It’s official. The Biden Administration announced the COVID-19 national emergency and public health emergency will end on May 11, 2023. The advanced notice is to allow time for states, hospitals, insurers, and others to prepare for changes that have been in place since the emergencies were first declared. Here’s what that means for healthcare and healthcare coverage.

Vaccines and Testing

The federal government will no longer be absorbing the costs for COVID-19 vaccines and testing. Those costs will shift to individuals and health plans. Individuals will be responsible for COVID-19 testing and treatment costs, subject to the cost-sharing requirements of their health plan. Vaccines will be covered by health plans at 100% as a required preventive care benefit, but only at in-network providers.

Medicaid

States will begin the Medicaid redetermination process starting in April. While the COVID-19 emergencies have been in place, states have foregone redetermining eligibility for Medicaid coverage in return for increased federal funding. It’s believed that several million individuals will lose Medicaid coverage once the redetermination process begins. Please note this process is beginning prior to May 11, 2023 because of a previously passed spending bill by Congress.

Medicare

Hospitals have received increased payments from the government when treating Medicare patients who havebeen diagnosed with COVID-19. These increased payments will come to an end.

ERISA Plan Extensions

Health and welfare plans that are subject to ERISA have been required to extend certain benefit deadlines. In particular, employees and their covered dependent have had extra time to:

• Enroll in a group health plan under a qualified HIPAA special enrollment period.
• Elect COBRA coverage, make a COBRA premium payment, or notify the plan administrator of a COBRA qualifying event or determination of a disability.
• File a claim for benefits, appeal a claim that was denied in whole or in part, request an external review of a final adverse benefit determination, or file information to perfect a request for an external review.

ERISA Plan Extensions (cont’d)

Employers and health plans have been required to disregard a period of time called the “Outbreak Period” when extending these benefit deadlines. Plan deadlines have been required to be extended to the earlier of 1) one year from the original deadline, or 2) sixty days from the end date of the national emergency - a date which is now known to be July 10, 2023. Regular deadlines will be enforced for events occurring after this date. As we get closer to the COVID-19 emergency end dates, we may see additional guidance from regulators to help with all these transitions.