PHE is ending – What does that mean?

The TMA (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.

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. Those are picking up speed, according to the RAC Monitor. Which is why understanding which waivers affect your practice, and when, are the key to surviving outside scrutiny.

Many of the cost sharing waivers are disappearing as well. So copays, coinsurance, and deductibles will apply when the waivers 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 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.
• Fact Sheet: What Do I Need to Know? CMS Waivers, Flexibilities, and the Transition Forward from the COVID-19 Public Health Emergency
• FAQs on CMS Waivers, Flexibilities, and the End of the COVID-19 PHE
• CMS Current Emergencies Web Page
• Prescribing Controlled Substances after the PHE ends

NOTE:  You must be a part of the Interstate Medical Licensure Compact in order to provide telehealth services across state lines. Please visit the Texas Medical Board Interstate Licensure page for more information.

International Telemedicine follows the same guidance as the Interstate Medical Licensure Compact in that you must be licensed in the country where your patient resides. CHUBB has released a handy best practice check list.