Fjord Informed – Issue #1:Providing Behavioral Health Providers with Timely and Accurate Information on Behavioral Health, Equity, Policy, and Public Health in Oregon

Welcome to the first issue of Fjord Informed! This newsletter is designed to keep behavioral health providers in Eugene updated on key policy changes, legislative developments, and systemic issues impacting health equity, social determinants of health (SDOH), and the behavioral health system. Our goal is to offer our fellow provider and provider groups clear, concise, and actionable information to support informed advocacy and service delivery.

Federal Policy Changes and Impacts on Medicaid & Marginalized Communities

Recent federal policy shifts have created significant concerns regarding Medicaid funding, coverage, and access to care for marginalized populations. To address the growing community anxiety, Fjord Counseling has created an FAQ document outlining key impacts on mental health care, Medicaid eligibility, gender-affirming care, immigration-related barriers, and data privacy. You can access the full FAQ document at fjordcounseling.com/news. We encourage other providers and provider groups to consider sharing this FAQ document with their communities or developing their own FAQ to help ensure accurate information is widely available. Some key takeaways include:

• Medicaid funding uncertainties may lead to coverage disruptions, but Oregon is working to maintain stability.

• Gender-affirming care restrictions have been proposed, but Oregon providers, including Fjord PRIDE, remain committed to affirming care.

• Immigration policy shifts have heightened fear within communities; however, Oregon maintains strong Sanctuary Promise protections.

• Privacy concerns due to federal policy changes require heightened awareness of HIPAA and Oregon-specific data protections.

*The Oregon Health Authority (OHA) also has a dedicated website providing information related to the agencies responses to these issues: https://www.oregon.gov/oha/Pages/Federal-Changes.aspx

2025 Behavioral Health Directed Payment Increases

The Oregon Health Authority (OHA) has announced changes to the 2025 Behavioral Health Directed Payment (DP) Increases aimed at enhancing provider reimbursement for those primarily serving Medicaid members. These payments are governed by Medicaid managed care regulations and apply to Coordinated Care Organization (CCO) contracts.

Key Changes for 2025

• Minimum Reimbursement Requirement: Contracted Primarily Medicaid Behavioral Health (BH) Providers must receive at least 110% of the Oregon Health Plan (OHP) fee-for-service (FFS) schedule rate or the CCO’s 2024 contracted rate plus an inflation factor.

• No Increases for Non-Medicaid BH Providers: Unlike previous years, only Primarily Medicaid BH Providers qualify for this rate increase.

Process for Applying

For Contracted Providers:

1. Assess Qualification: Providers must verify if at least 50% of their total revenue in the previous contract year came from serving OHP members.

2. Complete Attestation: Providers must submit a BH Provider attestation form with financial documentation to each CCO they contract with.

3. Submit Documentation: The attestation form and supporting financial information must be submitted to the CCO(s) you are contracted with before payment increases take effect.

New OHA Requirement for Organizations Hiring Associate Clinicians

The Oregon Health Authority (OHA) issued a Memorandum signaling intent to implement new regulations that require organizations employing associate clinicians (such as Board Registered Associates and Mental Health Interns) to obtain a Certificate of Approval (COA). Key proposals of the memorandum include:

• No longer allowing associate clinicians to bill Medicaid directly after June 2026 unless working for an OHA-certified or licensed organization.

• Allowing existing associate clinicians, under the supervision of a board approved licensed supervisor, to continue to bill Medicaid until June 2026.

• Requiring organizations that wish to continue employing associate clinicians after the new rules are in place to apply for a COA to continue billing Medicaid for services rendered by the associate clinicians.

For more details, please see this from the OHA Behavioral Health and Medicaid Divisions

*Fjord Counseling offers specialized assistance to behavioral health organizations in preparing for and obtaining the Oregon Health Authority (OHA) Certificate of Approval (COA). Learn more at https://www.fjordcounseling.com/consulting.

Health-Related Social Needs (HRSN)

Access to basic needs such as food, housing, and climate resilience is an essential component of health equity. Health-Related Social Needs (HRSN) initiatives help address social determinants of health by integrating services such as housing support, food security, and transportation into healthcare delivery. These are new benefits for eligible members covered under the Oregon Health Plan and members can apply NOW. These efforts are critical to reducing health disparities and ensuring every individual has access to the fundamental resources required for well-being.

Available HRSN Benefits

• Nutrition Support: Assistance with food security, including meal delivery, grocery vouchers, and access to community food programs.

• Housing Stability: Rental assistance, emergency housing support, and long-term solutions for individuals at risk of homelessness.

• Climate Resilience: Programs that provide air conditioning, heating support, and resources for individuals impacted by extreme weather conditions.

HRSN Resources

• PacificSource Community Solutions HRSN Program: PacificSource HRSN

• Trillium Community Services HRSN Program: Trillium HRSN

• Oregon Health Authority (OHA) HRSN Information: OHA HRSN

A Call to Action for Providers

Health equity is a social justice issue, and providers play a critical role in helping clients access these life-saving benefits. We urge behavioral health professionals to:

• Inform clients about available HRSN services. Many individuals are unaware of their eligibility for these programs.

• Assist clients with the application process. Navigating bureaucratic systems can be overwhelming, and providers can help simplify access.

• Advocate for expanded HRSN resources. Supporting policies that enhance funding for these initiatives will improve long-term health outcomes in our communities.

By actively engaging with HRSN resources, behavioral health providers can help break cycles of poverty and health inequity, ensuring that all individuals have the opportunity to thrive.

2025 Oregon Legislative Session Updates

As the Oregon State Legislature moves forward, several behavioral health and equity-related bills are advancing and include initiatives aimed at: reforming the Oregon State Hospital, expanding behavioral health residential capacity, enhancing workforce development, and implementing payment reforms. Below is a summary of these themes, along with specific bills pertinent to each area:

Oregon State Hospital (OSH) and Aid & Assist Reform: Legislators continue to address the increasing use of OSH for competency restoration, which has strained available resources. Policymakers are exploring alternative strategies, including increased funding for community-based restoration programs and expanding residential treatment options to reduce OSH admissions.

• Senate Bill 140 – Hospital Association Bill: This bill focuses on reforms related to the Oregon State Hospital, particularly concerning the 'Aid & Assist' population. It aims to improve the processes and outcomes for individuals requiring competency restoration services.

Behavioral Health Residential Capacity Expansion: Efforts to increase access to behavioral health treatment are underway, including expanding residential treatment beds, detox centers, and inpatient psychiatric services.

• House Bill 3085 – Emergency Behavioral Health Services for Children Program: This legislation proposes the establishment of a program dedicated to providing emergency behavioral health services for children. The goal is to increase the availability of immediate care options and ensure timely interventions for youth in crisis.

• Governor’s Recommended Budget: Governor Tina Kotek has proposed an additional $90 million to build out Oregon’s behavioral health system, with a focus on increasing the number of residential beds and improving care transitions for high-needs individuals.

Workforce Development Initiatives: There is an increased focus on improving provider well-being, addressing burnout, and ensuring sustainable working conditions for behavioral health professionals. Legislative proposals are exploring loan repayment programs, salary enhancements, and clinical supervision support.

• House Bill 2024 – Behavioral Health Workforce Package: This comprehensive package addresses the critical shortage of behavioral health professionals in Oregon. It includes provisions for loan forgiveness, scholarships, and other incentives to attract and retain qualified individuals in the behavioral health field.

• House Bill 3129 – Higher Education Behavioral Health Workforce Expansion Fund:  This bill would require the establishment of a Higher Education Behavioral Health Workforce Expansion Fund and declare a State of Emergency related to the Behavioral Health Workforce.

Behavioral Health Payment Reforms: Proposals are being developed to increase Medicaid reimbursement rates, reduce administrative burdens, and align payment models with patient-centered care.

• House Bill 2056 – Behavioral Health Cost Study: This bill mandates a comprehensive study to analyze the costs associated with providing behavioral health services in Oregon. The findings are intended to inform future payment models and ensure sustainable funding for providers.

• House Bill 2057 – Prohibition on 340B Drug Identification Requirements: This legislation seeks to prohibit certain requirements related to the 340B Drug Pricing Program, aiming to protect covered entities from burdensome administrative processes and ensure continued access to discounted medications for vulnerable populations.

• House Bill 2789 – Registered Nurse Billing Authorization: This bill proposes to authorize registered nurses to bill for specific services, thereby expanding the scope of reimbursable services and addressing gaps in care delivery, especially in underserved areas.

• House Bill 2564 – Insurance Rate Review Process Revision: This legislation aims to revise the insurance rate review process to promote transparency and fairness. It seeks to ensure that insurance rates are equitable and reflect the true cost of providing behavioral health services.

Additional Bills to Watch:

·         HB 2013: Seeks to ensure that outpatient facilities employing Certified Alcohol and Drug Counselors (CADCs) are officially recognized as providers of mental health treatment under insurance regulations. If passed, this would allow these facilities to receive reimbursement for mental health services.

·         HB 2042: Aims to increase consumer participation in decision-making regarding behavioral health services.

·         HB 2998: Would require specific mental health providers to screen for racial trauma as part of the initial assessment process.

State Budget and Behavioral Health Investments

Governor Tina Kotek has proposed a $39.3 billion budget for the 2025-27 biennium, emphasizing significant investments in housing, homelessness, behavioral health, and education. Notably, the budget includes over $330 million dedicated to mental health services, residential treatment, and behavioral health workforce training. This funding aims to add 336 treatment beds and support workforce development initiatives to address the state's behavioral health crisis. thelundreport.org

The exact allocation for behavioral health services is still under discussion, and the total funding requested through all proposed bills is being evaluated as the session progresses.

These legislative efforts reflect a comprehensive approach to enhancing behavioral health services in Oregon, addressing workforce challenges, service delivery, and systemic reforms.

Oregon 2025 Legislative Session Calendar

• January 13, 2025 – Swearing In

• January 21, 2025 - 83rd Legislative Session Convenes

• February 17, 2025 – Deadline for bill introduction

• April 8, 2025 – First chamber deadline (bills must pass out of initial chamber)

• May 23, 2025 – Second chamber deadline (bills must pass out of second chamber)

• June 29, 2025 – Constitutional Sine Die

Conclusion

The landscape of behavioral health policy in Oregon is rapidly evolving, with changes in Medicaid funding, legislative proposals, and regulatory requirements shaping the field. We encourage providers to stay informed, engage in advocacy efforts, and collaborate to ensure equitable access to behavioral health care.

Stay tuned for the next issue of Fjord Informed!

For feedback or topic suggestions, email us at info@fjordcounseling.com.