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Returned draft and proposed policy choices
What would the designation actually change?
What the record supports
LC 1969 is a returned study draft. A designation could define a class; needed financing, spending and payment authority would have to be supplied separately.
What still needs to be established
The working alternatives offer five levels: designation; designation and study; a public-financing pilot; targeted access protection; and an allowable-cost payment target. Each has two eligibility approaches. The member’s selection and hospital consent are not established, and no returned draft is treated as a filed bill.
Sources behind this distinction
Existing payment and financing structure
Where does hospital money move today?
What the record supports
CCO capitation, payments to hospitals, direct OHA fee-for-service payments and the hospital assessment are different flows. Federal matching percentages describe the government share, not a hospital reimbursement rate.
What still needs to be established
The current hospital-specific contracts, claims, supplements and assessment effects still need reconciliation before an increment can be estimated.
Sources behind this distinction
Existing local powers; specific transaction untested
What could a county or district lawfully contribute?
What the record supports
Public transfers can supply an eligible financing source. County or city authority, Article XI, section 9, district powers, geography, restrictions and any election are separate questions; an intergovernmental agreement does not create new taxing power.
What still needs to be established
No available balance, local commitment, new district or constitutional conclusion about a particular transaction is established.
Sources behind this distinction
Existing financing mechanism; remittance unverified
What is different for a public hospital?
What the record supports
A governmental provider may certify its own eligible expenditure instead of making a second cash transfer. Federal money is paid to OHA; any remittance to the same certifying provider follows the applicable method and terms.
What still needs to be established
Eligible costs, existing claims, payment-limit capacity and actual remittance terms must be established. CPE is not a pool for private hospitals.
Sources behind this distinction
Current distinctions; separate proposed federal changes
Do all CCO payment routes face the same approval and rate rules?
What the record supports
They do not. The two specified minimum fee schedules, custom directed arrangements, genuine voluntary CCO contracts and Oregon’s noncontracting backstop have different requirements. Current rules do not impose the covered-SDP ceiling on every CCO payment.
What still needs to be established
The exact rate, services, rating period, financing, contractual obligation and net increment need to be identified. Proposed 2028 and 2029 changes are not a protected window.
Sources behind this distinction
- 42 C.F.R. § 438.6(a), (c)(1)–(2), Directed-payment forms and approval
- Public Law 119-21, § 71116 (July 4, 2025)
- CMS-2449-P, 91 Fed. Reg. 30,400, 30,411, 30,415–16, 30,425 (May 22, 2026; proposed)
- Oregon Revised Statutes §§ 414.598, 414.728, 414.743 and 414.853–414.855
Existing direct-payment routes; capacity unestablished
Can fee-for-service or DSH provide a separate route?
What the record supports
OHA can pay eligible hospitals directly under approved fee-for-service and DSH methods. FFS ownership-group limits and DSH eligibility, allotment, hospital limits and audit requirements remain distinct.
What still needs to be established
No unused Oregon capacity or hospital-specific amount is established. Other Medicaid payments can reduce DSH capacity, so gross increases cannot simply be added.
Sources behind this distinction
Existing education methods; new rural design unapproved
Could a rural GME method be worth developing?
What the record supports
Oregon has existing Medicaid education-payment methods, and federal rules permit direct state-plan GME payments outside CCO capitation. Medicare GME, Oregon’s base methods, its additional public-teaching program and a proposed rural method are separate questions.
What still needs to be established
The claimant, resident-time and cost allocation, current receipts, lawful financing and approval of a new rural method remain to be established. An affiliation alone does not establish eligibility.
Sources behind this distinction
Three distinct established mechanisms; no commitment
What can Tribal partnership change—and who receives the money?
What the record supports
Tribal public transfers, qualifying care-coordination enhanced match and philanthropy are separate routes. Enhanced federal match goes to OHA; ordinary service payment and Oregon’s required Indian-provider return are distinct receipts.
What still needs to be established
The qualifying services, records, agreements, billing, return formula and actual payments need verification. No automatic hospital supplement or entitlement to residual state funds is established.
Sources behind this distinction
Existing service tools; specific benefit unmeasured
Could a service partnership help without a new hospital rate?
What the record supports
A lawful service contract or project can pay its actual recipient and may reduce a measured hospital expense. Cash support and cost avoidance are different results; a private CMHP does not become a public matching source through its public contract.
What still needs to be established
The operative agreement, payee, deliverables, existing Medicaid or CCBHC reimbursement and avoided-cost baseline are not established here.
Sources behind this distinction
Existing restricted tools; eligibility is project-specific
Could restricted local money or project grants support a defined need?
What the record supports
Lodging revenue, covered opioid-settlement funds, CDBG, philanthropy and federal project support keep their own use restrictions. The lodging changes become operative January 1, 2027. RHT funds cannot supply Medicaid’s nonfederal share.
What still needs to be established
No general hospital fund, available award or automatic matching eligibility is established. Identify the actual account, permitted project, eligible payee, commitments and timing.
Sources behind this distinction
Existing programs; a qualifying role is required
Are ambulance or administrative programs another useful branch?
What the record supports
Oregon has separate public and private ground-ambulance supplemental programs. Medicaid administrative claiming supports eligible administrative activities under approved cost allocation. These are role-specific mechanisms, not general designation payments.
What still needs to be established
No eligible hospital-owned transport operation or reimbursable administrative function has been established. Education-service, port and public-asset options also need their own powers and eligible purpose.
Sources behind this distinction
Verified components, not an identical ready-made solution
What do other states—and Oregon’s own tools—actually prove?
What the record supports
Oregon’s SB 1214 proposed a closely related class and rate floor but did not pass. Washington’s longstanding public-hospital class and new reservation class use Medicaid FFS benchmarks. Illinois supplies another statutory class-plus-payment example. Texas CHIRP illustrates managed-care payment and local public financing; its separate approved OB-GYN amendment is a different tool. Pennsylvania’s global-budget performance period was 2019–2024.
What still needs to be established
These examples do not prove Oregon approval, available funding, eligibility or equal results. A statute, a funded program and an actual hospital receipt are different evidence.
Sources behind this distinction
Established accounting test; outcome not yet calculated
How would we know a proposal actually helps?
What the record supports
Compare additional hospital receipts and substantiated savings with the same-period baseline. Deduct new costs, contributions, replaced payments and repayment; keep cash, accrual, awards and actual disbursement distinct.
What still needs to be established
The record does not yet establish a hospital-specific net amount or first feasible cash date. Public financial data are context, not a substitute for claims, contracts and reconciled finance records.
Sources behind this distinction
Adopted deadlines; implementation timing remains conditional
What can happen next—and when could cash actually arrive?
What the record supports
Ordinary presession draft delivery is December 1, 2026, and desk filing is December 11, subject to specified exceptions. Legislative action, effective authority, budget, required federal action and payment operations are distinct milestones.
What still needs to be established
No office turnaround, agency approval or payment date is promised. The current project target is the 2029–31 budget. Calendar 2028 is an earlier, route-specific planning scenario for a funded method enacted in 2027; neither is a payment commitment.
Sources behind this distinction
Defined office roles; requests remain drafts
Which office can answer which question?
What the record supports
LFO addresses government spending and administration; LRO addresses revenue and financing; Legislative Counsel addresses legal design and bill text. The draft requests start with existing information and then support selection of a small set of designs to test.
What still needs to be established
The member directs any submission; this site establishes no approval, submission, office response or delivery date. Their work does not replace OHA, hospital finance, local counsel or participant decisions.
Sources behind this distinction
