Medical Billing in Oregon | Oregon Health Plan & Timely Filing

Medical Billing in Oregon: The Short Version

Oregon operates the Oregon Health Plan (OHP) through 16 Coordinated Care Organizations (CCOs) — a nationally recognized alternative to traditional Medicaid managed care. CCOs are regional community organizations that integrate physical, behavioral, and oral health under global budgets with significant flexibility to design their own prior authorization criteria and benefit structures. This means billing rules vary meaningfully CCO to CCO. The OHA fee-for-service timely filing limit is 365 days (OAR 410-120-1300), but CCOs set their own limits — CareOregon, the largest CCO, requires claims within 120 days. Oregon's commercial market features strong regional carriers: Regence BCBS Oregon, Providence Health Plan, and Moda Health alongside national payers. Oregon also has a state balance billing law (ORS 743B.287) that predates and supplements the federal No Surprises Act.

Payer Landscape

Major Payers in Oregon

Payer	Type	What Billing Teams Should Know
Regence BlueCross BlueShield of Oregon	Commercial / Blues Plan / MA	Oregon's primary BCBS licensee. Part of Cambia Health Solutions (also includes Regence BCBS WA, UT, ID). Related but separate networks — verify which Regence entity a patient belongs to. Typically 180 days commercial timely filing
Providence Health Plan	Regional Commercial HMO	Affiliated with Providence Health & Services (CommonSpirit). Significant Oregon market share, particularly in Portland metro. Integrated delivery model — understand referral and authorization workflows
Moda Health	Regional Commercial HMO/PPO	Oregon-founded insurer. Significant individual and small group market. Important for independent practice credentialing in Oregon
PacificSource Health Plans	Regional Commercial PPO/HMO	Mid-sized Oregon-based commercial carrier. Strong in smaller markets and rural Oregon. Also operates as a CCO in some regions. Note: exiting Lane County CCO role in 2026 — members transitioning to Trillium
Kaiser Permanente Northwest	Integrated HMO	Significant Portland metro market share. Integrated delivery — non-Kaiser providers face complex authorization requirements for Kaiser-insured patients
Oregon Health Plan (OHA)	Medicaid (via CCOs)	OHA FFS: 365 days (OAR 410-120-1300). CCO timely filing varies: CareOregon requires 120 days. Always verify the specific CCO. Over 1.3 million Oregonians enrolled (~30% of population)

Medicaid Structure

Oregon Health Plan: Coordinated Care Organizations (CCOs)

Administered by the Oregon Health Authority (OHA). Oregon has 16 CCOs operating across the state. CCOs integrate physical, behavioral, and oral health with significant regional variation in PA requirements and benefit design. PacificSource is exiting Lane County in 2026 — members transferring to Trillium. For the full CCO list, see oregon.gov/oha.

CCO	Region / Notes
CareOregon	Largest CCO by membership. Portland metro (Multnomah, Clackamas, Washington counties). Timely filing: 120 days — significantly shorter than OHA FFS. Nonprofit model
Health Share of Oregon	Largest CCO by geographic scope. Tri-County area (Multnomah, Clackamas, Washington). Verify timely filing with CCO provider manual
Trillium Community Health Plan	Lane County (Eugene/Springfield). Absorbing PacificSource Lane County members in 2026 — re-verify patient CCO assignment and Trillium credentialing status
AllCare Health	Jackson and Josephine Counties (Rogue Valley / Southern Oregon). Integrated physical, behavioral, and oral health
Eastern Oregon CCO (EOCCO)	Rural Eastern Oregon — one of the largest CCOs by geographic area. Coordinated by PacificSource in most counties
Columbia Pacific CCO	Northwest Oregon (Clatsop, Columbia, Tillamook counties)
Umpqua Health Alliance	Douglas County (Roseburg area)
Additional CCOs (9 others)	Cascade Health Alliance (Klamath Falls), FamilyCare Health (Portland metro), and others. Full list at oregon.gov/oha/HSD/OHP/Pages/CCO-Plans.aspx

Filing Deadlines

Timely Filing Limits for Oregon Claims

OHA FFS allows 365 days, but individual CCOs set their own limits — CareOregon requires only 120 days. Always verify with the patient's specific CCO before relying on the OHA state limit.

Payer	Timely Filing Limit	Notes
Oregon Health Plan (OHA FFS)	365 days from date of service	OAR 410-120-1300. Applies only to FFS OHP — most members are in a CCO
OHP CCOs (varies)	120–365 days (CCO-specific)	CareOregon: 120 days. Medicare primary/Medicaid secondary: 120 days from Medicare EOB. All other CCOs: verify individual provider manual
Medicare (Original)	12 months from date of service	Federal standard (42 CFR §424.44); no contract variation
UnitedHealthcare (Commercial)	90 days from date of service	Standard commercial; some contracts allow 180 days. Verify provider agreement
Aetna (Commercial)	90 days in-network; 12 months out-of-network	Verify current contract terms
Cigna (Commercial)	90 days in-network; 180 days out-of-network	Standard commercial Cigna policy
Regence BCBS Oregon (Commercial)	180 days (commercial, typical)	Verify specific contract and plan. Regence standard is commonly 180 days in-network

Verified against payer publications (July 2026). Filing limits change by contract and plan year — treat this table as a starting point, not a substitute for the payer manual.

OR-Specific Rules

Oregon Billing Realities to Know

CCO Timely Filing Varies — Never Assume OHA Limit

Oregon's OHA FFS limit is 365 days, but the 16 CCOs are independent organizations that set their own timely filing requirements. CareOregon — the largest CCO — requires claims within 120 days from the date of service. Other CCOs range from 120 to 365 days. Billing teams must maintain a CCO-specific timely filing calendar rather than relying on the OHA state FFS limit.

CCO Global Budget Model — PA Varies by CCO

Oregon's CCO model operates on global budgets with each CCO designing its own prior authorization criteria within OHA guidelines. A service requiring PA at CareOregon may not require PA at AllCare. Providers operating across multiple CCO regions must maintain CCO-specific knowledge of authorization requirements — you cannot rely on uniform rules across all CCOs the way you might across branches of a national MCO.

Oregon Balance Billing Law — ORS 743B.287

Oregon's state balance billing prohibition predates and supplements the federal No Surprises Act. ORS 743B.287 prohibits providers in emergency medicine, anesthesia, pathology, radiology, lab, neonatology, assistant surgery, hospitalist, and intensivist roles at in-network facilities from balance billing patients. For self-funded ERISA plans, only the federal NSA applies — state law does not govern. Both laws may apply simultaneously for fully-insured commercial plans.

PacificSource Lane County Exit (2026)

PacificSource Community Solutions is exiting its CCO role in Lane County (Eugene/Springfield) in 2026, with Trillium Community Health Plan absorbing those members. Providers in Lane County must re-verify patient CCO assignments and ensure Trillium credentialing is active. Outstanding PacificSource OHP claims must be submitted to PacificSource before their runout deadline. New services for transitioned members bill to Trillium.

Frequently Asked Questions

The Oregon Health Authority fee-for-service OHP timely filing limit is 365 days from the date of service under OAR 410-120-1300. However, the patient's CCO sets its own timely filing requirements: CareOregon (largest CCO) requires claims within 120 days. Other CCOs may have different windows ranging from 120 to 365 days. Billing teams must verify the specific CCO's timely filing requirement — never assume the state FFS limit applies to CCO claims.

A Coordinated Care Organization (CCO) is Oregon's alternative to a traditional Medicaid MCO. CCOs are regional nonprofit or community-based organizations that coordinate physical, behavioral, and oral health services under a global budget. Unlike MCOs, each CCO designs its own prior authorization criteria, care management protocols, and benefit designs within OHA guidelines. This means billing teams must learn each CCO's unique requirements — you cannot rely on uniform rules across all CCOs the way you might across branches of a national MCO.

Oregon's commercial market is distinctive for its strong regional carriers. Regence BlueCross BlueShield of Oregon (part of Cambia Health Solutions) is the BCBS licensee and a major commercial and MA carrier. Providence Health Plan (CommonSpirit) and Moda Health are Oregon-grown regional carriers with significant market share. PacificSource and Kaiser Permanente Northwest are also significant. National carriers (UHC, Aetna, Cigna) have presence primarily in employer-sponsored markets. For most providers, Regence, Providence, and Moda are essential credentialing priorities alongside the national carriers.

Oregon's ORS 743B.287 predates the federal No Surprises Act and prohibits balance billing at health care facilities for specific provider types (EM, anesthesia, radiology, pathology, lab, neonatology, assistant surgeons, hospitalists, intensivists). The federal NSA extends protections to more service types and plan categories. For Oregon providers, both state law and federal NSA rules may apply simultaneously — the more protective rule governs. For self-funded ERISA plans, only the federal NSA applies, not Oregon state law. Consult legal counsel when navigating specific balance billing situations.

Medical Billing in Oregon: Oregon Health Plan CCOs, Payer Landscape & Timely Filing