Is CMS asking providers to begin to prepare for the eventual end of the COVID-19 Public Health Emergency (PHE)?

Yes. On August 18, 2022, CMS released the blog post linked below entitled, “Creating a Roadmap for the End of the COVID-19 Public Health Emergency”. While the post does not provide a specific date as to when the COVID-19 PHE declaration will be terminated, CMS is encouraging providers “to prepare for the end of these flexibilities as soon as possible and to begin moving forward to reestablishing previous health and safety standards and billing practices”.

The COVID-19 PHE declaration was last extended on July 15, 2022, and will therefore will be up for expiration or renewal on October 15, 2022. Within the post, CMS reiterated its commitment to providing stakeholders with a 60-day notice before ending the PHE. While purely speculative, we interpret this to mean the PHE will likely be renewed on October 15, 2022 – but possibly for the last time. The Craneware Group will continue to provide updates as they are released by CMS.

Within the post, CMS provides stakeholders with a link to what they are calling a “roadmap”. The “roadmap” outlines the current waivers and flexibilities in effect today, and CMS states it will update this document as needed to ensure providers have an accurate understanding of which flexibilities are and are not still in effect. However, CMS does remind providers that unless explicitly noted in the roadmap, all waivers and flexibilities will end once the PHE declaration is terminated.

While CMS praises providers for their extraordinary efforts during the height of the COVID-19 pandemic, they state it is their opinion that the pandemic is no longer in a phase where the majority of these waivers and flexibilities are still required, and that these waivers, at this time, may even be leading to an unnecessary decrease in patient safety and overall quality of care.

We encourage all providers to bookmark and frequently check the CMS “Roadmap” as well as The Craneware Group COVID-19 resource page for additional updates. Conversations with clinical leadership should begin immediately to establish “return to normal” game plans.

Resources:

CMS blog post, “Creating a Roadmap for the End of the COVID-19 Public Health Emergency”: https://www.cms.gov/blog/creating-roadmap-end-covid-19-public-health-emergency

CMS “Roadmap”: https://www.cms.gov/files/document/covid-19-emergency-declaration-waivers.pdf