Behavioral Health Changes in Oregon, Washington, Idaho and California

What changed. A temporary rule effective October 1, 2026 through March 29, 2027 allows an agency to apply for a Certificate of Approval and employ Alcohol and Other Drug Screening Specialists without each specialist holding individual certification. The rules cover individual and agency COA application, renewal, review, revocation, denial, suspension and conditions.

What it means. Programs that receive DUII screening referrals should decide whether an agency COA fits their staffing better than individual certifications. Calendar March 29, 2027, when the temporary rule expires unless OHA makes it permanent.

What changed. Effective October 1, 2026, board-registered associates can no longer treat or bill for behavioral health services provided to PacificSource Commercial and Medicare members. The change does not apply to Medicaid. Members seeing an associate must move to a licensed provider for services to remain billable.

What it means. Pull a list of PacificSource Commercial and Medicare members currently assigned to associates and move them to licensed clinicians now. Hold any claims for those members with an associate as rendering provider for dates of service on or after October 1.

What changed. OHA reorganized the Traditional Health Worker certification rules effective October 1, 2026. A reciprocity pathway covers holders of non-Oregon CHW, PHN, Peer Support Specialist and Peer Wellness Specialist certifications. A legacy pathway requires 3,000 verifiable hours in the past five years for CHWs, Peer Wellness Specialists and PHNs, or 2,000 hours for Peer Support Specialists, plus at least one professional recommendation letter.

What it means. Review peer staff and candidates with out-of-state credentials or long work histories for eligibility under the new pathways. Update hiring and credentialing checklists to reference the reorganized OAR 950-060 sections.

What changed. Commerce proposed new chapter 365-25 WAC for the Office of Behavioral Health Advocacy. Proposed WAC 365-25-060 gives certified behavioral health consumer advocates access to behavioral health providers or facilities as necessary for complaint and grievance resolution, and access to patient records with explicit patient consent or as legally permitted. A virtual hearing is October 13, 2026, written comments are due October 16, 2026 at 5:00 p.m., and the intended adoption date is October 23, 2026.

What it means. Review how your grievance policy and release of information process would handle a certified advocate's request for access or records. Submit comments by October 16 if the access language needs clarification for your setting.

What changed. HCA's fee-for-service Substance Use Disorder Billing Guide takes effect October 1, 2026. It updates the definition of the ASAM criteria and requires combination therapy codes to be billed with the appropriate modifier. Buprenorphine/naloxone is billed by tablet strength dispensed, so a 10mg dose dispensed as 2mg and 8mg tablets is one unit of J0572 and one unit of J0574, not J0575.

What it means. Check your billing system's code and modifier setup for buprenorphine/naloxone and combination therapy against the guide's Coverage Table. Confirm claims carry the SUD billing taxonomy for dates of service on or after October 1.

What changed. HCA's Mental Health Services Billing Guide, effective October 1, 2026, adds a group treatment section. Group treatment may not start before the intake evaluation and assessment are complete, must be part of the client's ISP, must benefit each billed client, and may not be delivered by audio-only telemedicine. Providers must document the CPT code, date, time and duration, clinical purpose, interventions, and each client's participation, response and progress.

What it means. Compare your group note template against the guide's required elements and add any missing fields before October group claims go out. Stop scheduling audio-only groups for Apple Health clients.

What changed. Premera is expanding policy 3.01.521 effective October 9, 2026 so that partial hospitalization programs treating mental health conditions, substance use disorders and eating disorders need prior authorization. Criteria may include psychiatric medication evaluations, substance use evaluations, nutritional assessments and InterQual criteria, with ongoing assessments every 7 to 10 days.

What it means. Build a Premera PHP authorization step into admissions for any start on or after October 9. Set reminders for reassessment documentation every 7 to 10 days so continued stay requests are supported.

What changed. DHW's Family First Team announced funding for certified Multisystemic Therapy providers in Idaho to expand community-based services. One organization may receive up to $400,000, and applicants must have provided MST services in Idaho for at least three years. Applications are due Friday, October 2, 2026 by 5 p.m. MT to FamilyFirstInquiry@dhw.idaho.gov, for a program expected to run October 19, 2026 through March 30, 2028.

What it means. Eligible MST providers should submit today or tomorrow. Confirm your three years of Idaho MST service history is documented in the application.

What changed. Beginning October 1, 2026, providers may again deliver and bill State Opioid Response safe and sober housing services, and may provide partial hospitalization to both SOR and SUPTRS members. Services provided before October 1 are not included. All safe and sober housing authorizations must include proof of enrollment in an ASAM level of care.

What it means. Recovery housing operators should confirm each resident's ASAM level of care enrollment is documented before requesting authorization. Do not bill SOR housing for dates before October 1.

What changed. IDHW and Magellan are implementing the updated Child and Adolescent Needs and Strengths Decision Support Application and a revised Levels of Care framework. The notice states implementation moves to October 1, 2026. Questions go to bhtcom@dhw.idaho.gov.

What it means. Youth programs should confirm assessors are trained on the updated CANS tool and that level of care recommendations follow the revised framework. Watch authorizations in early October for changes in approved levels.

What changed. 2026 UnitedHealthcare National Gold Card waivers begin October 1, 2026. Qualifying practices (single TIN with at least 10 eligible prior authorizations a year and an approval rate of 92% or more after appeals, for two consecutive 12 month periods) submit advance notification instead of prior authorization for listed codes. Codes include IOP H0015 and S9480, PHP H0035 and S0201, and psychological testing 96130 through 96139 and 96146.

What it means. Check whether your TIN received Gold Card status and, if so, switch those services to advance notification. If you did not qualify, track your UnitedHealthcare authorization volume and approval rate toward the next cycle.

What changed. OHA adopted permanent rules, effective September 4, 2026, replacing temporary rules for Crisis Stabilization Centers that serve people for less than 24 consecutive hours. Services must be available 24 hours a day, every day of the year, with at least two program staff on site for up to five individuals plus one more for each additional five, and a QMHP on call at all times. Certification lasts two years.

What it means. Operators planning a crisis stabilization center should build staffing models and budgets to the permanent ratios. Existing temporary certificate holders should compare current policies to the final rule text.

What changed. OHA proposed amendments to residential treatment facility and home licensing rules to align with HB 4016, HB 4068, HB 4069 and HB 4115. The proposal adds weapons policies and reasonable cause searches, individualized safety planning, capacity reporting and owner tax compliance, and extends background checks from two to three years. Comments are due October 19, 2026 at 5:00 p.m.

What it means. Residential operators should draft a weapons and search policy and check how capacity reporting would work with current census tools. Submit comments by October 19.

What changed. OHA proposed adopting an OHA Prioritized List because its waiver authority to use the Prioritized List in its current funding line form expires January 1, 2027. CCO rules would replace funded and unfunded references with covered and noncovered services and replace comorbidity guidance with an individual medical necessity review. The behavioral health telemedicine and ABA rules are updated to match. A hearing is October 20 and comments are due October 21, 2026.

What it means. Billing and utilization staff should read how the individual medical necessity review will be documented, since it replaces funding line logic. Submit comments by October 21.

What changed. Effective November 1, 2026, OHA will process only standard prior authorization requests for Behavior Rehabilitation Services and will end preliminary, retroactive and reauthorization processes. OHA has moved to a 7 calendar day review timeline and can pend a request 14 more calendar days for additional information. Providers should submit only standard requests after October 31, 2026.

What it means. BRS providers should retrain intake staff to submit complete standard requests before services start. Retire any workflow that relies on retroactive authorization by October 31.

What changed. OHA proposed a renewal process for the Culturally and Linguistically Specific Services behavioral health enhanced payment. Approval would be valid for three years, renewal applications would be due at least 90 calendar days before expiration, and providers could be removed from the registry if a complete renewal is not filed. A hearing is October 19 and comments are due November 16, 2026.

What it means. Providers on the CLSS registry should find their eligibility date and calculate when a renewal would be due. Submit comments by November 16.

What changed. For Trillium Medicaid, H2032 (activity therapy, per 15 minutes) requires conditional prior authorization after the first 104 units per member per calendar year, effective November 1, 2026. The 104 unit count starts November 1, and earlier units do not count. Trillium will also apply six billing and coding edits to behavioral health claims on or after November 1.

What it means. Identify members likely to exceed 104 H2032 units and prepare authorization requests. Review the six new claim edits with your billing team before November claims.

What changed. The Board proposed rules to implement SB 1547 (2026), which creates a licensed behavioral health and wellness practitioner credential operative January 1, 2027. Proposed fees are $325 to apply, $200 to renew and $100 delinquent. A hearing and the comment deadline are both October 22, 2026.

What it means. Programs that may hire this new credential should read the scope and supervision provisions before planning roles. Submit comments by October 22.

What changed. DOH filed a preproposal statement of inquiry on chapter 246-811 WAC for substance use disorder professionals and trainees. Topics include adding trauma informed care to continuing education and competency requirements, updating education standards in WAC 246-811-030(3), documentation requirements, and certification for applicants with foreign education or experience. DOH will announce workshops through its SUDP email list.

What it means. Agencies that employ SUDPs and trainees should join the DOH SUDP email list to follow workshops. Expect a trauma informed care continuing education requirement in future renewals.

What changed. An updated Medicaid Provider Agreement takes effect November 1, 2026 and adds requirements for artificial intelligence. Documentation, assessments, treatment plans, progress notes or claims generated in whole or in part with AI must be individualized to the participant and reviewed, validated and approved by the provider before claims are submitted. Providers are deemed to accept the agreement after the notice period.

What it means. If clinicians use AI scribes or note tools, document a review and sign off step before claims go out. Update your AI and documentation policies to cite the new agreement section.

What changed. Effective November 1, 2026, providers must submit encounter claims for every individual service delivered within the Assertive Community Treatment bundle, with the Q2 modifier in the first position and billed at $0.01 for reporting only. The ACT per diem, H0040 with Q2, remains the only reimbursable part of the bundle. Magellan states the ACT daily rate may not be billed while a member is incarcerated.

What it means. ACT teams should set up encounter claim lines in their billing system and test them before November. Add an incarceration check before billing the per diem.

What changed. DHCS released the Scaling Dyadic Care Grant Program RFA on September 15, 2026, committing approximately $17 million to Medi-Cal provider organizations. Tier 1 awards up to $700,000 go to locations serving at least 1,000 Medi-Cal children ages 0 to 5, and Tier 2 awards up to $500,000 to locations serving at least 500. FQHCs, RHCs, Indian Health Care Providers, hospital affiliated systems and community organizations operating Medi-Cal enrolled primary care clinics may apply by October 26, 2026 at 11:59 p.m. PT.

What it means. Organizations with integrated pediatric primary care should check their Medi-Cal 0 to 5 counts against the tier thresholds. Start the application now to meet the October 26 deadline.

What changed. SB 329 was approved by the Governor on September 27, 2026 and chaptered as Chapter 646. DHCS must assign a complaint about a licensed or certified alcohol or other drug program to an analyst within 10 days and complete the investigation within 120 days of assignment. Beginning July 1, 2027, DHCS must post an annual report of its investigations, and the bill authorizes a single licensure and certification fee increase to fund it.

What it means. California SUD programs should expect faster complaint investigations and keep grievance logs and incident files ready for review. Budget for a possible licensing and certification fee increase.

What changed. AB 2011 was approved on September 30, 2026 and chaptered as Chapter 915. It requires individual, small group and large group health plans and insurance policies to cover mental health and substance use disorder benefits in compliance with federal parity rules, regulations and guidance as they existed on January 1, 2025. DMHC and CDI must review conflicting provisions and issue joint compliance guidance.

What it means. Programs contracting with California commercial plans can cite these sections when challenging prior authorization, step therapy or other treatment limits on behavioral health care. Watch for the DMHC and CDI joint guidance.

What changed. The fourth temporary extension of COVID-19 telemedicine flexibilities for prescribing controlled medications is effective January 1, 2026 through December 31, 2026. No later DEA telemedicine special registration final rule appeared in the Federal Register through September 30, 2026.

What it means. Programs prescribing buprenorphine or other controlled medications by telehealth without a prior in-person exam should plan for January 2027 now. Identify affected patients and schedule in-person visits or alternatives in case no further extension is issued.