Public Health Emergency for COVID-19 Ending May 11, 2023

Public Health Emergency for COVID-19 Ending May 11, 2023

On January 30, 2020, the United States declared a Public Health Emergency (PHE) around the novel coronavirus. The outbreak was later categorized as a pandemic on March 11, 2020.

The Biden Administration is planning to allow the COVID-19 Public Health Emergency to come to an end on May 11, 2023.

The public health emergency ending in May will have widespread impacts on people of all backgrounds. It will also influence both sides of the healthcare spectrum: provider and patient.

During the public health emergency, millions of Americans benefited from free COVID tests, treatments, and vaccines throughout the pandemic. When the emergency comes to an end, there will be shifts in how these COVID-related items will be managed and paid for - as well as other consequences.

The emergency is continuing until May 11, 2023 to allow hospitals, healthcare providers, health officials, and the general public to prepare for the changes that will ensue once it ends.

Healthcare providers and hospitals are planning their strategies for how to continue helping their communities while ensuring to still receive payments. To alleviate confusion and provide clarity, NCDS Medical Billing has created a guide below about the end of the COVID-19 Public Health Emergency.

Is COVID-19 Still a Public Health Emergency?

The COVID-19 Public Health Emergency will come to an end starting on May 11, 2023.

The COVID-19 Public Health Emergency was initiated in January 2020 and was originally set to expire on April 11, 2023.

By declaring the PHE in January 2020, the U.S. federal government was able to access resources and funds that allowed them to have many COVID-19 related needs paid for. This included necessities like personal protective equipment, vaccines, and tests.

The government also was able to modify Medicaid and Medicare reimbursement policies. This allowed those covered by these programs to have increased resource and treatment access.

The Biden Administration extended the emergency declaration to May 11, 2023, and it will officially end at that time. The Administration had committed to at least a 60-day notice of termination of the Public Health Emergency.

WHO United States of America COVID-19 Case Data as of February 2023

World Health Organization data shows that although COVID-19 cases have been lower at the time of determination, the virus is still affecting hundreds of thousands of Americans as of February 2023.

With COVID-19 still being a threat and the Public Health Emergency coming to an end, healthcare providers must understand the policy, medical billing, and payment changes that will shift as a result.

Why is the COVID-19 Public Health Emergency Ending?

The Department of Health and Human Services (HSS) shared:

“We are in a better place in our response than we were three years ago, and we can transition away from the emergency phase.”

A few of the statistics, factors, and considerations that went into the decision to end the COVID-19 Public Health Emergency include:

• The implementation of the largest adult vaccination program in American history - nearly 270 million Americans received at least one COVID-19 vaccine shot.
  • NCDS Medical Billing helped debunk and prove myths and facts about the COVID-19 vaccine to encourage vaccination.
• Since the Omicron surge in January 2022:
  • COVID-19 daily cases reduced 92%
  • COVID-19 deaths reduced over 80%
  • COVID-19 hospitalizations reduced nearly 80%

HSS’s perspective is that as a country, we’ve come to a point in the pandemic where we have conquered the worst part of it. We've accomplished this through a high level of effort, investment, and innovation. Our nation’s leaders feel that the greatest challenges from COVID-19 are behind us.

However, despite the ending of the Public Health Emergency, COVID-19 is still a major public health priority for the Biden Administration.

Results from the KFF COVID-19 Vaccine Monitor Research

KFF data finds that nearly 4/10 people had been sick with either the flu, COVID-19, or RSV  in January 2023.

In addition to actual recent illnesses, 31% of people are still concerned about getting seriously sick from COVID-19. COVID-19 is even more top of mind for immunocompromised individuals, with 40% still being concerned about getting seriously ill.

Results from the KFF COVID-19 Vaccine Monitor Research

As the data shows, there are still public concerns about COVID-19, and the government intends to help ease the transition.

The White House stated: 

“An abrupt end to the emergency declarations would create wide-ranging chaos and uncertainty throughout the health care system — for states, for hospitals and doctors’ offices, and, most importantly, for tens of millions of Americans.”

By providing a grace period between the announcement of the ending of the Public Health Emergency and the actual end of the PHE, all parties can prepare for when May 11 comes.

What Will Change When the COVID-19 Public Health Emergency Ends?

The end of the COVID-19 Public Health Emergency will bring about a variety of changes and implications that are related to varying healthcare needs, not just COVID-19 related needs.

Dr. Josh Sharfstein of Johns Hopkins Bloomberg School of Public Health noted that the COVID-19 Public Health Emergency declarations brought on “a public health approach to health care during the pandemic. They helped a lot of people to get services. Now we’re going back to a health care approach to health care, and that brings all of the weaknesses of our system into play.”

Understanding the changes and implications of the end of the COVID-19 Public Health Emergency will allow both healthcare providers and those seeking care to be as educated and prepared as possible.

COVID-19 At-Home Testing

What’s Changing for At-Home Testing

Medicare:

Receiving COVID-19 tests will become more costly for those under Medicare.

During the COVID-19 PHE, people receiving Medicare were able to receive free at-home tests.

After the PHE comes to an end, those with traditional Medicare will no longer be guaranteed free at-home tests.

For those with Medicare Advantage, some insurers may cover COVID-19 tests but from a smaller range of in-network providers.

Medicaid:

For those covered by Medicaid, at-home tests have been covered by the PHE. They will continue to be covered for free through September 2024.

After September 2024, coverage for at-home tests will vary on a state-by-state basis.

Private Insurance:

Receiving COVID-19 tests will also become more costly for those with private insurance.

During the COVID-19 PHE, Americans with private insurance were able to receive free at-home tests.

After the PHE comes to an end, privately insured people will no longer be guaranteed free at-home tests. However, some insurers may cover COVID-19 tests but from a smaller range of in-network providers.

What’s Not Changing for At-Home Testing

Uninsured:

Most uninsured were already paying full price for at-home tests. However, free COVID-19 at-home tests may still be found through USPS’s free tests provided via mail, free clinics, community health centers, or other local organizations.

PCR/Rapid Tests Requested or Administered by a Health Professional

What’s Changing for Health Professionals Requested or Administered COVID-19 Testing

Medicare:

When the PHE ends, there will be no cost for the COVID-19 test itself. However, there could be potential costs for the doctor’s visit associated with the test.

For those under Medicare Advantage, both the COVID-19 test and associated doctor’s visit could have potential costs depending on what plan the beneficiary is under.

Medicaid:

For those covered by Medicaid, free testing will continue through September 2024.

After September 2024, the costs will be determined on a state-by-state basis.

Private Insurance:

For those under private insurance, both the COVID-19 test and the doctor’s visit could have potential costs depending on what plan the beneficiary is under.

There also may be a shift in the way insurers cover COVID-19 testing. There may begin to be a limit on the number of covered tests. Additionally, insurers may require that tests are completed by in-network providers.

Uninsured:

For those who are uninsured, 15 states had adopted a temporary Medicaid coverage option under the PHE. Once the PHE ends, those living in those 15 states will no longer have the COVID-19 testing services that were available.

What’s Not Changing for Health Professionals Requested or Administered COVID-19 Testing

Uninsured:

For the uninsured who were not in one of the 15 states that offered temporary Medicaid, this group will continue to pay full price for COVID-19 testing. However, there are often community options such as free clinics and community health centers to offer free testing options.

COVID-19 Vaccines

What’s Changing for COVID-19 Vaccines

There will be no changes to how COVID-19 vaccines are managed. The supply of federally purchased COVID-19 vaccines and boosters manages how it is offered, not the Public Health Emergency.

Availability, access, and costs of the COVID-19 vaccines will remain the same.

What’s Not Changing for COVID-19 Vaccines

COVID-19 vaccines will continue to be free to all, no matter what type of insurance coverage.

As long as the federally purchased vaccines are available, the COVID-19 vaccine will continue to be available and free.

Those who provide vaccines purchased federally may not charge patients. Or, they may deny vaccines as a result of the patient’s coverage type.

What Happens When the Federal Supply of COVID-19 Vaccines is Depleted?

Once the federal supply of COVID-19 vaccines is depleted, vaccines will continue to be free for most people covered by private and public insurance. This is due to the Affordable Care Act and other legislation.

Uninsured and underinsured adults may encounter cost barriers once the federally purchased doses are gone.

Those who are privately insured potentially will need to ensure that their provider is in-network.

COVID-19 Treatment

What’s Changing for COVID-19 Treatment

Medicare:

Those covered by Medicare may encounter cost-sharing requirements for COVID-19 pharmaceutical treatments once the COVID-19 Public Health Emergency ends.

Medicaid:

Those covered by Medicaid will continue to have all COVID-19 pharmaceutical treatments covered through September 2024.

After September 2024, COVID-19 pharmaceutical treatments will still be covered. However, there may be utilization limits and cost-sharing brought on depending on the beneficiary’s state of residence.

What’s Not Changing for COVID-19 Treatment

In general, pharmaceutical treatment for COVID-19 that has been purchased by the federal government continues to be free for all. No matter what type of coverage a patient has, treatments such as Paxlovid will continue to be free.

Similar to the COVID-19 vaccine above, COVID-19 treatment has been purchased by the federal government. The free status of COVID-19 treatments depends on availability and supply. It will not be affected once the COVID-19 Public Health Emergency comes to an end.

Telemedicine

Telemedicine increased in popularity as a result of the pandemic. This kept people connected to their doctors when they otherwise wouldn’t have been able to receive care, treatment, and consultation.

Due to necessity, telemedicine was allowed unique flexibility as a result of the COVID-19 Public Health Emergency.

For a deep dive on trends in the use of telemedicine during the COVID-19 pandemic, check out the NCDS blog. While telemedicine’s popularity is here to stay, some of these trends and uses will change as a result of the end of the COVID-19 PHE.

What’s Changing for Telemedicine

People seeking assistance via telemedicine will notice the following changes:

• Prescriptions for controlled substances will require in-person visits after May 11
• Patients may no longer be able to continue seeing certain providers. Some state licensure requirements may shift for providers who had state licensure requirements waived due to having equivalent licenses in other states to practice remotely via telehealth.
• Technologies that providers use for telehealth may shift as a result of the end of the COVID-19 Public Health Emergency. Penalties against providers using non-compliant privacy and security technology to provide telehealth services were waived during the PHE. After May 11, these will be reinforced. Telehealth providers must ensure to use of HIPAA-compliant technology going forward to avoid penalties.

What’s Not Changing for Telemedicine:

Telemedicine will continue to be a popular way of receiving care, despite the end of the PHE.

How Will Healthcare Providers be Affected by the End of the COVID-19 Public Health Emergency?

Healthcare providers and hospitals will have to adapt to some major shifts. These changes will affect how healthcare is given and paid for when the COVID-19 Public Health Emergency ends.

After operating under the conditions of the COVID-19 Public Health Emergency, time to adjust and prepare prior to May 11 will be necessary. Providers will need to build a strategy to best serve their communities in a world where COVID-19 still exists but the Public Health Emergency is over.

Providers have shared their concerns and called upon the government for continued help during this transition.

Particularly, AAFP Board Chairman Sterling N. Ransone Jr., MD, shared a letter on February 14th:

“Given that many of these policy changes have been in place for nearly three years and, in some cases, have significantly altered the health care coverage and delivery landscape, transitioning away from the federal FHE could cause considerable disruptions to physicians and patients.” 

Overall, the AAFP requests that the president’s administration develops and shares “a comprehensive plan for unwinding the flexibilities and waiver authorities available [under] the PHE, as well as use its authority to minimize disruption.”

How Will Telemedicine Change for Providers?

Telemedicine experienced a major increase in usage as a result of the pandemic. This option helped patients and providers who needed to stay close but not risk in-person visits.

CDC Telehealth Data, 2021

As a result, in 2021, 37% of adults used telemedicine in the last 12 months according to CDC data.

There were certain unique leniencies that providers were allowed to take as a result of the COVID-19 PHE:

• Prescription Writing:
  • Prescriptions could be written for controlled substances via telemedicine. However, these prescriptions will need to be written in person after the PHE expires.
• Licensing:
  • Licensing will need to be updated for the states that providers practice in, as providers with equivalent licenses in other states were able to practice via telehealth. These licenses may need to be updated depending on state policies.
• HIPAA-Compliant Technology:
  • Providers will need to ensure that their technologies used for telehealth are HIPAA compliant. During the PHE, penalties were waived for non-compliant technology. However, these penalties will begin to be enforced again come May 11.

How Are Patients Billed for COVID-19 Vaccines After the COVID-19 Public Health Emergency Ends?

Vaccines will continue to be provided for free. But, ensuring that medical billing and coding are completed properly will help ensure your practice has peace of mind when providing care.

NCDS offers expertise on how to conduct billing and coding for the COVID-19 vaccine, both prior to and after the federal supply is depleted. NCDS creates custom billing solutions both for Pharmacies/Immunization Clinics and Physician Practices. We were also among the first to implement COVID-19 billing into our advanced technology platform in December 2020.

How to Help Your Practice Transition After the COVID-19 Public Health Emergency Ends

The end of the Public Health Emergency is a great time to rethink how your practice is ensuring compliance, efficiency, and providing the best care possible during this time of transition.

A great place to start is with your medical billing services.

Contact NCDS Medical Billing to see how we can help your practice prepare for the end of the PHE. We'll also help you get the most out of your revenue cycle, and focus on your patients and community.

Questions?