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 Michigan Department of Health and Human Services (MDHHS) began mailing beneficiary alert letters March 2, 2023, to notify beneficiaries that an eligibility renewal packet will be sent soon. Per federal legislation, Michigan will restart Medicaid eligibility renewals for both fee-for-service Medicaid and Medicaid Health Plan (MHP) beneficiaries effective April 1, 2023. The MDHHS plans to continue to mail the beneficiary alert letters each month to additional groups of beneficiaries until February 2, 2024.

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 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. Providers will want to continue to verify beneficiary eligibility prior to services. It is important Medicaid Beneficiaries update their contact information in MI Bridges to ensure they receive information about the redetermination process and changes in coverage.

The MHA, in partnership with the Michigan Primary Care Association, Michigan Association of Health Plans, Michigan State Medical Society and Michigan Osteopathic Association, hosted a member webinar March 20 to cover the Medicaid eligibility redetermination process, timelines and provider roles. A recording of this webinar is available.

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

Telemedicine Flexibilities

The following telehealth flexibilities will permanently remain in place in Michigan:

• Per Michigan Medicaid policy (MMP 23-10), telemedicine reimbursement rate will be the equivalent to the in-person reimbursement rate.
• No prior authorization (PA) required when providing telemedicine services, unless the equivalent in-person service requires a PA.

The following telehealth flexibilities are extended through Dec. 31, 2024 under federal law:

• Medicare beneficiaries can access telehealth services in any geographic area.
• Medicare beneficiaries can stay in their homes for telehealth visits.
• Certain telehealth visits may be delivered through audio-only technology.

COVID-19 Flexibilities and Waivers

• Most Blanket waivers in effect to prevent gaps in care will expire at the end of the PHE.
• The 20% increase in Medicare payment rate for hospitals treating patients with COVID-19 will expire at the end of the PHE.
• Emergency waivers for nurse aid training will expire at the end of the PHE, at which time facilities have four months to have all nurse aides complete a state-approved training program.
• Reinstating the three-day prior hospitalization admission requirement for skilled nursing facilities.
• The Acute Hospital Care at Home initiative has been extended through Dec. 31, 2024.

COVID-19 Vaccines, Testing and Treatment

• Uninsured: Upon expiration of the PHE, tests, vaccines and treatments will no longer be provided cost-free. Once the federal supply is depleted, individuals will need to pay for tests.
• Medicare: Upon expiration of the PHE, vaccines will remain covered. Cost sharing requirements will be reinstated for tests, testing-related services and most treatments.
• Medicaid: Upon expiration of the PHE, vaccines will remain covered. Testing and treatments will remain covered but will be subject to cost-sharing one year after the PHE ends.
• Privately insured: Upon expiration of the PHE, vaccines will remain covered. Tests, testing-related services and most treatments will be subject to cost sharing.

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 Guidance for the Expiration of the COVID-19 Public Health Emergency (PHE) – This memorandum outlines the regulatory requirements set to be reinstated when the PHE ends.

CMS PHE FAQs – This list of frequently asked questions from the CMS covers the waivers and flexibilities that will be impacted by the ending of the PHE. It discusses upcoming changes to Medicare, Medicaid, the Children’s Health Insurance Program and private insurance coverage, as well as general FAQs which are relevant to all programs.

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 Policy Navigation Video Resources – The MDHHS created short videos to help providers and community partners navigate changes to eligibility for Medicaid and Food Assistance benefits, the PHE Unwind Policy Crosswalk resource and the MDHHS Stakeholder Toolkit.

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.

MHA End of the Public Health Emergency Resource Document (April 2023) – Highlights key pandemic flexibilities that will end upon conclusion of the PHE including Medicaid Redetermination, telemedicine flexibilities, COVID-19 vaccines, testing and treatments and other COVID-19 waivers.

MHA Hospital Association Reporting Portal (HARP): Medicaid Federal Match Rate Transition Template – This template assists hospitals in estimating the quality assurance assessment program (QAAP) tax increase for fiscal year 2023 due to the Medicaid federal match rate declining from the enhanced rate to the regular rate beginning April 1, 2023, which phases out the QAAP tax discount that had been in place since early 2020.

MHA Webinar – Michigan Medicaid Redetermination: Information for Medicaid Provider Health Centers, Hospitals and Stakeholders on 3.20.2023 – This webinar recording covers the Medicaid eligibility redetermination process, timelines and provider roles.

U.S. Food and Drug Administration FAQs: What happens to EUAs when a public health emergency ends? – Frequently asked questions regarding Emergency Use Authorizations (EUAs) granted during the COVID-19 PHE that highlight the impact of the PHE ending on currently available EUAs.