Editor's note: This article was updated on May 9, 2023 to reflect the COVID-19 status change from the World Health Organization (WHO).
The United States federal government’s public health emergency (PHE) designation for COVID-19 officially ends on May 11, 2023, with public health still remaining a "significant" priority. On the global stage, the World Health Organization announced on May 5, 2023 that while COVID remains an established and ongoing health issue, it is no longer is deemed a public health emergency of international concern (PHEIC).
For leaders and clinicians responsible for public health in the US, these transitioning designations are causing a period of uncertainty and unpredictable increases in variability of care — but they’re also bringing opportunity. Gaps left by the national PHE can provide multiple opportunities for hospital administrators, pharmacy leaders, community health centers, and public health professionals to shape the health of their communities in new ways.
Five ways the PHE change will impact public health
The end of the PHE doesn’t directly correlate with the end of all programs and benefits. It’s also connected to changes in other legislation, including the Consolidated Appropriations Act, 2023 (CAA); the Coronavirus Aid, Relief, and Economic Security (CARES) Act; the American Rescue Plan Act (ARPA); the Families First Coronavirus Response Act (FFCRA); and the Inflation Reduction ACT (IRA).
To effectively adjust to these legislative shifts, US healthcare leaders supporting clinical staff through this period will need to understand the following changes on the horizon.
1. Coverage for testing, treatments, and vaccines
Throughout the pandemic, Medicare beneficiaries paid no cost sharing for home services and certain treatments, but the end of the PHE marks the end of this exemption, except for coverage and costs related to oral antivirals that align with changes in the CAA. Medicaid and CHIP benefits are no longer tied to the PHE, and programs will now be required to cover the COVID-19 vaccine and vaccine administration without cost sharing as a mandatory Medicaid benefit.
On the private health insurance side, the end of the PHE means that group health plans and individual health insurance plans are no longer required to cover COVID-19 tests or testing-related services without cost sharing, prior authorization, or other requirements of medical management. Additionally, plans are no longer required to reimburse out-of-network providers for tests and other related services.
2. Medicaid reimbursement
During the PHE, states were receiving a 6.2 percentage point boost in their regular federal matching rate under certain conditions. As of March 31, 2023, however, the CAA has decoupled the continuous enrollment provision from the PHE and ended continuous enrollment.
3. Telehealth benefits and flexibilities
Many healthcare providers expanded telehealth access and benefits during the PHE, including allowing Medicare beneficiaries to remain in their homes for telehealth visits and allowing physicians to deliver telehealth services by smartphone. The CAA has extended these and other flexibilities through the end of 2024, independent of the status of the PHE. Similarly, the government has extended the flexibility of Federally Qualified Health Centers (FQHCs) and rural health clinics to provide telehealth services to Medicare patients through the end of 2024.
State flexibilities in expanding coverage and/or access to telehealth services under Medicaid are a mixed bag, with some tying flexibilities to federal and/or state public health emergencies and most states making Medicaid telehealth flexibilities permanent.
4. Hospital and nursing home reimbursement
The end of the PHE also marks the end of the 20% increase in Medicare payments through the Hospital Inpatient Prospective Payment System (IPPS) and the end of the waiver of the three-day prior hospitalization transfer requirement for skilled nursing facilities. These changes require acute and post-acute leaders to adjust to potential drops in future revenues and increases in administrative burden.
5. FDA emergency use authorization
Fortunately, the emergency use authorization for COVID-19 vaccines, tests, and treatments under the US Food and Drug Administration (FDA) aren’t impacted by the shift. The agency is also still able to issue emergency use authorizations.
How providers should respond to the end of the COVID public health emergency
The coming months and years will be a journey of helping hospitals, community health centers, and patients of all types adjust to the “next normal” — even as support and provisions continue to fluctuate. To adapt and reduce the variability in care that impedes positive outcomes for patients and communities impacted by, consider taking the following actions.
Refresh your public health strategy
The future of healthcare is shifting, so leaders need to adapt their strategy, messaging, and communication to reflect both the end of the COVID PHE and the impact on their state, region, and organization.
Pharmacists, in particular, will play an even more significant role in supporting healthcare access and patient education. To adapt to this shifting environment, pharmacists need to:
- Communicate the end of programs, such as free over-the-counter COVID-19 tests.
- Navigate shifting reimbursement rates, such as the end of the $75 reimbursement for at-home vaccines,
- Work to decrease flexibility in prescribing controlled substances.
Get familiar with the effects of long COVID
Affecting one out of every five infected people, long COVID will likely be a defining feature of the virus. The Centers for Disease Control and Prevention (CDC) reports that one in thirteen adults — or 7.5% — have long COVID symptoms, which last three or more months after initially contracting the virus. These conditions are more likely to affect the elderly, women, Hispanic people, bisexual people, and transgender adults.
In terms of mental health, rates of anxiety, depression, and substance use disorder increased during the peak years of the pandemic. Additionally, the COVID-19 virus itself can involve symptoms such as anxiety, depression, cognitive deficits, attention deficits, and suicidal behavior. Children have also been impacted, with changes to routine, financial instability, and caregiver absence or loss potentially contributing negative factors to their mental health.
Leaders should expect that this condition — and its effects — will have a unique and evolving impact on their care community, and they should provide clinicians with ongoing continuing education to keep pace with these impacts.
Examine health and social inequalities
Like past pandemics, COVID-19 both revealed and worsened social inequalities — and going forward, healthcare leaders will need to take an even deeper look. Compared to those living in resource-heavy communities, people living in areas of social disadvantage had higher rates of mortality from COVID. Toronto saw a tenfold difference in COVID case rates between higher-income neighborhoods housing primarily white people and lower-income neighborhoods housing communities of color.
Medicaid enrollment exploded to 90 million people during the peak pandemic years, but states will be able to disenroll residents post-PHE. A full 15 million people could be kicked off Medicaid once the continuous enrollment period comes to a close. While solving these disparities is beyond the purview of healthcare leaders, they can and should commit to helping patients of all backgrounds reach their full health potential.
Community health centers have a particular advantage in this area, as they often have a heightened understanding of health disparities and strong relationships with the communities most at risk. Other organizations, such as hospitals, pharmacies, and physician offices, should consider partnering with these organizations to tap into their existing community trust, expertise, and improved outcomes for certain demographic groups.
Plan for tracking infection rates
As federal tracking peters off, organizations will need alternative ways to stay on top of COVID-19 data. The PHE required states to share data with the CDC, and while government will continue to encourage this collaboration in the future, some states will likely choose not to participate. But this doesn’t mean you’re left in the dark.
Hospitals and nursing homes will still report data through the Centers for Medicare and Medicaid Services at least through 2024. Public and private organizations are also continuing to track critical public health measures, such as leveraging wastewater data as an alternative to case counts to understand surges.
Get ahead of your financial future
The end of the PHE represents major shifts in healthcare reimbursements, requiring healthcare financial leaders to prioritize budgeting and forecasting in their organizations. In addition to Medicare and Medicaid changes, reimbursements and flexibilities for telehealth for the following services end alongside the PHE end date, according to the American Hospital Association:
- Cardiac, intensive cardiac, and pulmonary rehabilitation services.
- Parity for services performed via telehealth.
- Services provided by physical and occupational therapists, speech language pathologists, and audiologists.
Long COVID promises its own challenges. A Harvard economist estimates a $528 billion increase in spending due to the treatment of COVID long haulers. Financial leaders will play a critical role in keeping organizations healthy by budgeting effectively and reducing healthcare costs.
Ultimately, healthcare leaders will need every tool in their population health toolbox to keep patients, organizations, and communities healthy through the next phase of the COVID pandemic. By using healthcare analytics fluidly, accessing trend data, and garnering instant access to the most important insights, leaders can enable their organizations to adapt effectively.
Explore how your organization can take its next critical step in population health management and in reducing clinical variation with expert solutions from Wolters Kluwer.
