Preparing for the End of the COVID-19 Public Health Emergency
by Johanna Gray, Advocacy Consultant

Most experts expect that the COVID-19 Public Health Emergency will end later this summer. First declared in March 2020, it has been extended in 90-day increments since then, with the current declaration set to expire in July 2022. This matters to HTCs because a few important policies will lapse with the end of the PHE, or soon after:

Extension of telehealth services: The really significant expanses of telehealth services during COVID are tied to the length of the PHE, for the most part. This includes removal of the originating site of care requirements, which allows patients to be seen in homes, the allowance of audio-only services, and payment for telehealth services equal to outpatient/office visits. Congress extended some telehealth measures an additional 5 months after the end of the PHE, but that only applies to some of the policies and only to Medicare. Medicaid plans and private payers may follow Medicare’s lead with these extensions, but it’s not unclear. Congress is right now debating various policies to extend the telehealth flexibilities more permanently, but that is still up in the air.

Medicaid: Another very significant policy change relates to Medicaid. At the start of pandemic, Congress required states to provide continuous coverage for Medicaid enrollees until end of the month in which PHE ends in order to receive enhanced federal funding (6.2% increase). When the PHE ends, states must review eligibility of all beneficiaries to determine if they still qualify for coverage. States will lose the enhanced federal match at end of the quarter in which the PHE ends, putting financial pressure on states to move more quickly. In practical terms, this means that it has been hard for states to remove anyone from their Medicaid rolls, but once the PHE ends, they’ll start a process to re-qualify people for Medicaid, for the first time in more than two years. Many people are worried about how this process will go and the potential for families to lose coverage during this redetermination process. One think tank in DC said that that 15 million people could lose Medicaid coverage when the PHE ends so it is a process we will have to watch very closely.

The current declaration goes until July, though it could be ended sooner. The Biden Administration has pledged to give states and all stakeholders 60-days notice before ending the PHE, so we’ll have a bit of advanced warning. In the meantime, we encourage you to start to gather information on your patients enrolled in Medicaid and to learn about anything your state has said about the timing and process for redeterminations. Feel free to reach out to the Alliance advocacy and payer teams with any questions on this. Much more info to come, but we encourage HTCs to start thinking about this now so we can try to make sure that everyone maintains coverage.