Seven packages · one consistent test

Seven ways to build a workable funding package.

Compare possible sources, payment routes and service partnerships on the same terms. No amount or participant is assumed.

Walk through the plan together.

Follow the choices, trace a payment, and explore the supporting research when a question comes up.

Start the walkthrough

These are seven packages, not seven independent pools of Medicaid match. County, district and certain Tribal or public-hospital resources may supply a non-federal share. GME is a payment route. Service partnerships and project support may add value outside Medicaid.

A common accounting test—not a shared legal pathway

Measure the result after the route is chosen.

Each package must show who contributes, what the approved route pays, what is offset and what reaches the hospital.

  1. 1

    Real source

    Available money, lawful owner and a decision to commit it.

  2. 2

    Allowed payment

    The right federal or state route, with its limits and approvals.

  3. 3

    All offsets

    Required contributions, displaced payments, administration and delivery costs.

  4. 4

    Net hospital cash

    What the hospital retains, when it arrives and which services it sustains.

Net gain=new receipts−new costs and contributions−payments lost or replaced

A reimbursed expense, a public contribution and a state saving can describe different parts of the same dollar. They must not be counted as separate gains.

Read the source rules and payment limits

Two separate legal questions. Every package needs a lawful source and a lawful use. For a matched Medicaid payment, test both:

  • A lawful source for the non-federal share. Medicaid is paid partly by the federal government and partly by the state. The non-federal part can sometimes come from local public money, such as a county transfer, a special district's revenue, a Tribe's funds, or a public hospital's certified spending.
  • An approvable payment route to the hospital. Examples are a fee-for-service supplemental payment, a managed-care directed payment, a disproportionate share payment, or a graduate medical education payment. Each has its own federal limits.

A source commitment does not establish payment authority. Direct philanthropy or services outside Medicaid do not require CMS approval merely because they are included here; their own authority and conditions still apply.

What counts as eligible public money. The actual government or Tribal contributor, source restrictions and transfer or certified-expenditure requirements must qualify. A governmental hospital’s own lawful public funds may qualify; routing a private provider’s contribution through government does not by itself make it eligible. Provider-related donations and health-care-related taxes have separate federal tests. A nonprofit does not become a public body because it holds a public contract.

Federal limits that matter.

  • For non-grandfathered inpatient and outpatient hospital arrangements covered by section 71116, the expansion-state ceiling applies to the total covered payment, generally using the applicable total published Medicare rate. If no such Medicare rate exists, the state-plan-rate fallback applies. CMS’s February 2, 2026 guidance is preliminary; the May 2026 implementing proposal is not a final rule.
  • Qualifying grandfathered directed payments phase down beginning with applicable rating periods starting on or after January 1, 2028. Age alone does not establish grandfathering.
  • Base and supplemental fee-for-service hospital payments subject to the rule are tested together against the applicable group’s upper payment limit; DSH has separate limits.
  • Graduate medical education payments follow their own state plan rules.
  • Rural Health Transformation grants cannot be used as the non-federal share.

Net, not gross. The question is what a hospital keeps. That means the payment received, minus any contribution or assessment the hospital pays, minus payments the new money displaces, minus new costs. Moving a large amount of money is not the same as adding resources.

01

Potential public source

County public funds

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Source owner / contributor
County treasury with lawfully available public funds
Actual or potential payee
Eligible hospital under the chosen payment method; a CCO may be the immediate payer
Decision owner
Local governing body and counsel; OHA; CMS for required federal action
Different steps, actual recipients
  1. FromCounty
    Conditional cash

    Transfers qualifying public funds after local authority and appropriation review.

    ToOHA
  2. FromOHA or CCO
    Conditional cash

    Pays under the independently selected and authorized method.

    ToEligible hospital
What can stop this package

An ineligible source or unlawful local transaction cannot be cured by routing through OHA. Public purpose alone does not resolve the constitutional inquiry.

What would move it forward

Document the source, authority, public service or property, consideration, remedies, appropriation and tax-revenue or credit exposure for one concrete transaction.

County/city counsel and finance; OHA financing/payment staff.

Read the full package, legal sources and first step
01 What it is

A county uses its own lawfully available public money as the non-federal share of an approved Medicaid payment.

Who makes the decisions

Local governing body and counsel; OHA; CMS for required federal action

03 Federal approval and limits

The county must have lawful authority, available funds and an authorized appropriation. Review the actual source, enforceable public service or property, consideration, remedies and tax-revenue or credit exposure under Article XI, section 9. OHA separately confirms the eligible source and applicable approved payment method, with any required new federal action.

04 Potential scale

Potential recurring support, limited by lawful available county funds. No amount is established.

05 What it adds to the designation

A county may be a local public partner if the member chooses a partnership criterion or option.

06 First step

Document the actual fund and proposed transaction, including tax/non-tax origin, public services or property secured, appropriation, obligations and recourse. Resolve the local legal basis before modeling the selected Medicaid payment.

Current status

Potentially usable. It depends on each county's own facts and choices.

02

Potential recurring public source

Health districts

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Source owner / contributor
Existing district revenue, or lawful new revenue if approved
Actual or potential payee
OHA for a Medicaid transfer; the named provider for a service purchase
Decision owner
District board; voters where required; OHA/CMS for a Medicaid route
Different steps, actual recipients
  1. FromDistrict
    Conditional cash

    Option A: transfers eligible public funds for an approved Medicaid route.

    ToOHA
  2. FromDistrict
    Conditional cash

    Option B: purchases defined services under the district’s own authority.

    ToContracted service provider
What can stop this package

A hospital-purpose district cannot be assumed under ORS 451 outside its specified geography.

What would move it forward

Map existing boundaries and statutory powers; choose transfer versus service contract.

District/local counsel, assessor/finance, governing board and electors where required.

Read the full package, legal sources and first step
01 What it is

Voters form a health district, or an existing district acts. Its revenue then supports health services through a transfer, a service contract or a joint arrangement.

Who makes the decisions

District board; voters where required; OHA/CMS for a Medicaid route

03 Federal approval and limits

As with county funds, or through a direct service contract outside Medicaid. Lawful district powers and available revenue; formation and voter approval where required; property-tax limits and clear governance. ORS 451 hospital authority is geographically limited, so it is not a general countywide substitute for ORS 440.

04 Potential scale

Potential recurring revenue. Timing and scale depend on district powers, boundaries, assessed value, compression and any required election.

05 What it adds to the designation

A district can provide a durable public partnership. The designation alone neither forms a district nor authorizes a levy.

06 First step

Check existing districts, boundaries, tax capacity, formation requirements, governance and the authority for the intended services.

Current status

Potentially usable on a longer timeline.

03

Public transfers and certified expenditure

Public-hospital financing

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Source owner / contributor
Lawfully available public hospital funds, or eligible public costs already incurred
Actual or potential payee
IGT: eligible payee under the chosen method. CPE: only the certifying provider, as the method provides.
Decision owner
Public board and certifier; OHA; CMS as required
Different steps, actual recipients
  1. FromGovernmental hospital
    Conditional cash

    Cash-transfer branch: transfers eligible public funds.

    ToOHA
  2. FromGovernmental hospital
    Certification

    CPE branch: certifies allowable expenditures and supporting records.

    ToOHA
  3. FromFederal Medicaid funds
    Cash

    Provides the federal share associated with eligible expenditure.

    ToOHA
  4. FromOHA
    Conditional cash

    CPE branch: remits only what the applicable method establishes.

    ToSame certifying provider

Cash transfer and CPE are alternatives with different mechanics. CPE begins with eligible expenditure already incurred; the certification is not a second cash contribution. A public hospital’s membership does not merge the separate ownership groups used for FFS upper payment limits.

What can stop this package

CPE is not cash to transfer twice; a public provider’s CPE is not a payment pool for other hospitals.

What would move it forward

Identify exact certifier and eligible expenditures; obtain the approved method and state remittance/reconciliation terms.

Public provider finance/certifier; OHA financial management; CMS as applicable.

Read the full package, legal sources and first step
01 What it is

A hospital owned by a public district can certify its own allowable spending, or transfer its lawfully available funds, as the non-federal share.

Who makes the decisions

Public board and certifier; OHA; CMS as required

03 Federal approval and limits

OHA claims the federal share on eligible certified public expenditures. Any amount remitted to the certifying provider depends on the applicable approved method; certification itself is not cash, and its federal match is not a pool for other hospitals.

04 Potential scale
Unquantified. For a cash transfer, deduct the hospital’s contribution once. For CPE, count only additional cash actually remitted under the applicable method after costs and offsets; certification is not cash.
05 What it adds to the designation

A willing governmental hospital can use an appropriate financing mechanism. Its public status does not transfer to other hospitals or by itself establish an approvable mixed class.

06 First step

Reconcile a participating public hospital’s allowable expenditures, existing claims and payments, available public funds, payment-limit capacity and required board approvals.

Current status

Potentially usable where a public hospital takes part.

04

Three legally distinct mechanisms

Tribal partnerships

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Source owner / contributor
A Tribe’s chosen public funds; qualifying enhanced federal match; or a direct donor gift—three distinct sources
Actual or potential payee
Ordinary service provider; OHA for federal match; Indian health care provider for the statutory return; gift recipient
Decision owner
Sovereign Tribal decision maker; Indian health care provider; OHA and other parties under their own authority
Different steps, actual recipients
  1. FromTribal public agency
    Conditional cash

    Public-transfer branch: voluntarily transfers qualifying funds.

    ToOHA
  2. FromFederal Medicaid funds
    Cash

    Enhanced-match branch: pays 100% only for qualifying expenditure.

    ToOHA
  3. FromOHA
    Cash

    OHA returns the required portion when ORS 413.241 conditions are met.

    ToContracting Indian health care provider
  4. FromTribal donor or foundation
    Conditional cash

    Gift branch: provides direct support on documented terms.

    ToNamed recipient

Ordinary hospital payment stays separate. OHA or the CCO pays the furnishing provider under the applicable service rules. Enhanced match goes to the state and does not automatically increase the hospital rate or redirect the ORS 413.241 return.

What can stop this package

Agreement alone is insufficient. No automatic hospital rate increase; no unsupported savings-to-hospital arrow.

What would move it forward

Map actual service claim, federal claim and ORS 413.241 return before discussing incremental savings.

Tribal/IHS provider and nontribal provider; CCO where relevant; OHA Tribal/claims/finance staff.

Read the full package, legal sources and first step
01 What it is

Three separate possibilities: Tribal public transfers, qualifying care-coordination arrangements and direct philanthropy.

Who makes the decisions

Sovereign Tribal decision maker; Indian health care provider; OHA and other parties under their own authority

03 Federal approval and limits

For eligible American Indian and Alaska Native Medicaid beneficiaries, hospital services furnished through a qualifying IHS/Tribal care-coordination arrangement may receive 100 percent federal match if the conditions in CMS State Health Official Letter 16-002 are met. An agreement alone is insufficient. Oregon already returns a portion of enhanced match to the participating Indian health care provider. The hospital’s ordinary payment does not automatically increase, and this proposal redirects none of those amounts.

04 Potential scale

Unquantified and dependent on Tribal choice. Public transfers, enhanced federal match and philanthropy must be tracked separately.

05 What it adds to the designation

A Tribe may choose to participate as a public partner. The designation neither commits Tribal funds nor redirects amounts governed by ORS 413.241.

06 First step

Identify existing agreements, the actual owner and restrictions of any funds, and the Tribe’s priorities through the appropriate government-to-government process.

These are three separate mechanisms. Each Tribe decides for itself, government to government.

  • Tribal public funds. A Tribe may choose to transfer its own public funds as the non-federal share. Certain federal self-determination funds may also be used as match under a specific federal statute.
  • Care coordination. For eligible American Indian and Alaska Native Medicaid beneficiaries, hospital services furnished through a qualifying IHS/Tribal care-coordination arrangement may receive 100 percent federal match if the conditions in CMS State Health Official Letter 16-002 are met. An agreement alone is insufficient. Oregon already returns a portion of enhanced match to the participating Indian health care provider. The hospital’s ordinary payment does not automatically increase, and this proposal redirects none of those amounts.
  • Tribal philanthropy. Direct support outside Medicaid, on the donor's terms.
  • Where it stands. Potentially usable only if a Tribe chooses.
Current status

Potentially usable only if a Tribe chooses.

05

Service and project value

Behavioral-health partnerships

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Source owner / contributor
Actual county, OHA, CMHP or restricted program purchaser; identify the operative contract
Actual or potential payee
Hospital, CMHP or other provider named in the service agreement
Decision owner
Contract owners, program board and any grant/settlement administrator
Different steps, actual recipients
  1. FromActual purchaser or grant recipient
    Conditional cash

    Pays for defined, eligible services under the agreement.

    ToContracted service provider
  2. FromImproved crisis or transition services
    Measured cost avoidance

    May reduce a measured boarding or delivery expense if realized.

    ToHospital expense ledger
What can stop this package

Public contract does not make a private entity a government; duplicate cost reimbursement is unavailable.

What would move it forward

Choose a measurable service change and reconcile existing payer/contract funding.

County/OHA/program contract owners; hospital and CMHP finance/clinical leaders.

Read the full package, legal sources and first step
01 What it is

A service partnership between a hospital and the community mental health program, aimed at reducing emergency-department boarding and strengthening crisis care.

Who makes the decisions

Contract owners, program board and any grant/settlement administrator

03 Federal approval and limits

Purchased services, shared staffing, grants, and opioid settlement funds used for approved purposes such as emergency-department navigators, warm handoffs and hospital transition programs. A real service agreement, no double payment for the same cost, and compliance with grant and settlement terms. Under the covered Oregon settlement framework, funds generally must be spent or encumbered within five years of receipt, or seven years for designated capital outlay; the actual agreement controls.

04 Potential scale

Unquantified. Measure purchased-service revenue and avoided boarding costs after new costs and existing reimbursement; do not count agency goodwill as money.

05 What it adds to the designation

A real partnership can demonstrate regional essential-service work. It does not itself supply public match or create eligibility for a hospital payment.

06 First step

Review existing crisis-service agreements, boarding data, funding restrictions and eligible projects; choose one or two measurable service improvements.

Current status

Potentially usable as service and project value. A private CMHP partnership does not itself create public Medicaid match. Any separate county contribution must pass the county-source and payment-route tests.

06

A payment route requiring financing

Graduate medical education

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Source owner / contributor
Eligible non-federal share for the selected Medicaid method; Medicare and grants tracked separately
Actual or potential payee
The legally eligible education-payment recipient, which must be established from actual records
Decision owner
Sponsor and hospital record owners; OHA; CMS for a new method
Different steps, actual recipients
  1. FromLawful financing sources
    Conditional cash

    Finance the approved Medicaid education-payment method.

    ToOHA
  2. FromOHA
    Conditional cash

    Pays approved training costs directly; no CCO payment step.

    ToEligible GME recipient
What can stop this package

An unapproved recipient or cost method, duplicate claiming, or assumed eligibility from an affiliation.

What would move it forward

Reconcile costs, claimant, training time, existing Medicare/Medicaid education receipts and grants; then define any new rural method.

Sponsor and hospital finance; OHA; CMS as required.

Read the full package, legal sources and first step
01 What it is

Payments for the documented costs of training resident physicians. Oregon already has an approved Medicaid graduate medical education program with specific eligibility rules and payment limits.

Who makes the decisions

Sponsor and hospital record owners; OHA; CMS for a new method

03 Federal approval and limits

Existing Medicare and Medicaid education payments. A new Medicaid pathway for rural training costs could be added with federal approval. Costs are documented and allocated correctly, the federal government confirms how the payment is treated under the directed-payment limits, and no cost is paid twice.

04 Potential scale

Unquantified. A new Medicaid payment requires an eligible non-federal share and recognized training costs. An existing sponsorship does not establish a new hospital receipt.

05 What it adds to the designation

An optional provision could direct OHA to seek an approved rural-training pathway. No exemption from section 71116 or payment above an applicable limit is assumed.

06 First step

Map approved and filled positions, training-site FTEs, cost-bearing agreements, Medicare and Medicaid claims, payment recipients, grants and existing support before estimating new revenue.

Current status

Potentially usable, pending records and federal confirmation.

07

Separate source and project screens

Other local, restricted and private sources

Back to comparison ↑
Source owner / contributor
The lawful holder of the actual account, award, gift or credit facility
Actual or potential payee
The eligible service/project recipient, contractor or borrower—hospital receipt is not presumed
Decision owner
Source owner, governing body, grantor or lender as the actual terms require
Different steps, actual recipients
  1. FromEligible public source
    Conditional cash

    Requires separate source authority and selected payment or procurement method.

    ToOHA or service purchaser
  2. FromRestricted account or grant
    Conditional cash

    Funds only the authorized purpose under operative restrictions.

    ToEligible project or service payee
  3. FromDonor or lender
    Conditional cash

    Gift terms control; credit creates repayment obligations.

    ToNamed recipient or borrower
What can stop this package

General hospital operations are not presumed eligible; 2027 lodging changes are not operative in November 2026.

What would move it forward

Identify one eligible service/project and actual restricted account before drawing a hospital cash arrow.

Local finance/counsel; program/settlement administrator; project owner.

Read the full package, legal sources and first step
01 What it is

A set of distinct local, restricted and private resources for eligible services, projects or financing.

Who makes the decisions

Source owner, governing body, grantor or lender as the actual terms require

03 Federal approval and limits

Match eligibility is considered only for a qualifying Medicaid route. Service purchases, philanthropy, grants and credit follow their own terms. Federal money requires an express exception before it can serve as Medicaid match.

04 Potential scale

No general pool or amount is established. Some routes fund a project, some reimburse an existing cost, and loans remain repayable.

05 What it adds to the designation

These tools may complement a designation. Each needs its own eligible recipient, lawful purpose, approvals and net-benefit calculation.

06 First step

Inventory existing awards, local restrictions and commitments, actual eligible services, available balances and decision owners before selecting a project.

Each of these is separate and limited. None is a general hospital fund.

  • Cities and joint public bodies. Potentially usable; available capacity is not established.
  • Lodging tax. Operative January 1, 2027, the new law permits no more than half of specified net lodging-tax receipts for city or county services, including services a special district provides in lieu of the city or county. It also addresses unexpended receipts and historic allocations. Current November 2026 limits still apply until then. Local restrictions and commitments must be checked; this is not an automatic hospital grant.
  • Ambulance programs. Oregon has public and private ground-ambulance supplemental programs. Eligibility turns on the ambulance service itself.
  • Ports. A port may run a hospital within its boundaries in limited circumstances. This is screening only.
  • Public colleges and universities. Potential service or workforce partnerships only. Education funds are not diverted.
  • Public service purchases and asset arrangements. For example, a county paying for services it needs, at fair value.
  • Administrative claiming and eligibility workers. These recover or support administrative costs. They are not hospital payments.
  • Independent philanthropy. Direct support outside Medicaid, on the donor’s terms. Donations to government for Medicaid require a separate analysis of donor relationships and federal donation rules; no particular match arrangement is established.
  • Community Development Block Grants. Limited to eligible facilities or services and program requirements; using the statutory federal-match exception needs project-specific review.
  • Federal grants and credit. These support separate projects. RHT’s current Catalyst application period is closed and selections are announced; future funding depends on CMS decisions. Existing awards must be checked. Loans must be repaid.
  • Existing hospital assessment. Part of today's baseline, not a new source.

Boundaries matter

What does not carry the plan.

  • Screened and not proposed. Impermissible private-provider donation recycling or hold-harmless arrangements. Reliance on a new hospital-specific charge. Rural Health Transformation grants used as match. Labeling a managed-care payment “cost-based” to evade applicable federal limits. Lawful governmental-hospital public funds remain subject to the separate Package 3 analysis.

The principal financing, payment and adjacent-support categories have been screened. This is a bounded coverage conclusion, not proof that funds are available or a payment is approvable. Remaining work is contributor-specific authority, records, approval and net-benefit analysis.

Turn the open issues into office requests

Pathway diagram