MedicaidAdministrativeLow impact
Update on enforcement of Payer-to-Payer Data Exchange
Oregon Health Plan·OR·Plan contract
Effective date
Mar 7, 2022
We identified it
Jun 20, 2026
Summary
Oregon Health Authority is deferring enforcement of payer-to-payer data exchange requirements for Coordinated Care Organizations and Dental Care Organizations, following CMS's decision to exercise enforcement discretion due to implementation challenges. While enforcement is deferred, the expectation for compliance remains unchanged.
Action Required
No immediate action required for billing teams. Continue current billing practices as payer-to-payer data exchange enforcement is deferred. If your organization has already developed FHIR-based API solutions, you may continue implementation. Organizations without FHIR capability should await further CMS guidance expected in 2022.