MedicaidAdministrativeHigh impact
Emergency fire response memorandum to CCOs
Oregon Health Plan·OR·Plan
Effective date
Sep 12, 2020
We identified it
Aug 19, 2026
Summary
This is an emergency fire response memorandum from Oregon Health Authority (OHA) dated September 12, 2020, providing guidance to Coordinated Care Organizations (CCOs) on billing, reimbursement, and member services during the September 2020 wildfire emergency. Key guidance includes: (1) tracking all emergency-related expenditures for FEMA reimbursement or Health Related Services (HRS) credit; (2) covering emergency medications, DME replacements, and essential supplies (food, clothing, hygiene items, air filters) through HRS funds when FEMA reimbursement is unavailable; (3) covering temporary housing for evacuated members through the end of the emergency declaration quarter; and (4) coordinating with county emergency management teams for resource allocation and reimbursement authorization.
Action Required
IMMEDIATE (September 12, 2020 forward): Billing and claims teams must implement emergency tracking and documentation procedures: (1) Establish detailed record-keeping system for ALL expenditures related to fire emergency response (staff, supplies, medications, housing, replacement DME/medical equipment, food, clothing, hygiene items, air filters). (2) Create separate cost tracking categories to distinguish expenses potentially eligible for FEMA reimbursement from those payable from capitated HRS rates only. (3) Do NOT deny or reject claims for emergency-related medications, DME replacements, prescription refills (non-controlled substances per pharmacy board guidance), essential supplies, temporary housing, or property restoration services during evacuation period. (4) Flag and route all emergency-related claims to compliance/finance team for FEMA reimbursement tracking rather than standard adjudication. (5) Work with county emergency management teams to verify FEMA eligibility before charging claims to HRS capitated rates. (6) Billing team must document that controlled substance medication refills require prescriber authorization (DEA regulations unchanged—pharmacy cannot dispense without authorization). (7) Coordinate with clinical leadership to identify vulnerable members (mobility issues, transportation gaps, severe respiratory conditions) for proactive outreach and case management to prevent billing denials for emergency services. Duration: Through end of the quarter in which Governor Brown ends emergency declaration. Failure to track and document emergency expenditures will result in loss of FEMA reimbursement opportunity and unexpected HRS fund depletion.