

Without adopting the Compact, Oregon risks:

• Worsening workforce shortages and gaps in mental health care.

• Higher administrative costs for licensing and compliance.

• Limited access to telehealth services, especially in rural areas.

Conclusion: A Step Toward a Healthier Oregon

Joining the Counseling Compact is a strategic and fiscally responsible decision. It addresses urgent workforce challenges, reduces costs, and improves access to vital mental health services for Oregonians. By adopting the Compact, Oregon’s legislators can ensure that the state remains a leader in addressing mental health needs while upholding the highest standards of care.

Now is the time to act. Let’s make Oregon a part of the Counseling Compact and pave the way for a healthier, more connected state.

Full “Ready-to-go” legislative rule is found here: https://prod761aul1.wpenginepowered.com/wp-content/uploads/2022/03/Final_Counseling_Compact_3.1.22.pdf

Why Oregon Should Join the Social Work Licensure Compact: A Path to Cost Savings and Increased Accessibility

In a rapidly evolving landscape of social work, Oregon has an opportunity to lead by example. By adopting the Social Work Licensure Compact, the state can address pressing workforce challenges, reduce bureaucratic barriers, and save significant taxpayer dollars. Here’s why this legislation is not only practical but essential for Oregon.

The Problem: Workforce Shortages and Barriers to Mobility

Oregon, like many states, faces a critical shortage of licensed social workers. Current licensing requirements often demand duplicative and time-consuming processes for professionals relocating to Oregon or seeking multistate practice. These barriers exacerbate workforce shortages and limit access to essential services, especially in underserved rural areas and for marginalized communities.

The Solution: The Social Work Licensure Compact

The Compact streamlines licensing for social workers, enabling them to practice across participating states with a single multistate license. This approach increases mobility, facilitates telehealth services, and supports military families who frequently relocate. Moreover, the Compact ensures rigorous standards, safeguarding public health and safety.

Cost-Saving Benefits for Oregon

1. Reduction in Administrative Costs:

   • Currently, the Oregon Licensing Authority invests significant resources in processing out-of-state applications and managing compliance for practitioners holding multiple licenses. By participating in the Compact, Oregon can utilize a centralized data system maintained by the Compact Commission, reducing duplication and administrative overhead.

   • States already participating in similar compacts report savings of up to 20% in administrative costs.

2. Economic Growth Through Workforce Expansion:

   • Simplifying the licensing process attracts more social workers to Oregon, addressing workforce shortages and expanding service availability. Increased workforce participation leads to better access to care, reducing the long-term costs of untreated mental health issues and social service needs.

   • Telehealth-enabled practice, supported by the Compact, reduces travel costs for social workers and their clients, especially in rural areas.

3. Avoidance of Turnover Costs:

   • Military families and transient professionals often face barriers in maintaining their licenses, leading to unnecessary turnover. Compact membership retains these professionals in Oregon, saving costs associated with recruiting and onboarding replacements.

Enhancing Access to Care

By joining the Compact, Oregon can:

• Increase access to qualified social workers in underserved areas.

• Support telehealth initiatives to reach remote populations.

• Facilitate continuity of care for clients who move across state lines.

Ensuring Public Safety

The Compact includes stringent safeguards, such as the sharing of disciplinary actions and licensure information among member states. Oregon’s participation would bolster these safety measures, ensuring that only qualified professionals serve the public.

What’s at Stake?

Without adopting the Compact, Oregon risks:

• Prolonged workforce shortages.

• Higher administrative costs.

• Barriers to access for vulnerable populations.

Conclusion: A Smart Investment

Joining the Social Work Licensure Compact is a fiscally responsible and forward-thinking decision. It addresses workforce shortages, reduces costs, and enhances access to care for all Oregonians. The time to act is now. Let’s ensure that Oregon remains a leader in providing accessible and effective social services while safeguarding taxpayer dollars.

Oregon’s legislators must seize this opportunity to invest in the future of social work. By adopting the Compact, we pave the way for a healthier, more connected, and economically efficient state.

Full “Ready-to-go” legislative rule is found here: https://swcompact.org/wp-content/uploads/sites/30/2024/01/Social-Work-Licensure-Compact-Model-Legislation.pdf

Revitalizing Oregon's Healthcare: The Case for Reinstating the Common Credentialing Program

The Oregon Common Credentialing Program (OCCP) was established to streamline the credentialing process for healthcare practitioners, aiming to reduce administrative burdens and eliminate duplication. However, in July 2018, the Oregon Health Authority (OHA) suspended the program due to significant challenges that hindered its cost-effective implementation.

This suspension calls for a fresh perspective, especially in today's era of artificial intelligence and advanced software solutions. Revitalizing the OCCP is not only feasible but also essential. By issuing a Request for Proposal (RFP), we can identify capable partners to develop and implement an efficient, modernized credentialing system. Our organization is prepared to bid on this opportunity, bringing our expertise and commitment to the table. However, the first step is to rally our legislators to support and authorize this initiative.

Challenges Leading to Suspension

The suspension resulted from several key issues:

• Financial Constraints: The OCCP was intended to be solely fee-funded without startup funding, leading OHA to cover initial costs with plans to recoup through program fees. Delays in required participation meant fee revenue was not collected as anticipated, creating a budget shortfall.

• Complex Implementation: Designing a program that addressed the complexities of business practices while meeting accrediting entity standards proved more intricate and expensive than initially predicted. This complexity led to extended timelines and increased costs.

• Diminished Stakeholder Support: Over time, support from stakeholders diminished due to the program's complexities and the effort required to change existing business practices to work with a centralized system.

Renewed Interest in Reviving the OCCP

Despite these challenges, the foundational concept of a centralized credentialing system remains compelling. The benefits of such a system include:

• Reduced Administrative Burden: A unified system minimizes repetitive paperwork, allowing healthcare providers to focus more on patient care.

• Enhanced Efficiency: Centralized credentialing accelerates the verification process, facilitating quicker onboarding of practitioners into healthcare networks.

• Improved Data Accuracy: Maintaining a single, up-to-date repository ensures that all stakeholders access consistent and accurate information.

Addressing Logistical Challenges

To successfully revive the OCCP, it's essential to address the logistical challenges of connecting all insurers and credentialing organizations:

• Stakeholder Collaboration: Engaging insurers, healthcare providers, and regulatory bodies to develop standardized processes and ensure widespread adoption is crucial.

• Technological Integration: Developing interoperable systems that can seamlessly communicate across various platforms used by different organizations is necessary for efficiency.

• Sustainable Funding Models: Establishing a financial framework that supports initial development and ongoing maintenance without imposing undue burdens on participants is vital for the program's longevity.

Our Commitment

We are dedicated to investing our knowledge, energy, and resources to develop the technology required to make this system a reality at the lowest possible cost. Our expertise in software development and healthcare systems positions us uniquely to tackle the challenges that previously hindered the OCCP.

Conclusion

Reviving the OCCP presents an opportunity to enhance Oregon's healthcare system by simplifying credentialing processes, reducing practitioner burden, and eliminating duplication. With dedicated investment, stakeholder collaboration, and a commitment to overcoming logistical challenges, Oregon can lead the way in implementing an efficient and effective common credentialing system. This initiative will remove barriers, enabling the swift deployment of healthcare providers across the state to areas where they are needed most.

Call to Action

We urge legislators, healthcare organizations, and stakeholders to come together to support this vital initiative. By collaborating, we can create a streamlined credentialing system that benefits providers and patients alike. Let's work together to make this vision a reality.