FAQ

What is an associate provider? 

An associate is a mental health provider who has graduated from a master’s level program and is currently working on achieving the direct-client hours required for full licensure. For example, to become a Licensed Professional Counselor (LPC) in the state of Oregon, a registered associate needs to have a minimum of 36 months of supervised clinical experience, including at least 1,900 hours of supervised direct client hours. There are slightly different requirements for those who are working to become a Licensed Marriage and Family Therapist (LMFT) and a clinical social worker (CSW), but all associates—no matter which license they are working towards—are required to have a minimum number of supervised direct client hours. It takes 3-5 years to become licensed. 

Why is the CareOregon decision a big deal? 

CareOregon is a Coordinated Care Organization, which is a network of all types of healthcare providers (physical health care, addictions and mental health care) who have agreed to work together in their local communities to serve people who receive health care coverage under the Oregon Health Plan (Medicaid). Though they receive public funding, they are a private organization, and can—in some circumstances—make decisions independent of other CCOs and the Oregon Health Authority. In December, CareOregon announced that their CCO will no longer reimburse associates providing mental health services to their members after July 31st, 2025 unless they work at a contracted group or a Certificate of Approval Site. You can view more information here. This means that any associate working in a private practice, a non-contracted group, or a group practice with a COA will no longer be able to bill CareOregon for mental health care services. 

CareOregon allowed associates to bill their CCO in all provider settings beginning in 2020, when they did not have network adequacy to serve the mental health needs of their members. According to a survey we completed in early 2025, we believe that at least 5,000 CareOregon members will lose access to care as a result of this decision. However, this will have much broader implications. Those 5,000 members will have to seek care elsewhere, putting an even greater strain on our already burdened mental health care system. CareOregon has advised associates who want to continue seeing their CareOregon clients to get a job at a COA site or a contracted group. However, limited job openings and lack of accessibility make it difficult for associates to transition to other employment settings. Some associates may forfeit their path to licensure or leave the field altogether as a result.

What does the Oregon Health Authority’s proposed rulemaking mean? 

The Oregon Health Authority’s proposed rulemaking suggests that associate- and intern-level mental health providers must work at Certificate of Approval sites in order to bill Medicaid for any mental health services that they provide. Certificates of Approval are difficult to obtain, and often take months to receive. This further restricts the settings in which an associate provider can provide services to Medicaid members. OHA has stated that the rulemaking process will begin in Spring 2025, and will be finalized by December 31st, 2025. This means that we have the ability to impact the rulemaking process. The Oregon Therapists for Equity are working to have our voices heard regarding this rule by providing public comment at various OHA meetings, contacting our legislators, and working with COPACT, the legislative arm of the Oregon Counseling Association. 

How will this impact my ability to receive care as an Oregon Health Plan member? 

If you have CareOregon/Health Share as your CCO: 

If your therapist is an associate clinician (professional counselor associate, marriage and family associate, clinical social work associate) and works in private practice or a group practice that does not have a contract with CareOregon or a COA, you will not be able to continue seeing them after July 31st, 2025. Clients may find it helpful to connect with their therapist and verify how their licensure status and place of employment may impact their care.

That being said, there are a few exceptions to this: 

● Your therapist may become licensed by July 31st, 2025, and in that case, will likely be able to continue billing CareOregon. You can ask them if they anticipate becoming licensed by that date.

● Your therapist may be able to transition their employment to a contracted group practice or a practice with a COA before July 31st in order to continue billing CareOregon.

If you have another CCO (PacificSource, Trillium, Columbia Pacific, etc.): 

Your access to your therapist is currently not affected. However, if the Oregon Health Authority moves forward in limiting the settings in which associates can bill Medicaid, your care may be impacted. OHA states that this rulemaking will be finalized by December 21st, 2025.