Featuring: Rebecca Stitt-Laugherty | Associate General Counsel-Regulatory
The Biden Administration announced Jan. 30 that the COVID-19 public health emergency (PHE) declaration will end on May 11 with the goal of preventing an abrupt end and allowing more than 90 days for healthcare providers to adjust to the operational and financial implications.
Below is an initial summary of key changes and considerations.
Key changes associated with the end of PHE:
- There will be a drawdown of most federal COVID-19 relief money, including the 20 percent increase in Medicare reimbursement that hospitals have received for COVID-19 patients during the PHE period.
- Millions of people could lose Medicaid coverage as states reexamine eligibility starting April 1. Since 2020, states were prohibited from performing routine eligibility redeterminations and disenrolling participants that are no longer eligible. This is expected to reduce current Medicaid enrollment by 15-21%.
- The costs associated with COVID-19 vaccines, some tests and certain treatments will be transferred to private insurance and government health plans. Uninsured people will no longer be able to access free vaccines through state Medicaid programs.
- Medicare coverage of telehealth services are no longer tied to the PHE declaration, with some permanent changes in effect and some flexibility extended through 2024.
- The provisions for telehealth services being provided as an excepted benefit and ability to use any non-public facing application to communicate with Medicare-covered patients will end on May 11.
- Acute care hospital at home waivers and flexibilities are also extended through 2024 as they are no longer tied to the PHE declaration.
Key considerations for healthcare providers:
- If large volumes of your community lose Medicaid coverage, are you prepared to exhaust coverage discovery efforts to ensure any eligible financial assistance is available to each patient?
- What impact will reduced reimbursement for COVID-19 treatment have on your revenue?
- Are you budgeting and planning for the potential increase in bad debt based on shifting costs and billing processes?
- How will this impact your approach to telehealth?
- How will you educate and retrain staff on flexibilities and waivers that will no longer exist?
- What new billing processes are needed to handle the end of flexibilities and waivers?
We will provide an in-depth analysis of major implications and key considerations for healthcare providers as the industry prepares for the changes associated with the end of the PHE declaration.
These materials are for general informational purposes only. These materials do not, and are not intended to, constitute legal or compliance advice, and you should not act or refrain from acting based on any information provided in these materials. Neither Ensemble Health Partners, nor any of its employees, are your lawyers. Please consult with your own legal counsel or compliance professional regarding specific legal or compliance questions you have.