Oregon's Behavioral Health Directed Payment: Who Gets 110% in 2026

As of October 2026, Oregon's behavioral health directed payment requires CCOs to pay at least 110% of the OHP fee-for-service behavioral health fee schedule (rates effective January 1, 2026), but only to "Team-Based Care" providers: CMHPs running ACT/supported employment, IIBHT or EASA, or providers that hold an OHA Certificate of Approval, earned at least half of their prior-year behavioral health revenue from OHP members, and deliver integrated team-based care. Every other outpatient behavioral health provider lost its rate floor on January 1, 2026 and is now paid whatever its CCO negotiates, which at CareOregon is 90% of DMAP rates for outpatient mental health and SUD groups. A program that qualifies but never attested is being paid as if it doesn't, and the effective date only moves forward.

That gap between 110% and a negotiated rate is the largest single swing in Oregon Medicaid behavioral health reimbursement this year. This post walks through who qualifies, what non-qualifiers are actually being paid, how attestation timing works, and what to check before your CCO's next remittance.

What changed in Oregon's behavioral health directed payment for 2026?

Through 2025, Oregon's directed payment protected most behavioral health providers whose revenue was primarily Medicaid. For 2026, the Oregon Health Authority (OHA) narrowed it. OHA's 2026 BH Directed Payment: CCO Requirements and OHA Governance (November 14, 2025) states that CCOs must pay at least 110% of the Oregon Health Plan (OHP) open card rate "only to behavioral health providers who qualify as Team-Based Care Medicaid Providers," and that providers who no longer qualify "do not have a payment floor anymore and are subject to negotiated rates with CCOs."

OHA's October 17, 2025 Provider Matters bulletin is explicit that CCO capitation was not cut to pay for this. The money stayed in the rates; the guarantee moved to a smaller group of providers.

Directed payments are a federal mechanism. A state can require its Medicaid managed care plans to pay providers in a specified way under 42 CFR 438.6(c), but only with a CMS-approved preprint. CMS's approval letter for Oregon's CY2026 behavioral health outpatient minimum-fee-schedule directed payment (OR_Fee_BHO1_Renewal) is dated March 26, 2026 and covers January 1 through December 31, 2026. OHA had told CCOs that a post-January approval would apply retroactively to the start of 2026.

Who qualifies as a Team-Based Care provider?

OHA's Team-Based Care directed payment guidance, updated May 15, 2026, sets two routes.

Route A: automatic. "Providers of ACT/SE, IIBHT, EASA and CMHPs automatically qualify and do not need to submit an attestation to qualify." That covers Assertive Community Treatment and supported employment, Intensive In-Home Behavioral Health Treatment, and Early Assessment and Support Alliance programs.

Route B: attest to all three criteria. Everyone else has to meet every one of these:

• Certificate of Approval. The provider holds a current OHA Certificate of Approval under OAR chapter 309, division 8. No COA, no floor. Our Oregon Certificate of Approval guide covers how to get one.
• At least 50% OHP revenue. At least half of "total patient service BH revenue" came from OHP members in the prior contract year. For 2026 that means your 2025 books.
• Integrated team-based care. The program delivers, as clinically appropriate, psychiatric and/or addiction medicine services, peer-delivered services (CRM, PWS, PSS), and case management, along with individual, group and family therapy.

The third criterion is the one we see trip up otherwise strong programs. A therapy-only group practice with heavy OHP volume clears criteria one and two and still fails, because it has no prescriber relationship, no peers and no case management. Adding peers is a billing project in its own right; see our peer support billing guide.

Who drops below 110%, and how far?

Once a provider falls outside the Team-Based Care definition, OHA sets no minimum. Each CCO decides. The published examples:

Sources: OHA 2026 guidance and the CCO provider pages linked above, checked October 5, 2026. Other CCOs set their own non-qualifying rates; read your contract amendment.

The arithmetic. Here is an illustration only, not a rate: take a program whose OHP outpatient claims would total $100,000 a month at the OHP fee schedule. At a 110% floor it is paid $110,000. At 90% of DMAP it is paid $90,000. That is a $20,000 monthly gap, or $240,000 a year, on the same visits and the same documentation. Put your own volume into that sentence and you have the number you are probably losing.

Do the CLS and co-occurring disorder enhancements still stack?

Yes. These are separate directed payments, and they didn't change in 2026. OHA's 2026 guidance documents set them as add-ons calculated on the OHP fee-for-service schedule effective January 1, 2026:

The practical point is that the team-based floor, ICOD and CLS are tracked separately. A CCO can pay one correctly and miss another. We routinely find programs approved for ICOD whose remits show no add-on at all.

When does the 110% start if you attest now?

This is the most expensive detail in the program. The May 15, 2026 guidance makes the floor effective January 1, 2026 for attestations received by March 31, 2026. After that, it is "effective on the 1st day of a subsequent calendar quarter if the 2026 attestation (and documentation) was received on any date in that quarter." OHA's December 2025 CCO webinar describes the same rule from the CCO side: rates are backdated "to the beginning of the calendar quarter in which a complete attestation is submitted and approved by the CCO."

In practice:

• Attest in October, November or December 2026. The floor reaches back to October 1, 2026 at most. January through September is gone.
• Attest incompletely. The clock runs from a complete submission, so a missing COA copy or revenue worksheet can push you into the next quarter.
• Contract with several CCOs. Attestation goes "to each CCO with which they contract." Qualifying at CareOregon does nothing at Trillium or PacificSource.

OHA posts the provider attestation template on its CCO Contract Forms page, but each CCO runs its own intake. CareOregon uses an online form and reviews in 7 to 10 business days. Cascade Health Alliance wants the COA, the 2026 attestation form and a written description of team-based delivery by email. AllCare takes email or fax.

How do you prove the 50% OHP revenue threshold?

OHA's guidance tells providers to "gather financial information" and submit "supporting documentation as may be required by each CCO." It doesn't prescribe a format. Here is what holds up:

• Use the right denominator. The test is total patient-service behavioral health revenue, not total organizational revenue. Grants, contracts and non-BH lines stay out.
• Use the right year. The test is the prior contract year. Pull 2025 cash or accrual figures consistently and say which you used.
• Count all OHP. Open card and CCO-paid OHP revenue both count as OHP-member revenue. Commercial, Medicare and self-pay go in the denominator only.
• Keep the worksheet. Directed payments are monitored through CCO reporting to OHA. Assume your attestation will be re-examined, and keep the payer-mix report that supports it.

If your OHP share is near 50%, a growing commercial book can quietly push you under the line for 2027. That is a good problem, but plan the rate impact before it happens.

What should you check on your remits right now?

Most programs never reconcile paid OHP claims against the directed-payment floor. Before the year closes, run this checklist:

• Rate floor. Sample paid claims by code and confirm the allowed amount is at least 110% of the January 1, 2026 OHP behavioral health fee schedule, posted on the OHP fee schedule page.
• Effective date. Confirm the CCO applied the floor from the right quarter and reprocessed or paid the difference on claims already adjudicated.
• Add-ons. Confirm ICOD and CLS increases appear on eligible lines, at the right percentage for the rendering staff type.
• Every CCO. Repeat for each CCO contract. They implement independently.
• Non-qualifying rate. If you don't qualify, confirm you are being paid the rate in your amendment, not a lower default.

This is the same work we do under a signed BAA in our free 90-day claims audit: we reconcile paid claims against your contracted and directed-payment rates and return written findings with dollar amounts.

Should a program restructure to qualify?

Sometimes. If you already hold a COA and clear 50% OHP revenue, the gap is usually staffing, not licensing. That means a contracted psychiatric or addiction medicine provider, certified peers, and case management delivered and documented as part of the treatment team. The math is simple: compare the annual cost of those roles, less what they bill, with the floor differential on your OHP volume. For many mid-sized outpatient programs the floor alone covers a meaningful share of that cost, and the clinical model gets better too.

If you don't hold a COA, that's the first decision, and it runs on OHA's licensing timeline, not your billing calendar. Our Oregon Medicaid billing guide and CCO contracting playbook cover the surrounding mechanics. Program design is where our team's operating background matters: we have run the programs these criteria describe, so we know what a team-based model costs to staff and how to document it so a CCO accepts the attestation.

What happens in 2027?

As of October 5, 2026, OHA hasn't posted 2027 behavioral health directed payment guidance on its CCO Contract Forms page, and CMS's current approval covers calendar year 2026 only. Each year's arrangement needs a new CMS-approved preprint. Watch for three things this winter: whether the team-based criteria carry into 2027 unchanged, whether 2027 attestations require fresh 2026 revenue figures (they almost certainly will, given the prior-year test), and whether the base shifts to a 2027 fee schedule. We will update this post when OHA publishes.

Frequently asked questions

Does every Oregon behavioral health provider still get 110% of the OHP rate?

No. Since January 1, 2026, the 110% floor applies only to Team-Based Care providers: CMHPs providing ACT/SE, IIBHT or EASA, and attesting providers that hold a COA, earned at least half their prior-year BH revenue from OHP members, and deliver integrated team-based care. Everyone else is paid a CCO-negotiated rate with no state floor.

What does CareOregon pay outpatient providers that don't qualify?

CareOregon's published 2026 policy pays non-qualifying outpatient mental health and SUD groups 90% of DMAP rates. It pays ABA and SUD residential at 100% of OHA's fee schedule. Other CCOs set their own rates, so check your contract amendment.

If I qualify but missed the March 31, 2026 attestation date, can I still get 110%?

Yes, but only going forward. Under OHA's May 15, 2026 guidance, a later attestation takes effect on the first day of the calendar quarter in which the complete attestation is received. An attestation submitted in the fourth quarter of 2026 reaches back to October 1, 2026 at most.

Do I need to attest separately with each CCO?

Yes. OHA's guidance directs providers to submit the attestation to each CCO they contract with. Each CCO runs its own intake and review.

Do the co-occurring disorder and CLS increases still apply in 2026?

Yes. ICOD adds 10%, 15% or 20% depending on staff type and setting, and CLS adds 22% (non-rural) or 27% (rural). Both are calculated on the OHP fee-for-service schedule effective January 1, 2026, and they are separate from the team-based floor.

Has CMS approved Oregon's 2026 behavioral health directed payment?

CMS's approval letter for Oregon's CY2026 behavioral health outpatient minimum-fee-schedule directed payment (OR_Fee_BHO1_Renewal) is dated March 26, 2026 and covers January 1 through December 31, 2026. OHA had committed that a post-January approval would apply retroactively to January 1, 2026.

See what your billing is leaving uncollected

If you bill OHP through one or more CCOs, there are three numbers worth knowing before year-end: whether you qualify for the floor, whether each CCO is actually paying it, and whether your ICOD and CLS add-ons are landing. Saint Health Group's free billing audit reviews 90 days of your claims under a signed BAA and returns written findings with dollar amounts by payer. If the answer is that your current biller never checked, our behavioral health billing team runs OHP, Medicare and commercial billing for outpatient, IOP, PHP and residential programs, and switching billers takes 7 to 14 days. For the wider revenue picture, see our revenue cycle collections guide and our revenue cycle and payer services.

Request your free 90-day billing audit