Below are answers to frequently asked questions about CareOregon’s policy change impacting unlicensed behavioral health providers who practice independently of a contracted agency or an agency holding a Certificate of Approval (COA) with the state. Effective July 31, 2025, claims submitted by these providers will no longer be reimbursed. For more information about this policy change, visit: Behavioral health contracting and networking change.
In 2016, the state of Oregon revised its regulations to allow unlicensed clinicians to practice in any setting. In 2020, CareOregon began reimbursing these providers as “non-contracted providers” to ensure continuity of care for members during a change in their behavioral health benefits management. Since then, we have prioritized supporting our behavioral health workforce and ensuring member access to essential behavioral health care services.
Over the past five years, the COVID-19 pandemic and resulting workforce burnout have contributed to a significant exodus of behavioral health providers – particularly from safety net organizations. Many individual providers shifted to private practice, where they served less acute patients. Additionally, state legislation in 2022 introduced rate increases that resulted in an unprecedented influx of unlicensed, uncontracted behavioral health providers billing for services provided to our members.
Through engagement with safety net organizations and feedback from members with high acuity or complex behavioral health care needs, we’ve observed differences between unlicensed providers working independently and those affiliated with either a contracted organization or an organization holding a Certificate of Approval. Data collected since 2020 highlights critical trends in member experiences with behavioral health providers, increasing demand for behavioral health care services, and the evolving work force needs within safety net organizations.
Our duty of care is to ensure that members can access clinically effective services — including crisis care and after-hours services — while ensuring that providers have the safety resources and clinical support needed to uphold key quality assurance and clinical standards. Community mental health programs and other safety net organizations are uniquely equipped to deliver comprehensive services for members with high-acuity or complex needs, such as serious and chronic mental health conditions or substance use disorders.
Addressing this need now has become increasingly urgent as demand for behavioral health care continues to grow, even as the effects of the COVID-19 pandemic wane. Our quality committee, internal network, and Clinical Division leaders have endorsed this policy change to strengthen our safety net. Additionally, the Oregon Health Authority has indicated its intention to reverse the 2016 rule change.
The revised network and contracting policy takes effect on July 31, 2025, allowing an eight-month transition period for both providers and members.
We encourage providers to pursue their license and continue serving these populations. Until licensure is obtained, these providers can either join a contracted provider group or an organization with a Certificate of Approval from the state.
You may continue to provide services to that member until July 31, 2025. If you are not able to complete the treatment plan before July 31, 2025, we recommend working with the member to transition their care to an in-network provider. CareOregon Provider Customer Service is available to assist with this, if needed. Please call 800-224-4840 and press option 3 for “provider.”
You can use the provider search tools linked below to find contracted in-network providers:
- Health Share / CareOregon (Portland Metro): providers.healthshareoregon.org/find-a-provider/behavioral-health
- Columbia Pacific CCO: colpachealth.org/members/find-a-provider
- Jackson Care Connect: jacksoncareconnect.org/members/find-a-provider
We would like to have the opportunity to support you and the member. If you have not been able to complete a transition plan or locate an available in-network provider, please call 800-224-4840 and press option 3 for “provider.”
Yes. Providers who are licensed as of July 31, 2025, will not be impacted by this change. You can continue to take on new clients prior to your licensure.
Providers who are unlicensed can join an organization that has a contract with CareOregon or an organization that has a Certificate of Approval from the state. Providers who are unlicensed and have not joined a contracted organization or an organization with a Certificate of Approval, will not be able to submit claims for services provided to CareOregon members after July 31, 2025.
