The Biden Administration announced its plan to end the COVID-19 national emergency and public health emergency (PHE) on May 11, 2023. The Department of Health and Human Services initially declared the COVID-19 PHE on January 31, 2020. The end of the PHE will significantly impact health plans.
Health Plan Changes
The COVID-19 emergency caused employer-sponsored health plans to comply with different requirements. The following rules related to the pandemic will no longer apply once the PHE ends:
- Standalone telehealth benefits. Large employers (more than 50 employees), were allowed to offer standalone telehealth benefits to individuals not eligible for coverage under any other group health plan offered by the employer without violating the Affordable Care Act’s market reforms. After the PHE ends, these standalone benefits will not be permitted.
- Out-of-Network COVID-19 Vaccines. The PHE covered coronavirus preventive services and immunizations, without cost-sharing requirements, through both in- and out-of-network providers. However, after the PHE, coverage will only extend to these services when using in-network providers.
- Coronavirus Diagnostic Testing without Cost Sharing. Once the PHE ends, health plans and issuers will no longer be required to cover COVID-19 tests and related services without imposing any cost-sharing, prior authorization, or additional medical management requirements.
Affected Deadline Extensions
Many employer-sponsored group health plan deadlines were extended due to the COVID-19 outbreak period. Once the COVID-19 national emergency ends, the outbreak period will end 60 days after. Therefore, if the national emergency ends on May 11, 2023, the outbreak period will end on July 10, 2023. Once the outbreak period ends, health plans will revert to their nonextended deadlines for:
- HIPAA special enrollment,
- COBRA Notices and Premium Payments,
- And claims and appeals.
As more information is made available, Creative Benefits will release updates. If you have any questions, please contact your dedicated Creative Benefits team member.