5 Actions to Prepare for a Post Health Emergency Transition

  • Health care and life sciences
  • 12/20/2022

Successfully transitioning to a post-public health emergency environment will take preparation and planning. We provide 5 actions you can take now to positively posi...

Today’s blog is provided by CLA’s Rebecca Rye and Jennifer Boese

The COVID-19 public health emergency (PHE) has resulted in unprecedented flexibilities extended to providers and their patients. The PHE has been in effect since January 27, 2020, and the current extension ends January 11, 2023. An additional extension seems likely, given the administration’s promise to provide a 60-day notice before the final expiration of the PHE. However, it is important to begin thinking through the impacts that the PHE expiration will have on your organization.

While individual waivers are far too numerous to list, CMS has assembled a comprehensive list of the blanket waivers applicable during the PHE—view it here to see which ones your organizations may have utilized.

What 5 actions can you take now?

1. Create a plan for transitioning back to previous requirements

The COVID-19 PHE has had an impact on essentially every aspect of the health care system in the US–staffing, safety protocols, and increased telehealth capabilities are just a few examples. Does your organization have a plan for what your future “normal” operations will look like as the PHE ends? It will be important to make sure you have a handle on what flexibilities you used, how and when those will cease, and a roadmap for your transition.

2. Identify waivers you have been utilizing that will end post-PHE—and when

Understanding the waivers and flexibilities you’re using and when those expire will help to smooth the transition back to previous requirements. CMS has developed provider-specific fact sheets to help you identify what items will be expiring immediately with the end of the PHE, and what items, like certain telehealth payments and flexibilities, will be available for a period of time afterward. The facts sheets range from physicians, hospitals, long-term care, home health, Medicare Advantage, labs, ACOs and more.

3. Identify ways that the transition will impact financial, operational performance

The end of the PHE will mark the end of several avenues of government aid and increased payments for certain codes or procedures. For example, there have been many flexibilities provided for telehealth, including allowing the home as an acceptable originating site as well as eliminating rural requirements. Some requirements and codes have been extended for a certain amount of time post-PHE. For those who have used this flexibility, it will be very important to understand this complex area.

Identifying codes that are being billed currently that will not be reimbursed in the future, the ways in which payments for procedures will change, and understanding the magnitude of the changes will help make sure your organization doesn’t face revenue surprises post-PHE.  It’s also worth considering how other payors will handle the end of the PHE or whether they are open to negotiations.

Further, many operational changes have been put into place during the pandemic based on these flexibilities or due to the pandemic itself. Now is also an opportunity to review these changes, your policies, your processes and whether these fit into future operations or strategies. You may also want to consider an operational assessment.

4. Help staff understand what is involved in the transition

Proper training of staff will be key to a smooth transition, especially when it comes to reverting to normal regulatory requirements. Many reporting requirements have been relaxed during the PHE, and these requirements will become applicable again directly following the end of the PHE. In addition, clear communication with employees as staffing and job roles change in the post-PHE period can help to maintain employee buy-in and satisfaction through the transition. You may want to consider an employee commitment survey to gauge what your employees feel about your organization.

5. Familiarize yourself with your state’s plans for Medicaid transition

If Medicaid is a portion of your payor mix, it is essential to track the plans for post-PHE transition in each state in which you have operations. The Families First Coronavirus Act required continuous Medicaid enrollment for the duration of the PHE for those enrolled as of March 18, 2020. In an issue brief released in August, HHS estimates that as many as 15% of Medicaid enrollees will lose eligibility for Medicaid and need to transition to another payor. Assessing the impact this transition may have on payments and collectability could be a key element of planning for organization serving a high proportion of low-income individuals. Make sure to review your state’s plans.

How can CLA help?

These flexibilities – whether those are regulatory, payment, workforce and beyond – create an even greater need for financial modeling, operational assessment, employee commitment/satisfaction, risk management and compliance. Now is an excellent time to take stock of where your organization is at and plan for a positive post-PHE transition.

CLA’s health care team is here to help. Reach out today!

This blog contains general information and does not constitute the rendering of legal, accounting, investment, tax, or other professional services. Consult with your advisors regarding the applicability of this content to your specific circumstances.

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