PHE is ending – What does that mean?
WARNING: October 1, 2025 – no congressional action – we revert back to pre-COVID era of telehealth!
See newest article: Telemedicine – Back to Pre-COVID Requirements | McGovern Medical School
Latest CCHP Telehealth FAQ (while we WAIT!) FAQs-Medicare-Telehealth-Flexibility-End-FINAL.pdf (external link)
The TMA (external link) (Texas Medical Association) has released a quick read one page document that shows at-a-glance what is ending when. Although the current admin has declared May 11, 2023 to be the end of the PHE, they have given 151 days post end to ease into the ceasing of some waivers. Others, according to the CAA (Consolidated Appropriations Act ) will end December 2024.
2025 Update: See Telehealth First Quarter 2025 Update
Additionally, all healthcare providers are encouraged to reverify all of their Medicaid patients benefits. Many were renewed automatically during the PHE. All Medicaid payers are re-evaluating their members eligibility, and many will lose benefits that were offered during the PHE.
What’s returning with a vengeance? Payer audits (external link). Those are picking up speed, according to the RAC Monitor (external link). Which is why understanding which waivers (external link) affect your practice, and when, are the key to surviving outside scrutiny (external link).
Many of the cost sharing waivers are disappearing as well. So copays, coinsurance, and deductibles will apply when the waivers (external link) expire. Supervision requirements, especially in the PCE (Primary Care Exception) setting, will revert back to pre-pandemic requirements. Also, in the PCE environment, the waiver that allowed levels 4 and 5 to be reported without Attending physician “presence” is going away. Back to those level 3s only!
One thing that bloomed during the PHE, telehealth. Thankfully, looks like that one is here to stay. With some changes, of course.
Will the PHE really end on May 11, 2023? We’ll see. Until then, please read the CMS PHE Transition (external link) Fact Sheet for more details. Stay tuned to see what happens.
UPDATE: CMS recently released the following resources:
- FAQs on CMS Waivers, Flexibilities, and the End of the COVID-19 PHE (external link).
- Fact Sheet: What Do I Need to Know? CMS Waivers, Flexibilities, and the Transition Forward from the COVID-19 Public Health Emergency (external link)
- FAQs on CMS Waivers, Flexibilities, and the End of the COVID-19 PHE (external link)
- CMS Current Emergencies Web Page (external link)
- Prescribing Controlled Substances after the PHE ends (external link)
Other Resources:
April 2025 (HSRA tool (external link))
March 2025 TMA PHE Telehealth Chart (external link)