On April 10, 2023, President Joe Biden signed a bipartisan congressional resolution to end the COVID-19 National Emergency after three years. The national emergency was tied to the extension of many deadlines related to employee benefits including COBRA, special enrollment, and claims and appeals, just to name a few. The Public Health Emergency (PHE), which expires on May 10, 2023, was tied to coverage mandates including no-cost COVID tests, free-at-home COVID tests and no-cost COVID vaccines.  

Many employers have questions about the impact of the end of these orders. The U.S. Department of Labor (DOL), U.S. Department of Health and Human Services (HHS) and the U.S. Department of the Treasury issued frequently asked questions (FAQs) guidance to assist employers in preparing for the end of these orders.  

Throughout the last three years, there have been many policy changes, extensions or temporary removal of deadlines, and changes on how to administer employer health benefits plans. While plan sponsors may welcome this end, there are some challenges you need to consider.  

Upcoming Challenges 

The PHE-required health insurance plans fully cover COVID-19 testing without employee cost sharing, both in and out of network. Now that the PHE is ending, medical plans, including employer-sponsored plans, will no longer be required to pay for testing. Employers will need to decide how they want to proceed. That goes for vaccines as well. Employers ultimately must decide not only what to do in terms of all COVID-19-related coverage, but when to roll those changes out to employees. Will the changes be effective immediately on the currently offered plans or will the changes wait until the new calendar year? 

The end of the PHE will also mark a couple of changes to health plan enrollment. One change is to Medicaid. Enrollment in the government health care program has soared in the past three years. COVID-19 rules barred states from kicking people off Medicaid during the public emergency. When the emergency ends, millions of people currently on Medicaid are expected to no longer qualify and will be removed from the program—which means some of them will likely join their employers’ health benefit plans. In addition to new enrollment, this could also increase claims and the cost of premiums of your company’s plan. COBRA extensions will also end, reversing to the pre-pandemic deadline of a 60-day election period.  

Another change employers need to be aware of is the extended time for special enrollment. During the national emergency, employees had up to a year to enroll in their employer’s health plan after a qualifying special enrollment event. Historically, employees had only 30 days to enroll in a plan following a special enrollment event such as losing coverage, getting married or having children. The 30-day window will become effective once again.  

How to Prepare 

Employers need to do a few things in anticipation of the pandemic emergencies ending. Reviewing health plan terms for COVID-19-related coverage and reviewing benefit terms for your individual plan is a good first step. You will need to decide how your company will proceed in terms of COVID-19-related coverage and when to roll it out. Reaching out to your network of providers and third-party administrators to obtain guidance on best practices will be helpful as you navigate this new direction.  

Communication with your employees will be crucial here. Make sure you have a strategy on how you are going to communicate the end of the PHE and how it will affect them. Be sure they understand any cost changes will be especially important, as employees have become accustomed to COVID-19 tests and vaccines being covered at no cost. In addition, note the changes to the special enrollment periods.  

At DM Payroll Solutions, we offer our clients end-to-end solutions to manage their benefits administration. Streamlining these efforts with online tools and automation uncomplicates matters, and provides better oversight of your company’s benefit plans while making the process smoother for you and your employees. 

If you have any questions on how this will affect your payroll, do not hesitate to contact the team at DM Payroll Solutions.