How the end of the public health emergency (PHE) affected your health coverage

The public health emergency (PHE) was first declared in January 2020, and was extended in 90-day increments for more than three years. The PHE ended on May 11, 2023. Various laws and regulations related to health coverage were tied to the PHE.

The national emergency was first declared in March 2020, and extended in one-year increments in 2021 and 2022. It ended on April 10, 2023. During the national emergency, deadlines related to COBRA and special enrollment periods for employer-sponsored health plans were extended, but those flexibilities ended on July 10, 2023 (60 days after the originally-scheduled end of the national emergency).

There are several things that people with marketplace plans need to be aware of in terms of COVID-related coverage after the end of the PHE:

• Although recommended vaccines, including COVID vaccines, continue to be covered with no out-of-pocket costs, this is generally only the case if you obtain your vaccine from an in-network pharmacy or medical provider. During the PHE, your plan covered COVID vaccines even if you didn’t use an in-network provider. But now that the PHE is over, your plan can require you to stay in-network for the shots to be covered.
• Your plan has likely continued to cover in-office PCR COVID testing, just as they cover laboratory testing for other illnesses. But you’ll probably need to stay in-network for your test, and your plan may require you to have an order from your doctor for the test. You should also expect to pay regular cost-sharing (copay, deductible, coinsurance) for the office visit and the lab work.
• Your plan no longer has to cover at-home COVID tests. Your plan may or may not continue to offer some benefit for at-home COVID tests, but they are not required to do so. These tests are obtained over-the-counter, so you may find that you simply have to pay for them in full, as is the case with most other over-the-counter medical supplies. The government will send you up to four tests, as long as supplies last. If you have access to HSA or FSA funds, you can use that pre-tax money to purchase at-home COVID tests.
• Nothing has changed about how overall COVID treatment is covered. If you get COVID and need medical care, you’ll have to pay your plan’s regular cost-sharing (deductible, copays, coinsurance) for any treatment you need. Make sure you understand your plan’s requirements for things like prior authorization and using in-network medical providers.
• If you have a catastrophic plan, it’s possible that it offered pre-deductible telehealth coverage during the pandemic, but that flexibility ended with the PHE. Catastrophic plans are again limited to only covering up to three primary care visits and preventive care before the deductible is met.
• If you have an HSA-qualified plan, it may have offered pre-deductible telehealth benefits (this was optional for the plans). That can continue through the end of 2024, and did not have to end with the PHE.

The end of the PHE did not have an immediate impact on the COVID-related coverage that people receive via Medicaid:

• COVID vaccines continue to be covered with no cost-sharing.
• After September 30, 2024, states no longer have to cover COVID vaccines for limited benefit enrollees (but they do have to continue to fully cover the cost of COVID vaccines for full-coverage enrollees). Enrollees with limited-benefit Medicaid include, for example, those eligible only for family planning services, or only for tuberculosis-related services.
• Testing (including at-home tests) and treatment for COVID will continue to be covered with no cost-sharing until September 30, 2024 (through the end of the calendar quarter that begins one year after the PHE ends).

During the pandemic, states were not allowed to disenroll anyone from Medicaid, even if they no longer met the eligibility requirements. That rule was initially scheduled to continue through the end of the PHE, but the 2023 Consolidated Appropriations Act set an end date of March 31, 2023.

States resumed disenrollments after that, and millions of people have been disenrolled from Medicaid during the “unwinding” of the pandemic-related continuous coverage requirement.¹

For Medicare beneficiaries, the end of the PHE did bring some changes to how COVID-related coverage works, although the specifics vary depending on how a beneficiary gets their coverage:

• Medicare continues to cover COVID vaccines at no cost. COVID vaccines are covered under Medicare Part B, and the deductible and coinsurance do not apply.
• Until the end of the PHE, Medicare covered COVID testing (including up to eight at-home tests per month) with no cost-sharing. After the PHE, coverage and out-of-pocket costs depend on whether the beneficiary has Original Medicare or Medicare Advantage:
  – Original Medicare no longer covers the cost of at-home COVID tests. It will cover PCR testing under Medicare Part B, which has a deductible ($240 in 2024) and then 20% coinsurance. If a beneficiary has supplemental coverage, it may pay some or all of the out-of-pocket costs for PCR testing.
  – If a beneficiary has Medicare Advantage, their plan may or may not cover the cost of at-home tests, and may or may not have cost-sharing associated with PCR testing. Beneficiaries will need to check with their plan to know what to expect.

• Out-of-pocket costs for COVID treatments also depend on whether the beneficiary has Original Medicare or Medicare Advantage, whether the care in inpatient or outpatient, and the scope of the care needed.
• Monoclonal antibody treatments continue to be covered with no out-of-pocket costs in 2024, as long as the beneficiary has COVID symptoms.
• Most COVID-related telehealth flexibilities for Medicare beneficiaries will continue to be in effect through the end of 2024, and are no longer tied to the PHE timeframe (this is a result of the federal Consolidated Appropriations Act, 2023, which was enacted in late 2022).
• Some Medicare telehealth flexibilities, especially for mental/behavioral health, are permanent, while others only continue through 2024.
• Audio-only telehealth is no longer allowed after the end of the PHE unless it’s behavioral/mental health treatment. And providers and patients once again have to use HIPAA-compliant telehealth platforms (during the PHE, they could use any private audio-visual platform). After the end of 2024, there will once again be various restrictions on telehealth, including geographic and originating site requirements (ie, patients may have to go to a clinic to access telehealth, rather than receiving it from home).
• During the PHE, Medicare Advantage plans could not require enrollees to pay more for out-of-network care, and they couldn’t require primary care physician referrals before an enrollee could see a specialist. That ended June 10, 2023 (30 days after the end of the PHE), and Medicare Advantage plans resumed their normal rules for referrals and out-of-network care.

Recommended reading: How will the end of the public health emergency affect Medicare enrollees?

For people with employer-sponsored health coverage, the end of the PHE was similar to the effects for those with ACA marketplace coverage (see details above).

(Also note that certain large employers were allowed to offer telehealth-only coverage during the PHE to employees who weren’t eligible for regular health coverage; that ended at the end of the plan year during which the PHE ended.)

But the end of the national emergency did change the rules for COBRA deadlines and special enrollment periods for employer-sponsored plans, which aren’t applicable to those with marketplace coverage.

Here’s what you need to know about the end of the COVID emergency declarations if you have employer-sponsored health coverage:

• Recommended vaccines, including COVID vaccines, continue to be covered with no out-of-pocket costs on all non-grandfathered employer-sponsored health plans (grandfathered plans do not have to cover any vaccines with zero cost-sharing; as of 2020, about 14% of covered workers were in grandfathered plans). But enrollees need to use in-network providers to obtain zero-cost COVID vaccines.
• Employer-sponsored health plans generally continue to cover PCR COVID testing administered by in-network providers. But regular cost-sharing (deductible, copay, coinsurance) is now applicable, and plans can require a doctor’s order for the test.
• Just like other private health plans, employer-sponsored plans no longer have to cover the cost of at-home COVID tests. Employer-sponsored plans have the option to continue to provide some benefit for at-home test kits, but are not required to do so (some employers offer these tests directly to their employees; you can check with your employer to see if this is available). As is the case for people with marketplace coverage, those with employer-sponsored plans can take advantage of the free tests that the government will mail to you while supplies last. HSA or FSA funds can also be used, pre-tax, to purchase COVID tests.
• The coverage of COVID treatment generally did not change. Medically necessary inpatient and outpatient care continue to be covered, with the plan’s normal cost-sharing requirements.
• If you have a special enrollment right (an opportunity to enroll in your employer’s plan outside of open enrollment, due to a qualifying life event), you normally only have 30 days, or 60 days in some cases, to enroll. That time-limited window was not applicable during the national emergency. But starting July 11, 2023 (60 days after the originally-scheduled end of the national emergency), the time limits on special enrollment periods for employer-sponsored coverage were once again applicable.
• You only have 60 days to elect COBRA (if it’s available to you), and then 45 days to pay the first premium. After that, you have a 30-day grace period for each monthly premium payment. During the COVID national emergency, people had up to a full year extension on these deadlines. That ended on July 10, 2023, and the normal COBRA deadlines are once again applicable.

In general, the takeaway for most people is that vaccines continue to be free as long as you use an in-network provider, testing generally now has cost-sharing associated with it, and cost-sharing for treatment did not change (it had cost-sharing both during and after the PHE). COBRA and special enrollment periods for employer-sponsored health plans continue to be available on the same terms as before, but their deadlines are now the same as they were pre-COVID.