The Impact of the End of the COVID-19 National Emergency on Health Plans
As the COVID-19 national emergency came to an end on April 10, 2023 [5], significant changes to health plans have started to take place. This comprehensive article looks into the various implications with the end of the national emergency on health coverage, addressing matters such as COBRA, employee benefits, vaccination coverage, and more.
COBRA Deadlines and Flexibility
During the national emergency (NE), the Consolidate
d Omnibus Budget Reconciliation Act (COBRA) allowed for more flexible deadlines for both employers and employees [1]. With the end of the NE and the subsequent conclusion of the outbreak period, these deadlines are expected to revert to their pre-pandemic norms, returning normalcy to employers.
COBRA and the Outbreak Period
The outbreak period relief, which extended deadlines for claims and appeals, will end on July 10, 2023, as informally commented by the Department of Labor (DOL) [5]. Employers and employees should be aware of these adjustments and prepare accordingly for the changes that will take effect after this date.
Changes to Employee Benefit Plans
In March 2023, the Department of Labor, Health and Human Services, and the Treasury released new Frequently Asked Questions (FAQs) to address specific deadlines and regulations [3]. These are comprehensive and should serve as a general guide to navigate the changes to benefits plans and answer any immediate questions you may have.
Preparing for the End of the Outbreak Period
It is crucial for employers to review and update their benefit plans in compliance with the new regulations, ensuring a smooth transition for their employees during this period. Falling out of compliance, or being unclear about deadlines for new changes to take effect, can lead to noncompliance and missed opportunities for your business and employees alike.
Implications for Health Coverage
The end of the COVID-19 public health emergency and national emergency will bring about changes that may impact health coverage [6]. Some of the changes employers and employees should be aware of include:
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- COVID-19 diagnostic testing
- COVID-19 vaccinations
- Deadlines for key health benefit decisions
- Medicaid and CHIP coverage
Vaccine Coverage
Non-grandfathered group health plans are required to cover COVID-19 vaccines (including booster doses) without cost-sharing, prior authorization, or other medical management requirements during the public health emergency [9]. After the emergency declarations end, it remains to be seen how these coverage requirements may change.
Conclusion
As the world approaches a return to pre-pandemic policy, employers must adapt their health plans and employee benefit schemes to comply with the ‘new’ regulations accordingly.
