Could the COVID National Emergency End? 4 Things to Keep in Mind

Is the COVID National Emergency Ending? 4 Things to Keep in Mind.

The latest COVID-19 National Emergency period is set to end on February 28, 2023. If it’s not extended again, employer-sponsored health plans may need to adjust. Here are some quick reminders of what your plan needs to keep doing, what you can stop, new opportunities you might be missing and ideas on preparing for the post-emergency period.

1. What’s no longer required

Subsidized COBRA premiums and mandatory paid leave for COVID-related absences ended on December 31, 2020.

Plans are no longer required to cover telehealth visits with no deductible for HSA-qualified HDHP participants. That provision expired on December 31, 2021. They are, however, allowed to do so through 2023.

The loosened deadlines for changing elections offered through a cafeteria plan also have expired.

2. What’s still required

More generous deadlines for electing and paying for COBRA have been extended. Employees can still elect COBRA coverage up to a year after a COBRA-qualifying event and pay for it up to 60 days after the National Emergency is over.

Employees are also still allowed up to a year to elect health coverage under the HIPAA special enrollment rules, or until 60 days after the National Emergency ends, if sooner. That will be April 29, 2023, if the National Emergency expires in February as expected. NOTE: Surprisingly, there aren’t any specific requirements for employers to inform employees of the extensions to the COBRA deadlines or HIPAA special enrollment periods.

Health plans are still required to provide COVID test kits and testing for free – up to eight tests per covered individual per month – even for HSA-eligible HDHPs.

3. Additional options for HDHPs

Inspired in part by challenges in obtaining health services during the pandemic, the government has softened the rules about the medications and services HSA-qualified HDHPs are allowed to cover as preventive services.

Are you missing out on this opportunity? If you offer an HDHP, it can now cover the following at 100%, with no deductible:

• Anti-resorptive therapy for osteoporosis and osteopenia
• Beta blockers for congestive heart failure and coronary artery disease
• LDL testing for heart disease
• Blood pressure monitors for hypertension
• Insulin, A1C testing, retinopathy screening and glucometers for diabetes
• Inhaled corticosteroids and peak flow meters for asthma
• INR testing for liver disease and bleeding disorders

Just a few things to consider before adopting these changes for your HDHP:

1. While a few of these allowances (such as diabetes products and services) have been made permanent, others could be overridden by future administrations.
2. If you add preventive services to your HDHP, make sure to also cover them under your other plans, such as a PPO.
3. Adding coverage for the new preventive services could result in rate increases. You will want to assess whether those are justified by the improved coverage.
4. To minimize costs, some carriers restrict coverage to certain brands or vendors.

4. Preparing for changes post-pandemic

Once the National Emergency ends, employers will no longer be required to cover COVID-19 testing and related services or vaccinations from out-of-network providers without cost sharing. You’ll need to consider whether you want to continue this coverage.

You will be required to continue covering in-network COVID-19 vaccinations with no cost sharing as preventive care.

Depending on what you’ve communicated thus far, you may want or need to update employees on:

• Testing coverage
• Vaccination coverage
• Deadlines approaching for notifications, applications and payment for COBRA
• Deadlines for requesting HIPAA special enrollment