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MedicaidAdministrativeHigh impact

Provider Announcement

Oregon Health Plan·OR·Plan contract
Effective date
Oct 1, 2019
We identified it
Jun 20, 2026
Days to comply

Summary

The Oregon Health Authority clarified conflicting requirements between CCO contracts and state/federal regulations affecting NEMT attendants, consent forms, member disenrollment, claims payment notices, encounter data submission, and continued benefits during appeals. Billing teams must follow the regulatory hierarchy: CFR takes precedence over OAR, which takes precedence over contract language. Key changes include: encounter data submission within 45 days of adjudication (not monthly), claims payment notices only for denied claims (not approved), and corrected member disenrollment reasons per OAR 410-141-3810.

Action Required

Action needed
REQUIREMENTS: - Immediately: Billing team and claims processing staff must audit current practices against the regulatory hierarchy (CFR > OAR > Contract). Review claims payment notice procedures and discontinue sending notices for approved claims; send notices ONLY for denied claims per OAR 410-141-3565(8)(c). - Immediately: Update encounter data submission workflows to comply with OAR 410-141-3570(4): submit encounter data within 45 days of claim adjudication, not monthly. Update any automated submission systems and calendar reminders. - Immediately: Verify member disenrollment procedures align with OAR 410-141-3810(1)(b)(A) for all valid reasons to disenroll without cause. Update member communication templates and eligibility system rules. - Within 1 week: Providers performing hysterectomy or sterilization procedures must update consent form submission procedures: submit forms to OHA within 30 days from date of service (not prior to procedure) per OAR 410-141-3570(6). Audit pending procedures for compliance. - Within 1 week: Billing team must verify NEMT attendant policies reflect OAR 410-141-3935 requirement: attendants required for members age 12 and under only (not all members under 18). - Within 1 week: Appeals/continued benefits team must ensure duration of continued benefits during appeals/contested case hearings follows 42 CFR 438.420(c) and remove contract language referencing authorization expiration as a stopping condition. - Ongoing: Designate staff member to report any newly discovered discrepancies between contract, OAR, and CFR to Cheryl Henning, CCO Contracts Administrator (Cheryl.L.Henning@dhsoha.state.or.us). Non-compliance may result in claim denials, member service failures, and OHA sanctions.