Oregon COA Checklist: Every Document OHA Requires
An Oregon Certificate of Approval application under OAR 309-008-0400 needs an implementation plan, compliance attestation, location descriptions, credentialing policies, liability insurance, seclusion and restraint policies, code of conduct, ownership and licensing history disclosures, and any substantiated abuse findings. Policies must cover the 26 areas in OAR 309-019-0110. File at least six months before certification.
Saint Health Group·September 28, 2026 · 8 min read · Last updated October 7, 2026

As of October 2026, an Oregon Certificate of Approval (COA) application is governed by OAR 309-008-0400, and the policy manual behind it by OAR 309-019-0110. The application asks for a service implementation plan, a compliance attestation, five current documents (location descriptions, credentialing policies, liability insurance, seclusion and restraint policies, and a code of conduct), ownership and licensing history disclosures, and any substantiated findings of abuse, neglect, or mistreatment. The policy manual has to cover 26 required areas. If OHA finds the application incomplete, you have 14 calendar days from receiving its written notice to submit an amended application. This checklist walks through every item, cites the rule for each, and gives you a list to work from before you submit.
What Is the Oregon COA, and Who Needs This Checklist?
The Certificate of Approval is Oregon's certification for providers of outpatient mental health, substance use disorder, and problem gambling treatment. OHA administers it under OAR chapter 309, division 008, and ORS 430.637 sets the criteria for the on-site quality assessment that supports it. The outpatient service standards your policies must meet are in OAR chapter 309, division 019. Under OAR 309-008-0250(1), a current certificate is required for a provider that offers behavioral health treatment services by contract with OHA or a public body, or by receipt of other public funds. OAR 309-008-0250(4) exempts an individual practitioner licensed by the applicable board and a provider made up exclusively of such licensed practitioners. If you need the narrative walkthrough of the full approval timeline first, start with our Oregon Certificate of Approval guide and OHA licensing timeline. This post is the checklist you work from once you're ready to assemble the packet.
One distinction matters before you start. A COA is not a residential license. OAR 309-008-0250 says certificates are not a substitute for the licenses residential facilities need under ORS 443.410 and 443.725, so a residential substance use disorder program also applies for a residential license under OAR chapter 415, division 012, and a residential mental health program under OAR chapter 309, division 035. Those applications have their own forms, fees and facility documents; see our Oregon residential SUD licensing guide.
This checklist is written for private-practice and group-practice owners preparing their first COA submission, and for operators adding a COA-certified outpatient service line. ORS 430.637 applies OHA's on-site quality assessment to providers that are not accredited by a national organization meeting OHA's quality standards. Accreditation from CARF or the Joint Commission does not replace the application, audit and certification review under OAR chapter 309, division 008. Ask OHA how your accreditation is treated before you plan your timeline. If you're a group-practice owner tracking Oregon's July 2027 COA deadline for board-registered associates, see our Oregon COA guide for private-practice associates for the deadline-specific context first. Where Joint Commission status is part of the plan, our Joint Commission accreditation consulting covers the gap analysis and mock survey.
What Does the COA Application Itself Require?
OAR 309-008-0400 requires a legible application on OHA's forms that includes:
- Implementation plan. A detailed plan outlining how you will implement the proposed services, consistent with the applicable rules.
- Attestation. A written attestation that you comply with the applicable service delivery rules.
- Service delivery location descriptions. The type and scope of services at each location. Applicants with more than one location must document each one.
- Credentialing policies for the individual practitioners who will deliver services.
- Liability insurance covering every location.
- Seclusion and restraint policies and procedures. For outpatient providers these must prohibit seclusion and restraint, per OAR 309-019-0110(2).
- Code of conduct.
- Ownership disclosure. Every individual or entity with a 5 percent or greater ownership interest.
- Licensing and certification history for the applicant and its owners.
- Substantiated findings. Disclosure of any substantiated findings of abuse, neglect, or mistreatment.
- Any other documentation the applicable rules require or OHA asks for.
Timing is part of the requirement. Initial applicants must submit a completed application at least six months before the date they want to be certified, and renewing providers must request an application and submit a complete one at least six months before the current certificate expires.
What Written Policies and Procedures Must Be in Place Before You Apply?
OAR 309-019-0110 requires every outpatient provider to develop and implement written service delivery policies and procedures for office-based, community-based and telehealth services, available to individuals and families on request. The rule, as amended in October 2024, lists 26 required areas. Reviewers aren't looking for a manual that merely exists; they check whether it matches how the program will actually operate, which is why writing and implementing policies have to happen together.
| Required policy area | OAR 309-019-0110(1) |
|---|---|
| (a) | Personnel qualifications, credentialing, and training |
| (b) | Mandatory abuse reporting |
| (c) | Criminal records checks for program and volunteer staff |
| (d) | Fraud, waste, and abuse in Medicaid and Medicare |
| (e) | Alcohol, drug and gambling free workplace |
| (f) | Fee agreements |
| (g) | Confidentiality under HIPAA, 42 CFR Part 2, and Oregon law |
| (h) | Compliance with Title 2 of the ADA |
| (i) | Grievances and appeals, with an example grievance form |
| (j) | Individual rights |
| (k) | Quality assessment and performance improvement |
| (l) | Trauma informed service delivery |
| (m) | Culturally and linguistically appropriate services |
| (n) | Crisis prevention and response |
| (o) | Incident reporting |
| (p) | Peer delivered services |
| (q) | Prevention of communicable disease transmission |
| (r) | Emergency evacuation |
| (s) | SUD services consistent with the ASAM Criteria for each certified level of care |
| (t) | Code of conduct, including professional boundaries and ethics |
| (u) | Referral, care coordination, and transfer of services |
| (v) | Medical protocols |
| (w) | Urinalysis testing |
| (x) | Mental health advance directives for adults |
| (y) | Voter registration for adults |
| (z) | Quality assurance review, overseen by the clinical supervisor, with quarterly sampling of service plans and assessments |
The same rule also requires your policies to prohibit psychological and physical abuse; seclusion and all forms of restraint; withholding shelter, meals, medication, clothing or supports; discipline of one individual by another; and titration of opioid dependence medications as a condition of receiving or continuing treatment. Programs offering Enhanced Care Services and community mental health programs have additional policy requirements.
What Staffing and Facility Records Should Be Ready?
- Staff qualifications. Credentials for every clinician, supervisor and program director, matched to the qualifications in OAR 309-019-0125.
- Personnel files. Documentation, training and supervision records set out in OAR 309-019-0130.
- Background checks. Criminal records checks for program and volunteer staff, consistent with your policy under 309-019-0110(1)(c).
- Building readiness. Each location must meet OAR 309-019-0205. Keep up-to-date documentation of your local business license, zoning, building code, and fire and safety compliance in the file, along with your lease and floor plan as supporting records.
What Happens After You Submit?
Under OAR 309-008-0500, OHA conducts a comprehensive audit of your application materials within 60 days of receiving them. If anything is incomplete or out of compliance, OHA sends a notice and you have 14 calendar days to submit an amended application. A certification review follows. OHA may complete it on site or as a desk review, and any findings may require a Plan of Correction that OHA approves before the certificate issues. Under OAR 309-008-0900, an initial certificate is valid for up to one calendar year and a renewal for up to three. The certificate lists the service delivery rules you are approved under, and an accompanying letter lists every approved location. For the full step-by-step timeline, see our OHA licensing timeline.
Oregon COA Application Checklist FAQ
What documents do I need to apply for an Oregon Certificate of Approval?
Under OAR 309-008-0400: a completed OHA application with a detailed plan for implementing the proposed services, a written attestation of compliance, descriptions of each service delivery location, your credentialing policies, proof of liability insurance, seclusion and restraint policies, a code of conduct, the names of everyone with a 5 percent or greater ownership interest, your licensing and certification history, and any substantiated findings of abuse or neglect. Your full policy manual must also cover the 26 areas in OAR 309-019-0110.
How far ahead should I apply for an Oregon COA?
At least six months before the date you want to be certified, per OAR 309-008-0400. Renewals are also due at least six months before the current certificate expires. OHA has 60 days to audit the application materials, and if it finds gaps you have 14 calendar days from its notice to send an amended application.
Do I need a COA if I'm already accredited by CARF or the Joint Commission?
Yes, if you provide behavioral health services under contract with OHA, a public body, or with other public funds. ORS 430.637 applies OHA's on-site quality assessment to providers that are not accredited by a national organization meeting OHA's quality standards, and it lets OHA rely on assessments performed by another state agency or its contractor. It does not remove the application and documentation requirements in OAR 309-008-0400.
What written policies must be in place before I submit a COA application?
OAR 309-019-0110 lists 26 required policy areas, lettered (a) through (z), for outpatient behavioral health providers. They run from personnel qualifications and abuse reporting to ASAM-consistent SUD services, urinalysis testing and a quarterly quality assurance review. The rule also requires policies that prohibit abuse, seclusion and restraint, and withholding of basic needs. The full list is in the table above.
What happens if my COA application is incomplete?
OHA audits the application within 60 days of receiving it, under OAR 309-008-0500. If materials are missing or noncompliant, you have 14 calendar days from OHA's notice to submit an amended application. That short window is why it pays to assemble every document before you file.
How long is an Oregon COA valid once issued?
Under OAR 309-008-0900, an initial certificate is valid for up to one calendar year and a renewal for up to three. One certificate lists every service delivery rule you are approved under, so adding a service or location means a modification, not a second certificate.
Get Every Document Right the First Time
A missing insurance certificate or an unsigned policy is a small thing to fix and a large thing to have stall your certification. Saint Health Group doesn't just hand private-practice and group-practice owners this checklist; we write the policies and procedures to match how your program actually operates, assemble the full application packet, and run a readiness review before anything goes to OHA, so your first submission is a complete one. Because COA compliance rarely stands alone, we also handle the adjacent pieces operators need at the same stage: payer contracting and credentialing, revenue cycle setup, and the accreditation path if CARF or Joint Commission status is part of your plan. See how our Oregon licensing consultants run this process end to end, explore our full licensing & accreditation and compliance & risk services, or contact us to start your COA application checklist review.
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