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Guide to COVID-19 Coverage and the End of the Public Health Emergency and National Emergency

On January 30, 2023, the Biden Administration informed Congress that it intends to end both the public health emergency (PHE) and national emergency declarations (NE) for COVID-19 on May 11, 2023.

The Administration also released a Fact Sheet detailing the government’s COVID-19 Public Health Emergency Transition Roadmap. This document details various provisions tied to the expiration of the PHE and those the Administration is seeking to extend or make permanent.

This information is intended to help you better understand the implications to ending the PHE and NE emergency declarations, including the expiration of various federal government flexibilities and legislative requirements affecting the health insurance market.

  • On May 11, 2023, the requirement for private insurance companies to cover COVID-19 tests without cost sharing, both for over the counter (OTC) and laboratory tests, will end. Consumers will incur additional out-of-pocket costs for COVID-19 testing-related services, including cost-sharing and costs associated with out-of-network services.
  • Additionally, the requirement for health insurance providers to cover eight (8) over the counter COVID-19 tests per covered individual per month will expire on May 11, 2023.
  • Dependent on supply and resources, the United States Government may continue to distribute free COVID-19 tests from the Strategic National Stockpile through the United States Postal Service, states, and other community partners. Pending resource availability, the Centers for Disease Control and Prevention’s (CDC) Increasing Community Access to Testing (ICATT) program will continue working to ensure continued equitable access to testing for uninsured individuals and areas of high social vulnerability through pharmacies and community-based sites.

  • The requirement for issuers to provide COVID-19 diagnostic items and services within cost-share (ie. deductibles, copayments, coinsurance, prior authorization, or other medical management requirements) will expire on May 11, 2023.
  • Note: Plans will continue to have the option to provide coverage of COVID-19 treatments without cost-sharing in high deductible health plans (HDHPs). For plans that adopted this flexibility, consumers will incur additional out-of-pocket costs for COVID-19-related services, including deductible costs.
  • The requirement for issuers to reimburse a provider that has a negotiated rate with the plan or issuer for COVID-19 diagnostic testing an amount that equals that negotiated rate; or, if the plan or issuer does not have a negotiated rate with such provider, the cash price for such service that is listed by the provider on a public website will expire on May 11, 2023.
  • Coverage of COVID-19 testing and vaccines without cost-share will expire on May 11, 2023. Consumers will incur additional out-of-pocket costs for COVID-19-related services, including cost sharing and deductible costs.

Provisions related to Telehealth and Telemedicine that are set to expire:

  • Group health plans may offer telehealth access as a premium, tax-free benefit separate from other health plans.
  • Telehealth services may come at a higher cost in plan year 2024. Telehealth services in HDHPs may come at a higher cost in plan year 2025.
  • Temporary enforcement relief that allowed plans and issuers to make changes to coverage to increase benefits, or reduce or eliminate cost sharing, for the diagnosis and treatment of COVID-19 or for telehealth and other remote care services more quickly than they would otherwise be able to under current law are set to expire on May 11, 2023. Consumers may incur mid-year plan benefit changes as the PHE expires

Provisions related to Opioid Use Disorder (OUD):

  • Access to buprenorphine for opioid use disorder treatment in Opioid Treatment Programs (OTPs) will not be affected. Early in the COVID-19 pandemic, the Substance Abuse and Mental Health Services Administration (SAMHSA) released guidance allowing patients to start buprenorphine in an OTP by telehealth without the required in-person physical examination first. This flexibility will be made permanent.
  • Access to expanded methadone take-home doses for opioid use disorder treatment will not be affected. This flexibility will be expanded for one year from the end of the COVID-19 PHE, which will be May 11, 2024, to allow time for the agency to make these flexibilities permanent.

PDF icon March 29, 2023 | Compliance eBlast - End of the COVID-19 Public Health Emergency and National Emergency

PDF icon March 28, 2022 | Compliance eBlast - Temporary Waiver to Deductible for Telehealth Service for HSA-QHDHP

PDF icon January 21, 2022 | Compliance Alert - Over The Counter COVID Tests

PDF icon January 14, 2022 | Compliance eBlast - Over The Counter COVID Tests

PDF icon June 24, 2021 | Compliance eBlast - COVID-19 Waiver of Cost Share Update

PDF icon April 29, 2021 | Compliance FAQ - COBRA Subsidy 2021 FAQ

PDF icon April 21, 2021 |  Compliance eBlast - Personal Protective Equipment (PPE) to protect against COVID-19

PDF icon March 26, 2021 | Compliance Bulletin - 2021 American Rescue Plan Act COBRA Subsidy Deadlines for COBRA Actions under the CARES Act (updated March 31, 2021)

PDF icon January 14, 2021 | Compliance Alert - New Options for Medical Care Reimbursement and Dependent Care Reimbursement Accounts

PDF icon December 17, 2020 | Updated Frequently Asked Questions for HPI Brokers and Clients

PDF icon May 28, 2020 | Compliance Bulletin: Optional Plan Changes Permitted under Newly Issued IRS Guidance

PDF icon May 28, 2020 | Optional Plan Changes Checklist

May 28, 2020 | Sample Attestation Required for Dropping Medical Coverage

PDF icon May 11, 2020 | Compliance Alert - Pandemic-Related Deadline Extensions

PDF icon April 14, 2020 | We're here to support you | A message to our valued brokers

PDF icon April 8, 2020 | Frequently Asked Questions for HPI Brokers and Clients

PDF icon April 3, 2020 | Compliance Alert - COVID-19 Update

PDF icon March 26, 2020 | Revised Compliance Alert - The Families First Coronavirus Response Act (this replaces the Alert distributed on March 24, 2020)

PDF icon March 17, 2020 | Mandated Telehealth Coverage

PDF icon March 11, 2020 | Important Information About Coronavirus

Provisions related to COBRA:

Certain extensions for timeframes affecting COBRA continuation coverage will reset on July 10, 2023 (60 days after the end of the COVID-19 National Emergency that ends on May 11, 2023). Regular deadlines will resume mid-year for the following submission deadlines:

  • Electing COBRA coverage
  • Making COBRA premium payments
  • Notifying the Plan of second qualifying events under COBRA

Additionally, effective July 10, 2023, certain pre-COVID-19 submissions timeframes will be reinstated for the following:

  • Filing medical, dental, vision, Medical Care Reimbursement Account (i.e. health FSA), and disability claims for covered benefits/eligible expenses
  • Appealing denials of medical, dental, MCRA and disability claims
  • Making a Special Enrollment Request under HIPAA rules for medical or dental coverage

Benefits and coverage questions:
Contact the phone number listed on the back of your Member ID Card, or call:

Monday through Friday, 8am to 5pm (ET)


COVID-19 -specific questions:
Monday through Friday, 8am to 5pm (ET)

If you are not feeling well, please contact your primary care provider to discuss active symptoms.

© 2024 Health Plans, Inc.

Health Plans, Inc. is a Harvard Pilgrim company

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