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Essential Health Benefits (EHB) Rulemaking Advisory Committee

​The Department of Consumer and Business Services (DCBS) is convening an advisory committee to consider possible changes to Oregon’s Essential Health Benefits (EHB).

The committee will make recommendations related to:

  • Review and consideration of Oregon’s EHB benchmark plan options for 2022
  • Supplemental benefits necessary to meet federal requirements
  • Changes to Oregon’s current EHB Benchmark plan. Possible areas for consideration include:
    • Ensuring adequate coverage of insulin in the EHB prescription drug formulary;
    • Ensuring Oregon’s EHB adequately addresses the opioid crisis, including access to Medication Assisted Therapy (MAT); and
    • Other issues related to EHB identified by the committee or the Division.

Any proposed revisions to Oregon’s EHB will be subject to approval by the federal Centers for Medicare and Medicaid Services (CMS). CMS has established firm deadlines and procedural requirements that states must follow when changing their EHB.

Request for Comment - Proposed Changes to Oregon’s Essential Health Benefits for 2022

Background on Essential Health Benefits:

Essential health benefits (EHB) are the benefits, items, and services that must be covered by individual and small employer health benefit plans in Oregon. Under the Affordable Care Act, each state selects its own set of EHB in accordance with guidance provided by the federal Centers for Medicare and Medicaid Services (CMS).

For plan years prior to 2020, CMS regulations require states to define their EHB by reference to a “base benchmark plan” that was chosen from a fixed set of options. The base benchmark was then supplemented as necessary to ensure coverage for all required categories of essential health benefits. Oregon has selected PacificSource Health Plans’ Preferred CoDeduct Value small employer plan as its EHB benchmark.

Beginning with the 2020 plan year, CMS regulations give states additional flexibility to define their EHB. The new flexibility allow states to revise their EHB selections using one of three options: (1) selecting another state’s entire EHB benchmark, (2) replacing a category of benefits in the current benchmark with the same category of benefits used in another state EHB plan, or (3) otherwise selecting a set of benefits to become part of the state EHB plan. Several states have relied on the third option to add benefits not covered by their benchmark plans to their EHBs.

States proposing to make changes are required to have an actuarial analysis of the benefits, a public comment on the proposed benefit changes, and submit an application to CMS as specified by 45 CFR 156.111(a).

2022 Essential Health Benefits Rules Advisory Committee

The Division of Financial Regulation (DFR) convened an Essential Health Benefits Rulemaking Advisory Committee to review, discuss, and propose ideas for additions and changes to Oregon’s EHBs beginning with the 2022 plan year. The committee met three times on February 21, March 10, and March 26, 2020. Representatives from consumer advocacy groups, insurers, and provider groups participated in the RAC and consideration of proposed benefits to further analyze. The division reviewed the information and feedback from the committee to recommend benefits for the 2022 Benchmark Plan.

Summary of Proposed Changes:

The division is seeking CMS’ approval to add four benefits to Oregon’s Essential Health Benefits beginning in 2022.



Estimated Cost Per Member Per Month

1. Coverage of up to 20 visits for spinal manipulation each year



Coverage of up to 12 visit for acupuncture each year


3. Removal of prescribing barriers to Buprenorphine for medication-assisted treatment of opioid use disorder


4. Provide prescription of at least one intranasal opioid reversal agent (e.g. Narcan) for initial opioid prescriptions of 50 morphine milligram equivalents



These benefits are discussed further in the application documents available below.

  1. OR – CMS State Confirmation Template 2022
  2. NovaRest Actuarial Confirmation and Draft Report
  3. Actuarial Certification
  4. Benchmark Plan Document
  5. OR – 2022 Formulary Drug List Template
  6. OR – 2022 Benchmark Summary Chart

The department is seeking public review and comment on this proposal. The public comment period for the proposed EHB will be open until May 6, 2020. All comments received will be given full consideration by the department before finalizing the proposed benefits and submission to CMS.

Comments can be submitted in the following ways  (Please include reference to essential health benefits in the subject line of your comment):


Department of Consumer and Business Services
Division of Financial Regulation
350 Winter St. NE
P.O. Box 14480
Salem, OR 97309-0405

Proposed: April 23, 2020

Last day for public comment: May 6, 2020, 5 p.m

Meeting schedule and location:

Labor and Industries Building
350 Winter St NE
Salem, OR 97301
Conference Room 260
 Google Maps

Call in participation:

Call: 877-336-1831
Access code: 9971342#

Meetings and documents:

Public Meetings

The EHB Rulemaking Advisory Committee’s meetings are open to the public. The meeting can be live streamed at:
The meeting is held in Conference Room 260. Limited time is available at the meeting to present comments in person. All individuals who wish to submit public comments are strongly encouraged to do so in writing via email to:


Public comments

Committee members

Andrea Szabo
Bridgett Quest
Samaritan Health Services
Cortney Rouse
American Massage Therapy Association
Dave Nesseler-Cass
Moda Health/Delta Dental
Jeff Clark, ND
Oregon Association of Naturopathic Physicians
Karin Hoffman-Burns
Oregon Association of Health Underwriters
Kate Murphy
Regence BCBS
Lisa Pool, LAc
Blue Sky Acupuncture, LLC
Mark Summers
Pacific Benefits Consultants
Megan Lane
Providence Health
Numi Lee Griffith
Sadie Ellwood
Kaiser Permanente
Tony Kopki
Vern Saboe, DC
Oregon Chiropractic Association

​Committee contact

Michael Schopf
Senior Policy Advisor,
Oregon Division of Financial Regulation
Phone: (503) 877-7275

Karen Winkel
Rules Coordinator,
Oregon Division of Financial Regulation
Phone: (503) 947-7694