Public Health Emergency Over?

What’s next for Medicaid and local hospitals

By Craig Manning

January 31 marked three years since Alex Azar, then-secretary of the United States Department of Health and Human Services (HHS), officially declared COVID-19 a nationwide Public Health Emergency (PHE).

Thirty-six months and 12 renewals later, that federal PHE designation remains in place, though many healthcare experts predict it will lift this spring.

The expiration of the PHE declaration would represent a major milestone in moving on from the pandemic. But it also impacts health insurance coverage, hospital operations and more.

A PHE is a mechanism allowed by the Public Health Services Act, wherein a sitting HHS secretary can take emergency actions to combat a public health risk. For instance, it was because of the PHE that the FDA was able to grant Emergency Use Authorizations for several COVID-19 vaccinations, before those vaccines received official FDA approval.

A PHE declaration lasts 90 days, though the designation can be extended by the HHS secretary following consultations with public health officials. So far, HHS has renewed the COVID-19 PHE every three months since January 2020.

Most recently, on Jan. 11, current HHS Secretary Xavier Becarra extended the PHE for a 12th time, citing “the continued consequences of the COVID-19 pandemic.” Under this particular extension, the PHE will be in place until at least April 11.

Despite the renewal, chatter around ending the PHE has been growing louder. In December, 25 Republican governors sent a letter to President Biden asking the administration to end the PHE declaration.

In the letter, the undersigned argued that “the emergency phase of the pandemic is behind us” and that the PHE was “negatively affecting states, primarily by artificially growing our population covered under Medicaid, regardless of whether individuals continue to be eligible under the program.” This situation, the governors concluded, “is costing states hundreds of millions of dollars.”

According to Mi Stanley, corporate director of special projects and communication for Traverse Health Clinic, the PHE effectively paused Medicaid redeterminations during the pandemic to prevent loss of health coverage. In other words, while new Medicaid enrollments have continued, disenrollments have ceased –which in turn has meant an ever-growing number of Medicaid enrollees.

With or without the PHE, Medicaid is now due for a shakeup. In December, Congress passed an omnibus spending bill that decoupled the Medicaid continuous eligibility policy from the PHE.

“Basically, throughout the PHE, states were not going through the process of redeterminations for beneficiaries of Medicaid,” Stanley said. “But with the budget bill that was recently passed, Congress decided that – whether or not the PHE continues to get extended – starting on some could lose coverage when redeterminations kick back into play. Some analysts expect that, statewide, some 400,000 people could lose coverage due to the reactivation of the review process.

“We could end up with, at least for some period of time, an increase in the percentage of patients that we see who are uninsured,” Stanley said. “As a community health center, we never turn anyone away for inability to pay or for being uninsured, and that would continue to be the case. But we also know that, when people don’t have health insurance coverage, they’re less likely to seek out preventive care.”

Stanley said that the clinic’s services will continue to be free, even if it’s just to outdoors, in their cars or in tented areas, rather than inside the hospital proper. According to Gabe Schneider, who acts as director of government relations for Munson Healthcare, most of those waivers are no longer in use.

“In the Munson system, our COVID-19 hospitalizations have largely stabilized, which means we’re not relying much on those waivers provided by the PHE,” Schneider explained.

The PHE waivers that Munson is still using, Schneider added, mostly pertain to telehealth. The PHE gave providers much more leeway in the digital delivery of care, which Schneider said has been a huge boon to rural hospital systems.

April 1, states have to begin the redetermination process for Medicaid.”

Stanley said that for the first time in a couple of years, people are going to be required to update their information.

“There are probably people who are currently on Medicaid who have never been through this process, because they got it during the PHE,” she said.

Per Stanley, Traverse Health Clinic is currently making “a big push” to inform patients of the impending end to the continuous enrollment policy, and assist them in updating their information with the state.

Nearly 50% of Traverse Health Clinic patients are Medicaid enrollees, and

ask about Medicaid eligibility.

“Anyone can call and ask for an appointment with our eligibility specialists, who can walk them through the application process to reapply or apply for Medicaid, or to apply for a Marketplace plan,” she said.

In addition to continuous Medicaid coverage, the PHE also created a laundry list of waivers that, during the worst of the pandemic, helped hospitals deliver care by whatever means necessary.

One waiver allowed hospital systems like Munson Healthcare to bring in traveling nurses that were licensed in other states. Another permitted hospitals to screen emergency department patients

Those flexibilities were actually uncoupled from the PHE as well, with the aforementioned Congress omnibus spending bill extending “some of the more important telehealth flexibilities” to 2024. Munson Healthcare, which in 2022 “completed nearly 80,000 video visits,” per Schneider, is grateful for the extension.

“About 10% of our visits across our eight hospitals continue to be completed by video,” Schneider said. “That includes 68% of our visits for sleep disorders, 66% of our visits for behavioral health, and 56% of our visits for infectious disease.”

Schneider said that the PHE flexibility has had a big impact on Munson’s ability to deliver care in a rural area.

“So, we’re glad to see those flexibilities extended to 2024, and it’s going to be on our radar to push Congress to permanently eliminate those telehealth restrictions in the future,” he said.