The COA Requirement and the July 2027 Associate Deadline: What Oregon Group Practices Need to Decide Now
By Emelie Douglas, LPC, MBA · Founder, Sprout Your Practice
Starting July 1, 2027, board-registered associates in Oregon can serve Medicaid (OHP) members only if they are licensed or work for an agency that holds an OHA Certificate of Approval (COA). If your group practice has associates seeing OHP clients and you don't hold a COA, you have about nine months to choose a path. COA applications are backlogged, so this is not a decision to leave for spring.
I touched on the COA in my guide to starting a group practice in Oregon. This post is the decision guide: what changed, who it affects, and the three realistic options. Everything here is drawn from OHA's own FAQ, last updated July 2, 2026.
What actually changed, and when?
Two rules, two dates. Don't mix them up. The first is already in effect. The second is the one most group practices need to plan around.
• July 1, 2026 (in effect): OAR 309-019-0125 and 309-019-0130. Unlicensed behavioral health providers must be physically located in Oregon while working for a COA-holding agency. OHA describes this as a clarification of an existing requirement, not a new one, so there is no grace period.
• July 1, 2027: OAR 410-172-0660. Board-registered associates may serve Medicaid members only if they are licensed or work for a COA-holding agency. OHA says this ends the policy that let associates bill Medicaid from private practice and non-COA settings.
Who does this affect?
Any practice where board-registered associates serve OHP members and the practice does not hold a COA. OHA is focused on three associate types: clinical social work associates, marriage and family therapist associates, and professional counselor associates.
A few boundaries matter:
• It is Medicaid-scoped. An associate at a non-COA practice seeing commercial or private-pay clients isn't governed by these rules. Commercial payers have their own requirements, so check each contract.
• Some settings are exempt from the 2027 change: psychology interns, FQHCs, Rural Health Clinics, Tribal Health Clinics, school-based health centers, and hospital-based primary care homes with integrated behavioral health.
• CCOs can move earlier. OHA's FAQ notes that individual CCOs may implement the change for their own members before July 2027. Ask each CCO you contract with directly.
What is a COA, and what does getting one involve?
A COA is an agency-level certification from OHA that lets an outpatient program employ unlicensed staff. It's separate from individual licensing or credentialing. It is a real operational review, not a form.
According to OHA, the process looks at your program overview, organizational structure and staff qualifications, policies and procedures, personnel records, chart review, facility inspection, building and fire codes, and liability insurance. A COA also lets you employ QMHPs, QMHAs, peer support specialists, and CADCs, which may matter if you're thinking about your workforce beyond associates.
The honest read: if your documentation standards, policies, and personnel files are already in good shape, a COA is a heavy lift but a manageable one. If they're not, the COA becomes a systems project first.
What are your options?
There are three realistic paths: get a COA, move associates' caseloads away from OHP, or bridge associates to licensure before the deadline. Most practices will use some mix.
• Pursue a COA. Best fit if serving OHP members is central to your mission and you expect to keep hiring associates. Tradeoff: time, administrative load, and ongoing compliance. Start now because of the backlog.
• Shift associates' caseloads. Associates stop taking new OHP clients and transition existing ones to licensed clinicians or other providers before July 2027. Tradeoff: it changes your payer mix, and it reduces access for the clients with the fewest options. If you choose this, plan the transitions so no one is dropped.
• Bridge to licensure. Map each associate's projected licensure date. Some will be licensed before July 2027 and the rule won't affect them. This doesn't solve the problem for your next hires.
Also think about hiring. If you stay non-COA, a new associate hired today likely can't build a long-term OHP caseload with you. Say that clearly in interviews.
What should you do this quarter?
Get the facts on your own practice, talk to your CCOs, and make the call by early 2027. That leaves time to transition clients with care rather than in a rush.
• List every associate, their current OHP caseload, and their projected licensure date.
• Calculate what share of your revenue is associate-delivered OHP care.
• Ask each CCO you contract with whether they plan to implement early.
• If a COA is on the table, email OHA at LCApplications@oha.oregon.gov now to start the conversation.
• Set a decision date. My recommendation: no later than the end of Q1 2027.
• Tell your associates what you're weighing and when you'll decide. Uncertainty drives turnover faster than bad news does.
Whatever you think of the policy itself, OHA's stated goal is getting OHP members with complex needs the care and the supervised workforce they deserve. Our job as owners is to make sure clients don't experience this change as a sudden loss.
FAQ
Can associates at my non-COA practice keep seeing private-pay or commercial clients after July 2027?
Based on OHA's FAQ, the 2027 rule covers serving Medicaid members, so by itself it doesn't govern commercial or private-pay work. Commercial payers and your licensing board have their own rules, so check each one.
Can my CCO let our associates keep seeing OHP members after the deadline?
No. OHA's FAQ says that once the rule takes effect statewide on July 1, 2027, only associates at COA-holding agencies can care for OHP members, regardless of CCO. CCOs can, however, apply the change earlier.
About the author
Emelie Douglas is a Licensed Professional Counselor, MBA, and the founder of Sprout Your Practice. She built Sprout Therapy PDX from a solo private practice into a group of 40+ clinicians with ~90% annual retention, and served as president of the Oregon Counseling Association. She helps therapists and group practice owners grow businesses that are profitable, ethical, and sustainable — without burnout. Book a free consultation.