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HHS’s Middle for Medicare & Medicaid Companies (CMS) has issued a reality sheet addressing the top of the COVID-19 public well being emergency (PHE), which (together with the COVID-19 nationwide emergency) is anticipated to finish on Might 11, 2023 (see our Checkpoint article). The actual fact sheet, which is addressed to people, confirms that HHS is anticipating the PHE to run out on the finish of the day on Might 11 and gives details about the implications for protection underneath personal medical health insurance, in addition to Medicare, Medicaid, and CHIP. Listed below are highlights related to employer-sponsored group well being plans:
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COVID-19 Vaccines, Testing, and Remedies. Most plans should proceed to cowl vaccines furnished by in-network suppliers with out value sharing however might require people receiving vaccines from out-of-network suppliers to share a part of the fee. [EBIA Comment: For non-grandfathered plans, in-network COVID-19 vaccines without cost sharing will continue to be required under the Affordable Care Act’s preventive services coverage mandate.] When the PHE ends, obligatory protection for OTC and laboratory-based COVID-19 PCR and antigen exams will finish. Plans might select to cowl these exams however might require value sharing, prior authorization, or different types of medical administration. The tip of the PHE won’t change how COVID-19 remedies are coated; plans that require value sharing or apply deductibles might proceed to take action.
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Entry to Telehealth Companies. As is presently the case throughout the PHE, protection for telehealth and different distant care companies might range from plan to plan after the PHE ends. When coated, plans might impose cost-sharing, prior authorization, or different types of medical administration.
EBIA Remark: Whereas the very fact sheet specifies implications for personal medical health insurance, the listed objects are additionally related to self-insured plans. The actual fact sheet notes that the businesses will proceed to offer steering within the coming months. Group well being plan sponsors ought to particularly be looking out for steering concerning the top of the COVID-19 nationwide emergency, which is able to set off the 60-day countdown to the top of the outbreak interval and the top of the tolling interval for a lot of plan-related deadlines (see our Checkpoint article). For extra data, see EBIA’s Group Well being Plan Mandates guide at Part XVI.C (“COVID-19: Mandated Protection of Diagnostic and Preventive Companies”) and EBIA’s Self-Insured Well being Plans guide at Part XIII.C.11 (“Protection Mandates Regarding the COVID-19 Pandemic”), which will likely be up to date for steering.
Contributing Editors: EBIA Employees.
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