The OHA implemented the new policies through legislation, administrative rules, the contractor selection process, and contracts. Together, these documents define the state’s expectations of its CCOs and enable the OHA to assess each CCO’s planned approach to implementing the new policies.
The CCO 2.0 requirements built on several policies that were already in place. In the 1.0 phase, CCOs were required to conduct a community health assessment, develop and implement a community health improvement plan, and establish a community advisory council (CAC). In CCO 2.0, the OHA strengthened these requirements. For example, the new contract specifies that SDOH and equity (SDOH-E) partners and organizations must be included in the development of both the assessment and improvement plan. (An SDOH-E partner is an entity, including a CBO, that, “delivers SDOH-E related services or programs, or supports policy and systems change, or both within a CCO’s service area.”) Also, the contract now indicates that the CAC must play a role in directing the CCO’s investments in SDOH-E and in the CCO’s community benefit initiatives. Compliance with these policies is monitored through two reporting mechanisms which are detailed below — each CCO’s health-related services policy and each CCO’s Supporting Health for All through REinvestment (SHARE) Initiative spending plan.
In CCO 1.0, CCOs were given the flexibility to pay for health-related services. These are services that are not covered by Oregon Medicaid but that would “improve care delivery and overall member and community health and well-being.” CCOs could choose to invest in providing services to individual members or in community benefit initiatives. However, during the policy development process for CCO 2.0, the OHA conducted a review that found that the agency was not collecting the information needed to fully understand and oversee these investments — and, it found that what information it did have indicated that the investments, especially those in community benefit initiatives, were minimal. As a result, the CCO 2.0 contract encourages greater investments in health-related social services and strengthens both reporting and oversight of SDOH-E. For example, all health-related services investments must consider the CCO’s health improvement plan, which must be developed with the input of CBOs and other stakeholders.
During the policy development process for CCO 2.0, the legislature also passed HB 4018, which, starting this year, will require the CCOs to spend a portion of their previous year’s net income or reserves on services to address health disparities and the social determinants of health in line with the CCO’s community health improvement plan. The OHPB recommended specific policies to guide the implementation of HB 4018, including requiring the CAC to have a role in spending, as described above, requiring alignment with a statewide housing priority, and requiring that a portion of the funding go directly to SDOH-E partners through a formal agreement (e.g., contract or memorandum of understanding – MOU). Through these agreements, the CCO can commission CBOs or other SDOH-E partners to deliver a service or program, and/or foster policy or systems changes that address the SDOH and equity.
Oregon renamed this legislative requirement the Supporting Health for All through REinvestment (SHARE) Initiative. The SHARE Initiative was implemented on January 1, 2021 with the income/reserves produced by the CCOs in 2020. Under SHARE, the CCO must spend some of its profits/reserves on housing supports and may choose to spend the remainder of its funds in four priority areas: economic stability (e.g., access to quality childcare), neighborhood and built environment (e.g., quality, availability, and affordability of housing), education (e.g., high school graduation), and social and community health (e.g., trauma, such as adverse childhood experiences). The OHA reserves the authority to approve the CCO’s spending priorities and plans for the SHARE funding. These requirements align with the public health agency’s state health improvement plan for 2020-2024 which established economic drivers of health, such as housing, transportation and living wage jobs, as one of five priorities.