The PHE Has Officially Ended- Now What?

After numerous extensions by way of The Department of Health and Human Services (HHS) since 2020, the Public Health Emergency (PHE) has finally expired. Employers will recall that back in 2020 after the passage of The CARES Act, health plans were mandated to cover many COVID related services, such as testing, home test kits, and vaccinations without imposition of any out of pocket costs to participants. As of May 11th, these requirements no longer apply to employer health plans. So what does this mean?

Insurance carriers have updated their plan documents to outline the new COVID related service features of their employer sponsored plans, and many have made these updates available on their websites for participant access. Employers should consider supplementing this with direct employee communications detailing the specific changes they can expect to see as of May 12, 2023.

The major changes that impact employees and their dependents are as follows:

• No insurance coverage for over the counter (OTC) COVID test kits (FSA, HRA and HSA funds may be used)

• No cost share for COVID testing when administered In-Network only

• No cost share for COVID vaccines when received In-Network only

As of June 9, the ‘outbreak’ period will also come to an end. Most notably, this means there will no longer be any extensions for participants to enroll in COBRA, or to make their COBRA premium payments. Once an individual is terminated from COBRA for nonpayment, there will not be any opportunity to re-enroll.

The end of the PHE is a welcome sign and employers are in a unique position to help their employees navigate the changes with positive communications.