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Payer Updates

OHP Billing Change for BH Associates

By George Ruan • July 5, 2026

Last updated: July 5, 2026.

If you are a board-registered behavioral health associate in Oregon — a clinical social work associate (CSWA), a marriage and family therapist (MFT) associate, or a professional counselor (LPC) associate — or you supervise or employ one, here is the short answer: starting July 1, 2027, Oregon Health Authority (OHA) will require these associates to either become fully licensed or work for an agency that holds an OHA-issued Certificate of Approval (COA) in order to serve and bill Oregon Health Plan (OHP) Medicaid members. That change ends the long-standing policy that let associates bill Medicaid from private practice and from settings without a COA. As of this writing the requirement is still in the future, so associates can keep billing OHP under the current policy for now — but the clock is running, and this is the date to plan around.

TL;DR: OHA filed permanent rules on July 1, 2026, but delayed the piece that matters most for associates by a full year. Effective July 1, 2027, board-registered behavioral health associates must be licensed or work at a COA-holding agency to bill OHP Medicaid. It applies whether the client is in a coordinated care organization (CCO) or Open Card (fee-for-service), with a short list of exempt settings. Because the date has moved before (an earlier plan pointed at October 1, 2026), confirm the current effective date on OHA’s page before you make any decision.

One caution up front: this topic has been revised more than once, and older write-ups still floating around the internet cite an October 2026 date that OHA has since superseded. The current, official effective date for the associate billing requirement is July 1, 2027. Always verify against OHA’s live page before acting, because a policy this consequential can shift again.

Sections

What Changed

On July 1, 2026, OHA filed a set of permanent Medicaid rule changes affecting unlicensed behavioral health providers. Most of those changes took effect the same day. The one change with the biggest impact on associates, however, was given a one-year runway.

There are really two moving parts to separate:

  • Effective July 1, 2026 (already in effect): OHA clarified that unlicensed behavioral health providers — including board-registered associates, peer support specialists, qualified mental health associates and professionals, certified alcohol and drug counselors, and problem gambling addiction specialists — must be physically located in Oregon while working for a COA-holding agency. OHA describes this as a clarification of a requirement it says already existed, reflected in updates to rules in OAR division 309-019.

  • Effective July 1, 2027 (still upcoming): board-registered behavioral health associates must either become licensed or work for a COA-holding agency in order to serve and bill Medicaid members. This is the change that ends the current policy of associates billing OHP from private practice and non-COA settings, and it is reflected in changes to OAR 410-172-0660.

In OHA’s own framing, the goal is to make sure OHP members with the most complex behavioral health needs are served by clinicians who have the consistent training, supervision, and agency infrastructure that a COA setting is meant to provide. Whether or not you agree with the rationale, the operational takeaway is the same: the setting an associate works in — not just their registration status — will determine whether their OHP services can be billed after the effective date.

Who Is Affected

OHA is focused on three categories of board-registered associates. These are clinicians who have earned a master’s degree and are registered with a state professional board, but are not yet licensed, and who practice under the clinical supervision of a board-registered, licensed supervisor:

  • Clinical social work associates (CSWAs) registered toward LCSW licensure.

  • Marriage and family therapist (MFT) associates registered toward LMFT licensure.

  • Professional counselor (LPC) associates registered toward LPC licensure.

The reach is broad in one important way: OHA’s page states the policy affects most behavioral health associates caring for OHP members regardless of whether those members are enrolled through a CCO or are Open Card (fee-for-service). In other words, an associate cannot sidestep the requirement simply by billing a particular payer lane.

Exempt settings. OHA has published a list of provider types and care settings that are exempt from the OAR 410-172-0660 change. As of the current FAQ, these include psychology interns (whose administrative examinations differ from directly providing behavioral health care), Federally Qualified Health Centers (FQHCs), Rural Health Clinics (RHCs), Tribal Health Clinics, hospital-based primary care homes practicing integrated behavioral health, School-Based Health Centers, and School-Based Health Services. Exemption lists are exactly the kind of detail that gets refined during rulemaking, so confirm the current list on OHA’s page and FAQ before you rely on any single line item.

The Effective Date to Verify

This is the part to get right, because the date has genuinely moved. Here is the timeline OHA has published:

  • January 2025: OHA announced the underlying policy decision.

  • April 13, 2026: OHA held a Rules Advisory Committee (RAC) meeting on the proposed rules.

  • May 19, 2026: OHA held a public hearing.

  • June 10, 2026: In a memo from OHA leadership, the agency updated the effective date, citing an unprecedented volume of outpatient COA applications and the need to give everyone more time to prepare.

  • June 18, 2026: Final public comment deadline (5 p.m. Pacific Time).

  • July 1, 2026: OHA filed permanent rules. Most rule changes took effect this day; the associate Medicaid-billing requirement did not.

  • July 1, 2027: The COA-or-licensure requirement for board-registered associates billing Medicaid takes effect.

Do not use the old October 2026 date. Earlier communications about this policy pointed to an October 1, 2026 effective date. OHA’s June 2026 rulemaking memo and its most recent FAQ (last updated July 2, 2026) both supersede that with a July 1, 2027 effective date for the associate billing requirement. If a source still says October 2026, it is out of date.

What a Certificate of Approval (COA) Is

A Certificate of Approval is an agency-level certification, not an individual credential. Under Oregon Administrative Rule chapter 309-108, a COA allows an outpatient behavioral health provider organization to employ and use unlicensed staff — roles such as qualified mental health professionals and associates, certified alcohol and drug counselors, certified recovery mentors, peer wellness and peer support specialists, and family support specialists.

To earn a COA, an agency goes through a screening, application, and compliance review that OHA’s Licensing and Certification unit conducts. Per OHA, that review can look at items such as:

  • Program overview and organizational structure.

  • Staff qualifications and personnel records.

  • Policies and procedures.

  • Clinical chart review.

  • Facility inspection, including building and fire codes.

  • Liability insurance.

Two things worth underlining. First, a COA is granted to the organization, so it is the agency — not the individual associate — that holds it. Second, COA requirements are separate from the licensing and credentialing an individual provider must complete to practice in Oregon and to enroll with OHP. A clinician can be enrolled and credentialed and still be unable to bill Medicaid as an associate after July 1, 2027 if they are not licensed and not working under a COA. OHA has said that because of unusually high demand, COA application processing is taking longer than usual — a practical reason not to leave this to the last minute.

If your organization is considering pursuing a COA, OHA directs interested providers to email its Licensing and Certification applications team; the current contact is published on OHA’s behavioral health associate billing page. This post does not walk through the COA application itself, and none of this is legal advice — treat it as a map of where to look, not a compliance opinion.

Why This Matters for Private Practices

Under the current policy, a board-registered associate in a solo or small group private practice can bill OHP for services, provided the usual enrollment, supervision, and coding requirements are met. The July 1, 2027 change is aimed squarely at that arrangement. After the effective date, an associate who is neither licensed nor working for a COA-holding agency will not be able to bill Medicaid for their OHP services.

For a private practice that relies on associates, that leaves a few realistic paths to weigh well before the deadline:

  • Move associates to licensure. If an associate is close to completing supervised hours and exams, mapping their licensure timeline against July 1, 2027 may be the cleanest answer.

  • Pursue a COA for the practice. A practice that wants to keep employing associates for OHP work can explore whether it can meet OHA’s outpatient COA requirements — knowing that application review is currently backlogged.

  • Restructure who sees OHP members. Some practices may shift OHP caseloads to their licensed clinicians and have associates focus on other payers or populations, at least until they are licensed or the practice holds a COA.

  • Partner with a COA-holding agency. An associate could move or contract into a setting that already holds a COA.

None of these is a small operational decision, which is exactly why the one-year runway matters. Waiting until spring 2027 to start a licensure push or a COA application is likely to be too late given current processing times.

CCO and Open Card Implications

A common misconception in Oregon is that the payer lane changes the rules here. It does not. OHA’s page is explicit that the requirement applies to most associates serving OHP members whether those members are enrolled in a coordinated care organization or are Open Card (fee-for-service). So the associate policy is a floor set by the state; it is not something you route around by choosing FFS over managed care.

Two CCO-specific nuances are worth holding in mind. First, OHA’s FAQ acknowledges that CCOs may choose to implement the OAR 410-172-0660 changes before OHA’s statewide effective date. That means a particular CCO could tighten its own network expectations earlier, so a plan-by-plan check is wise if you contract with CCOs. Second — and this is a separate point that trips people up — being enrolled with OHP is not the same as being in-network with a CCO. Enrollment and CCO contracting are distinct steps, and neither one changes the associate billing requirement.

We unpack that enrollment-versus-network distinction in OHP enrollment vs. CCO credentialing, and the broader map in our Oregon Medicaid credentialing pillar guide.

What Associates and Supervisors Should Do Now

If you are the associate or the supervising clinician, the useful work is planning, not panic. A practical sequence:

  1. Confirm the current effective date. Start on OHA’s behavioral health associate billing page and its FAQ, and note the “last updated” date each time you check.

  2. Map the licensure timeline. For each associate, compare their expected licensure date to July 1, 2027. Where it is close, prioritize supervised-hour completion and exam scheduling.

  3. Check whether an exemption applies. If the associate works in an FQHC, RHC, Tribal clinic, or school-based setting, verify the current exemption language rather than assuming.

  4. Decide on a setting strategy. Licensure, a practice COA, restructuring OHP caseloads, or moving to a COA-holding agency — pick a path and give it a real timeline.

  5. Plan client communication carefully. If a client may need to change providers or settings to keep coverage, plan a compliant, clinically sensitive transition well ahead of time. Do not wait until the deadline forces an abrupt handoff.

What Practice Owners Should Verify

Practice owners and managers carry the operational risk here, because a missed transition can mean unbillable OHP services or clients who lose continuity of care. Before the effective date, verify:

  • Which of your clinicians are board-registered associates versus fully licensed, and each associate’s realistic licensure date.

  • Whether your practice holds, or could realistically obtain, a COA — and how long OHA’s current processing backlog might add to that.

  • How many of your OHP members are currently served by associates, so you can size the transition.

  • Whether any of your settings qualify for an exemption under the current, published list.

  • Whether any CCO you contract with intends to apply the change ahead of the statewide date.

  • Your enrollment and credentialing records, so licensed clinicians can absorb OHP caseloads cleanly if you shift work to them.

This post is for general operational education and is not legal, compliance, or billing advice. Always confirm current OHA and CCO requirements before submitting enrollment, claims, or authorizations.

Action Steps for Providers

  1. Re-verify the date on OHA’s page today. Treat July 1, 2027 as current but not frozen, and re-check before any irreversible decision.

  2. Inventory your associates and their licensure timelines. Know exactly who is affected and when.

  3. Choose a path per associate. Licensure, practice COA, caseload restructuring, or a move to a COA-holding agency.

  4. Start any COA application early. Processing is backlogged; time is the scarce resource.

  5. Check exemptions and CCO-specific timing. Do not assume; confirm each against a current source.

  6. Build the client-transition plan now. Protect continuity of care and communicate changes early and clearly.

  7. Keep enrollment and credentialing current. See our guide to enrolling as an Oregon Medicaid therapist so licensed clinicians are ready to take on OHP work.

Where Bomi Fits

Want help keeping Oregon Medicaid billing and credentialing workflows straight through a change like this? Bomi helps therapy practices with eligibility checks, claims, denials, credentialing workflows, payer follow-up, EOB review, and revenue operations, so clinicians can spend more time with clients and less time reverse-engineering rule changes.

For this policy specifically, that means helping you keep the operational pieces aligned as the July 1, 2027 date approaches: tracking which clinicians are licensed versus associate-level, keeping enrollment and credentialing records clean so licensed providers can absorb OHP caseloads, and following up on claims and denials while your setting strategy is in motion. You can see how we approach credentialing and billing operations, or start from the Oregon overview.

The honest version: Bomi cannot license an associate, issue a Certificate of Approval, or guarantee that any CCO adds you to its network — no billing partner can, and OHA and the professional boards own those decisions. What Bomi can do is keep the enrollment, credentialing, eligibility, and claims work organized so fewer OHP dollars fall through the cracks while your practice adapts to the new requirement.

Bottom Line

Oregon is changing who can bill OHP Medicaid as an unlicensed associate. Effective July 1, 2027, board-registered behavioral health associates — CSWAs, MFT associates, and LPC associates — must be licensed or work for a COA-holding agency to serve and bill Medicaid members, across both CCO and Open Card, with a short list of exempt settings. The date moved once already (away from an earlier October 2026 plan), so verify it on OHA’s page before you act. Then use the runway: map licensure timelines, weigh a COA, and plan client transitions now rather than in mid-2027.

FAQ

Who counts as a board-registered behavioral health associate?

For this rule change, OHA is focused on three types: clinical social work associates (CSWAs), board-registered marriage and family therapist (MFT) associates, and board-registered professional counselor (LPC) associates. These are master’s-level clinicians registered with a state professional board but not yet licensed, practicing under a board-registered clinical supervisor.

What is the July 1, 2027 date?

It is the effective date for the requirement that board-registered associates be licensed or work for a COA-holding agency to serve and bill OHP Medicaid members. OHA filed the permanent rules on July 1, 2026 but delayed this particular requirement by one year. Because the date has been revised before, confirm it on OHA’s current page before making decisions.

Does this apply to CCO members and Open Card members?

Yes. OHA’s page states the requirement applies to most associates serving OHP members regardless of whether they are enrolled through a coordinated care organization (CCO) or are Open Card (fee-for-service). Note that a CCO may choose to apply the change before OHA’s statewide effective date, so check plan-specific timing too.

What is a Certificate of Approval (COA)?

A COA is an agency-level certification under OAR chapter 309-108 that lets an outpatient behavioral health organization employ and use unlicensed staff. It is granted to the organization after a screening, application, and compliance review, and it is separate from the licensing or credentialing an individual clinician needs. Individual associates do not hold a COA; their employing agency does.

Can associates in private practice still see OHP clients?

For now, yes — the current policy still allows it, so associates can continue billing OHP from private practice until the requirement takes effect. Starting July 1, 2027, an associate who is neither licensed nor working for a COA-holding agency will not be able to bill Medicaid for OHP services. Confirm the current effective date and any exemptions before relying on this.

What should supervisors and practice owners do first?

Start by verifying the current effective date on OHA’s page, then inventory which of your clinicians are associates versus licensed and map each associate’s licensure timeline against July 1, 2027. From there, decide on a path — licensure, a practice COA, caseload restructuring, or moving to a COA-holding agency — and plan client transitions early. COA processing is backlogged, so an early start matters.

Sources

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