Preparing for the end of the Public Health Emergency (PHE)

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April 17, 2023

The Public Health Service Act, initiating the public health emergency (PHE), was declared on January 31, 2020.  It has been renewed 13 times since then.  The PHE was put into place in response to the COVID-19 pandemic.  Several temporary waivers and flexibilities have been implemented by state and federal governments in response to the challenges faced throughout the nation.  On January 30, 2023, President Joe Biden announced that the PHE will end on May 11, 2023.  The end of the PHE signals the termination of the temporary waivers/flexibilities that were implemented throughout the pandemic (there are a few flexibilities that will extend past May 11, 2023).  Healthcare organizations will need to re-examine their current policies, procedures, processes, workflows, etc. in preparation to transition back to “normal” operations.

Some areas that should be evaluated are:

  • Operations
    • Telehealth
    • Medicaid patients and their coverage may be impacted
    • Coverage of COVID-19 over-the-counter, laboratory testing and vaccines will change, as well as, the patient’s cost-share
    • Provider licensure and credentialing
    • License flexibilities
    • Nursing staff training requirements
  • Compliance
    • HIPAA Rules which include Privacy, Security, and Breach Notification Rules
    • Business Associates and Vendor preparedness
  • Technology (compliance and operationalization)
      • Patient and provider facing applications
      • Privacy and security regulations
      • Remote physiological monitoring/digital healthcare
  • Finance and Revenue Cycle
      • COVID-10 related funding will be impacted (Provider relief funding, federal medical assistance percentage (FMAP) provided an additional 6.2 percentage points to each state’s Medicaid program)
      • Benefit and coverage requirements
      • Coding and documentation changes
      • Update Financial Hardship and Write-off Polices and review self-pay fee schedules

Not only should you consider your state and federal healthcare programs (Medicare, Medicaid, Tricare, etc.), but you should also contact your Commercial/Fee-for-Service payers and determine if they have post-PHE changes that will impact your organization and patients.

Review CMS’ Coronavirus waivers & flexibilities site https://www.cms.gov/coronavirus-waivers and determine which, if any waivers/flexibilities were implemented by your organization.  Examine your policies, procedures, and workflows to ensure you are post-PHE ready.  And make sure that your Business Associates and vendors are aware of the end of the PHE and prepared for the termination of any waivers/flexibilities that may have impacted them (and your organization).

If you have questions or would like more information on how we can help, please contact us today.

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