After several years of renewing both the COVID national emergency and the COVID public health emergency (PHE) periods, we will see these come to an end on May 11, 2023. The ‘outbreak’ period will end 60 days later, on July 10. Under the CARES Act, health plans have been covering many services without imposing out of pocket or deductible costs. Come May, these cost waivers will expire and plans’ usual procedures for most COVID services will be imposed.

When the PHE ends, health plans will no longer be required to cover COVID-19 diagnostic tests and related services without cost sharing. Health plans will still be required to cover ‘preventive services’ without cost sharing, which now include COVID vaccines, when obtained at an in-network provider. Once the outbreak period ends, health plans will impose regularly applicable deadlines for purposes of HIPAA special enrollment, COBRA notification and payment deadlines, and claims and appeals procedures. 

The offering of telehealth services without requiring deductible satisfaction, while preserving HSA eligibility, was also a relief during the COVID period. This relief has been extended through 2024 by separate legislation, and will not come to an end with the PHE or outbreak period.

Employers should reach out to any employees or terminated individuals who might be overdue in COBRA premiums, or still in their extended election period to let them know about the upcoming expiration. Likewise it's a good idea to proactively communicate the in-network requirement for COVID vaccination and testing to avoid unexpected incurred costs on May arrives.