Report 2025-29
Objective
The objective of this audit was to determine the extent to which the Oregon Health Authority (OHA) is meeting the objectives set forth by Ballot Measure 110 (2020), as amended by the Legislature in Senate Bill 755 (2021), as amended by House Bill 2513 (2023), as amended by House Bill 4002 (2024), and as amended by Senate Bill 610 (2025).
Scope
The audit focused on efforts made by OHA to coordinate Measure 110 (M110) to serve families and individuals affected by substance use disorder. Our audit considered the program from 2021 through July 2025 and builds upon our two prior reports on the implementation of the M110 program.
Why this audit is important
Oregon is among the highest in the nation for substance use disorder and use of illicit drugs. In 2023, more than 1,700 Oregonians died from a drug overdose.
M110 was passed by Oregon voters in 2020 to expand access to drug treatment and recovery services. It also removed criminal penalties for possession of personal quantities of drugs. In September 2024, legislation took effect that significantly changed the program by recriminalizing controlled substances. The program is funded by cannabis tax revenue.
M110 providers offer services not funded by other government programs, such as Medicaid, and are an important part of the behavioral health care continuum. The state awarded $391 million in grants to M110 providers, known as Behavioral Health Resource Networks (BHRNs), in 2025. About $800 million has been awarded since 2021.
What we found
The vision laid out in M110 — to replace criminalization of substance use disorder with a public health approach — remains unfulfilled due to persistent structural and operational weaknesses across Oregon’s behavioral health system. A coordinated approach would help ensure access to care, and the chance for recovery, does not depend on where a person lives. For a problem that is decades in the making, it will likely take decades of intentional effort to correct. Instead, the pattern of annual revisions has undermined confidence in the program’s direction and hindered the development of long-term strategies. Additionally, without action by OHA to address governance, integration, and accountability, the program has little to no chance to fully deliver on its promise to help Oregonians struggling with addiction. The state’s efforts address only the symptoms of substance use disorder, without effectively treating the underlying disorder itself.
Governance and leadership instability have contributed to inconsistent guidance and poor grant oversight.
The grant process has been inconsistent since the start of M110. A lack of consistent prioritization by OHA leadership, operational turnover, and multiple legislative changes have further complicated efforts to operate the program.
OHA has not yet strategically integrated M110 services into Oregon’s broader behavioral health system.
OHA did not integrate the newly created M110 provider network into the broader continuum of care supported by Medicaid and other state or federal programs. Fragmentation reduces the efficiency and effectiveness of service delivery.
Flawed data and unclear goals prevent OHA from demonstrating M110 effectiveness.
OHA has not collected sufficient information to determine the number of people served or outcomes from the program.
The former M110 telephone hotline was inefficient from the beginning.
As an example of OHA’s dysfunctional implementation, the additional hotline for M110 was redundant and lacked strategic integration, as it duplicated existing efforts and cost the state significant resources.
Counties’ implementation of deflection programs provides inequitable access to services.
Deflection programs, a form of law enforcement intervention created in Oregon in 2024, are implemented inconsistently across counties. In some jurisdictions, deflection does not exist at all, raising concerns about equity of access.
What we recommend
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Develop an implementation roadmap with timelines, assigned accountability, and key deliverables for program integration, evaluation, and outreach.
Agency response:
Agree
Target completion date: Program integration: December 31, 2026. BHRN evaluation and outreach: June 30, 2026
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Communicate updated operational definitions for “culturally and linguistically specific services” and “culturally responsive services” to BHRN grant developers and evaluators, and M110-funded providers in future grant cycles.
Agency response:
Agree
Target completion date: December 31, 2028
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Require all M110-funded providers to begin participating in standardized interim data reporting using established systems.
Agency response:
Agree
Target completion date: March 31, 2026
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Complete a baseline analysis using available or proxy data. This analysis should be used to set future performance targets, identify service gaps, and address key questions in law including whether, since December 3, 2020:
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Overdose rates declined.
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The number of drug and alcohol treatment service providers increased.
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The number of culturally specific providers increased.
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Access to harm reduction services has increased.
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More individuals are accessing treatment than they were before December 3, 2020.
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Access to housing for individuals with substance use has increased.
Agency response:
Disagree
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Publish a yearly performance report with standardized measures of M110 program outcomes against the retrospective baseline and statutory goals.
Agency response:
Disagree
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Implement data-sharing infrastructure to support integrated care pathways and monitor the continuity of treatment and recovery services for people with substance use disorder engaging with the M110 program.
Agency response:
Disagree
Agency Response
OHA agreed with three of our six recommendations. The response can be found at the end of the report.
