How to transition your practice out of the COVID-19 public health emergency

Three years after the COVID-19 pandemic began, we know a lot more about the virus, prevention and immunity in our communities. As such, the Biden administration has announced the end of the COVID-19 Public Health Emergency (PHE) effective May 11th, 2023.

With the end of the COVID-19 PHE comes many changes and questions about how to ethically and legally adapt to a post-PHE world—especially as an employer, manager or healthcare worker. While there is a lot unknown, there are still some useful tips and information available to us now.

It comes as no surprise that with the end of the Public Health Emergency (PHE) many mandates or allowances that came with COVID-19 will dissolve as fast as they arrived. Clear communication and understanding of policies in your practice will be as important now as they were when they were taking effect. You should prioritize:

Discussing ending mask mandates
Discussing ending or continuing vaccine mandates
Discuss the end of additional COVID leave

Remember, even though COVID specific sick leave may be ending, many states still require regular paid sick leave so you should be aware of their state’s rules. It may also be important, regardless of what updates are made, to get all changed policy documents and handbooks electronically signed by your employees and stored securely and digitally.

Much of COVID times have led us to uncharted HR and legal territories—this post-PHE territory is no different. It is always better to be safe than sorry. Keep policies updated, signed and stored digitally to minimize legal risks in the case of future potential lawsuits. Don’t forget that compliant HR solutions, like HR for Health, do this for you so your practice is always covered.

Required free over-the-counter COVID testing is ending for many private insurers. 5-14 million Americans covered by Medicaid during the PHE provisions may also lose healthcare coverage, and therefore access to testing. This leaves communities with less access to testing that prevents spread of COVID-19.

Private insurers are encouraged to still cover the testing in full, but there could be a fee incurred
Medicare beneficiaries also out of luck: No more free OTC COVID-19 testing
Medicare and Medicaid still covers some testing costs in full: This is also known as not requiring cost-sharing, but this will end on September 30, 2024

Regardless of private insurance coverage, testing is a vital part of protecting your team and your patients from the spread of COVID and ensuring your practice stays fully operational.

HHS.gov:
People with Traditional Medicare can continue to receive COVID-19 PCR and antigen tests with no cost-sharing when the lab tests are ordered by a physician or certain other health care providers, such as physician assistants and advanced practice registered nurses. People enrolled in Medicare Advantage plans can continue to receive COVID-19 PCR and antigen tests when the test is covered by Medicare, but their cost-sharing may change when the COVID-19 PHE ends. Additionally, the program that allowed Medicare coverage and payment for over-the-counter (OTC) COVID-19 tests will end when the COVID-19 PHE ends on May 11; Medicare Advantage plans may continue to cover the tests, and beneficiaries should check with their plan for details.

Providers were given more flexibility to use everyday technology for virtual visits during the COVID-19 public health emergency. Privacy concerns in the Health Insurance Portability and Accountability Act (HIPAA) were relaxed due to lack of provider access during COVID. While many of the telehealth advantages are NOT expiring on May 11th, 2023, several will be phasing out before the end of the year.

Telehealth advantages weren’t just for patients but employees and doctors too, helping them fill their schedules at a time when patients couldn’t or wouldn’t come in themselves. Concessions made during a PHE will no longer be allowed, what will remain as law around HIPAA and telehealth is still being made clear.

Keep in mind:

Your employees may not have access to the same telehealth benefits when seeking treatment for COVID-19 post-PHE
Your patients may not have access to the same telehealth benefits when seeking treatment or advice for medical and dental emergencies
Your doctors and practitioners may have new and changing regulations around protecting patient privacy in the wake of the PHE ending, with some HIPAA concessions no longer applicable

HHS.gov:
The vast majority of current Medicare telehealth flexibilities that people with Medicare—particularly those in rural areas and others who struggle to find access to care—have come to rely upon throughout the COVID-19 PHE, will remain in place through December 2024. Additionally, states already have significant flexibility with respect to covering and paying for Medicaid services delivered via telehealth. This flexibility was available prior to the COVID-19 PHE and will continue to be available after the COVID-19 PHE ends.

Now that data tracking will be scaled back, there’s less visibility into local risk for COVID contraction. Mild infections were already difficult to track because they were treated with at-home Covid tests that are not reported to the CDC or the states.

The average number of weekly cases fell steadily since early January, 2023. Moving forward, hospitalized COVID patients will be the main indicator of trends, including visits to emergency departments that result in COVID diagnoses.

A reasonable conclusion reached is that local areas will only know that COVID has spiked after many of the residents have been exposed.

Continuing the enhanced precautions of the pandemic will not only help guard against COVID-19 but also against other respiratory viruses, especially as influenza and respiratory syncytial virus (RSV) rates have spiked lately.

In order to receive all their federal funding, Medicaid was required to cover everyone during the PHE. Now, an estimated 5 million to 14 million people will lose Medicaid coverage during the unwinding of the continuous enrollment provision.

Practices still have COVID outbreaks within their teams and patients, leading to serious disruptions, even with small scale spreads (because it doesn’t take much to hamper production). Absences due to family illness prove it only takes a single family member getting COVID to affect practice performance.

About 3% of American adults are, to some degree, immunocompromised and at risk of hospitalization when hit with COVID.

Medicaid rollbacks may impact infection rates, testing rates, access to vaccines and more. Leaving your patients at risk for exposure, and therefore your team at risk for exposure. From staffing to sick leave, this could create an HR nightmare for your practice.

COVID or a situation like it will become an HR nightmare once again, likely within your working lifetime, so it’s important to stay up to date and be ready… instead of being completely overwhelmed like in 2020. Keeping your practice handbooks compliant, policies automatically up to date, and sick-time tracked correctly can all be done for you with HR for Health.

Dental benefits at risk as Medicaid re-eligibility checks begin
Lots of people were able to enroll in Medcaid during the pandemic, giving them access to healthcare and dental care that may not have been otherwise available to them. As states start to re-examine their coverage policy moving forward, 5-14 million Americans will have changing coverage that could impact their ability to seek proper care.

"There's a big concern, though, because millions of people currently have Medicaid coverage, and if they don't complete these forms, they could lose that coverage and not even realize it," Dr. Renuka Tipirneni from the University of Michigan said.

She says lots of people enrolled for Medicaid for the first time during the pandemic and those already enrolled haven't needed to complete annual paperwork. But now that's changing.

"If they don't follow through with completing the new paperwork this year, they could lose Medicaid coverage," Tipirneni said. "That's hundreds of thousands of people in Michigan." WXYZ.com

The cleanliness that kept disease down during peak COVID still benefits your practice by reducing the spread of all types of pathogens. Preventing the spread of viral infections has always been part of every healthcare practice’s protocol. That is more important than ever!

Keep yourself, your team and your patients healthy by continuing to:

Stop the everyday spread with hand sanitizer readily available for your team
Wear N95, KN94 or KF94 masks during treatment, and consider wearing them at other times when your team members could be exposed to pathogens
Promote air quality and utilize air handling systems that reduce teh spread of pathogens.

How to transition your practice out of the COVID-19 public health emergency

Important questions to ask yourself…

1. Communicate with your team and ensure your handbooks and policies are up-to-date with changing laws and regulations

2. Ensure access to COVID testing for employees

3. Be aware of changing rules around telehealth and teledentistry

4. Practice extra precaution because there won’t be mild infection warnings

5. Medicaid Continuous Enrollment Provisions are unwinding

6. Basic prevention never goes out of style, or effectiveness