How Will the End of the PHE Affect Radiology?

As reported last week, the Biden Administration has announced that the COVID-19 Public Health Emergency (PHE) will end May 11.

The Centers for Medicare and Medicaid Services (CMS) has provided many flexibilities throughout the PHE. The Consolidated Appropriations Act of 2023 has extended some of the telehealth flexibilities through 2024. For example, there are no geographic restrictions for originating site for non-behavioral/mental telehealth services through the end of 2024. Conversely, CMS currently pays the same rate for telehealth and in-person visits, but this will end at the end of 2023. CMS does have the opportunity to make changes to these flexibilities in the calendar year 2024 Physician Fee Schedule Proposed Rule. Additionally, the 20% increase in Medicare reimbursements that hospitals received for COVID-19 patients will end with the expiration of the PHE.

The PHE also required that states maintain Medicaid continuous coverage for individuals. In 2020, states that received enhanced Medicaid funding were prohibited from dropping individuals from the program while the PHE was in place. During the pandemic, Medicaid enrollment increased significantly, and over 91 million people were enrolled in either Medicaid or CHIP as of October. The continuous coverage requirement will end on March 31. The Department of Health and Human Services (HHS) estimates that around 15 million people will lose health benefits as states begin their redetermination processes to evaluate eligibility. If someone is no longer eligible for Medicaid, they will have until July 31, 2024, to sign up for coverage via the federal Affordable Care Act (ACA) marketplace.

The American College of Radiology® (ACR®) will continue to monitor the PHE wind-down. If you have any questions, please do not hesitate to contact Christina Berry, ACR Team Lead, Economic Policy.