COVID-19 Public Health Emergency

The U.S. Department of Health and Human Services will end the COVID-19 public health emergency (PHE) May 11, 2023. The ending of the PHE will result in the elimination of several pandemic flexibilities, while others have been extended by Congress.

A key item of interest in Michigan is Medicaid redeterminations, which will begin April 1. The MHA continues to work with the Michigan Department of Health and Human Services and other partners on maintaining access to coverage for Michiganders, as Medicaid redetermination will impact many beneficiaries. Work is underway to educate Medicaid enrollees about the process to ensure as many enrollees as possible who remain eligible for coverage maintain that coverage with no interruptions.

Items that remain in place following the conclusion of the PHE include the major telehealth waivers and the Acute Hospital Care at Home individual waiver that was initiated during the PHE. All the waivers referenced are extended through 2024.

Members with questions should contact Kelsey Ostergren at the MHA.

Medicaid Redetermination

Due to a federal provision of the PHE known as Medicaid Eligibility Maintenance of Effort, states had to stop reviewing the eligibility of existing Medicaid beneficiaries on an annual basis for nearly all Medicaid enrollees while new beneficiaries continued to be added to state Medicaid rolls. As a result of this process suspension, Michigan has an additional 355,000 residents enrolled in traditional Medicaid and 367,000 additional Healthy Michigan Plan enrollees. The state will soon begin a rolling process of reviewing eligibility of all Medicaid beneficiaries as those individuals reach their renewal dates to determine if they still qualify for the program.

While many of these individuals still may be eligible for Medicaid, it is likely that a significant number of previously eligible people will no longer be eligible once their eligibility is redetermined, with the first group of people potentially losing Medicaid eligibility in July. The goal of the MHA and our partner stakeholder groups is to work with the Michigan Department of Health and Human Services (MDHHS) to ensure as many people as possible either maintain their Medicaid coverage or transition to an appropriate plan on the insurance exchange if they do not now have employer-sponsored coverage.

The MDHHS has created an initial set of tools and resources for providers and partners aimed at educating their patients about the need to ensure their contact information is updated, so they properly process their redetermination paperwork.

Members with questions about Medicaid redetermination should contact Ruthanne Sudderth at the MHA.

Resources for Hospitals

The MHA has compiled a series of resources from national organizations and federal departments for hospitals to help prepare for the ending of the COVID-19 PHE.

Important Information Sources

American Hospital Association: Public Health Emergency to End May 11 – Highlights key provisions that will expire because of the COVID-19 PHE ending, including associated dates.

Centers for Medicare & Medicaid Services (CMS): Coronavirus Waivers & Flexibilities – Provides a detailed list of all CMS waivers that will be expire with the ending of the COVID-19 PHE, unless otherwise noted. Information on Michigan-specific waivers, by waiver type, are also available.:

• Section 1115 waiver.
• Section 1915(c) waiver.
• Section 1135 waivers – The CMS and the U.S. Department of Health and Human Services (HHS) issued several nationwide Medicare “blanket” waivers as part of the PHE, in addition to issuing state-specific waivers on an individual basis.

CMS Provider Specific Fact Sheets – Fact sheets include information about the waivers and flexibilities which have been terminated, made permanent or will expire at the end of the PHE, and are specific to each provider type.

• Hospice.
• Hospitals and Critical Access Hospitals, Ambulatory Surgical Centers and Community Mental Health Centers.
• Inpatient Rehabilitation Facilities.
• Laboratories.
• Long Term Care Facilities (Skilled Nursing Facilities and/or Nursing Facilities).
• Physicians and Other Clinicians.
• Rural Health Clinics & Federally Qualified Health Centers.
• Teaching Hospitals, Teaching Physicians and Medical Residents.

CMS Waivers, Flexibilities and the Transition Forward from the COVID-19 Public Health Emergency; What do I need to Know? – This Fact Sheet discusses how the end of the PHE will impact COVID-19 vaccines, testing, treatment, telehealth, blanket waivers, scope of practice, virtual supervision and more.

HHS: Fact Sheet, COVID-19 Public Health Emergency Transition Roadmap – Details flexibilities that will and will not be affected by the PHE ending, including access to vaccination and treatment, testing, emergency use authorizations for COVID-19 products, telehealth and treatment of opioid use disorder.

Kaiser Family Foundation: What Happens When COVID-19 Emergency Declarations End? Implications for Coverage, Costs, and Access – A detailed overview of the major health-related COVID-19 federal emergency declarations that were made and when they expire in relation to the end of the PHE.

Kaiser Family Foundation: Medicaid Emergency Authority Tracker – Lists all PHE-related waivers, by waiver type.

Medicaid Federal Disaster Resources – Lists state-specific 1135 waivers.

Medicaid Benefit Changes Resources – Tools and resources to educate patients about the need to ensure their contact information is updated for redetermination paperwork.

Michigan Department of Health and Human Services (MDHHS) Medicaid Provider Manual (MMP 23-14) – Details the updates made to the Michigan Medicaid Provider Manual in response to the PHE ending.

MDHHS PHE Unwind COVID-19 Policy Crosswalk – Provides an overview of the policies enacted during the PHE which are being terminated as the PHE expires; connecting the initial Medicaid COVID-19 response bulletins issued with the L letters that change/impact the guidance.