The Biden Administration recently announced its intention to end both the COVID-19 pandemic national emergency period and the public health emergency on May 11, 2023.
We’re finally putting the COVID-19 pandemic behind us, great news, right?
Not so fast. The end of the national emergency period and the public health emergency trigger a return to pre-pandemic requirements that may have unintended consequences for employer-sponsored health insurance plans and individuals.
The end of the national health emergency causes the federal government to reinstate requirements that existed prior to the pandemic, most notably the requirement for states to verify the eligibility of Medicaid recipients.
Beginning in April 2023, states are required to verify Medicaid eligibility for all enrollees. Those no longer eligible will lose their benefits, requiring them to seek coverage elsewhere, either through an employer-sponsored health insurance plan or an individual policy.
In Maryland alone, it is estimated that 80,000 residents will lose Medicaid coverage over the next 16 months. Employers may want to prepare for a possible influx of enrollment requests due to the Qualifying Event.
First Dollar Coverage of COVID Vaccines and Testing
Access to no cost at-home COVID test kits and COVID vaccinations may be eliminated due to the end of the public health emergency. Although it will no longer be mandatory, group health plan sponsors and insurance companies may elect to continue providing no cost tests and vaccines.
The public health emergency allowed for the suspension of certain telehealth prescribing requirements to grant greater access to healthcare services. The end of the public health emergency may bring about changes to telehealth services.
COBRA Election Deadlines
The federal health emergency suspended the 60-day election period for COBRA continuation, extending the election period to the end of the outbreak period. COBRA election periods return to pre-pandemic levels at the conclusion of the health emergency.
Assuming the Administration adheres to the May 11th date, and we end the national health emergency period and public health emergency, we should expect federal officials, state governments, plan sponsors and insurance companies work to address any disruptions associated with the return to “normal”.
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