How Employers Should Prepare for the End of the COVID-19 Emergencies

​In late January, the Biden administration announced that the COVID-19 public health emergency (PHE) and national emergency will end May 11. The pronouncement marks the beginning of a significant phase in the ongoing pandemic, as well as the ending of a series of benefits enabled by the emergencies.

But what exactly does the end of the PHE and national emergency mean for employers and their health and benefits plans? And how should they address and prepare for it?

"We certainly can't ignore the implications of this," said Wade Symons, regulatory resources group leader at consulting and professional services firm Mercer. "It's something that [employers] have to consider from a cost perspective and administrative perspective—and from an employee communications perspective as well."

Who Pays for COVID-19 Testing, Vaccines?

The PHE mandates that health insurance plans fully cover COVID-19 testing without employee cost-sharing, on both an in- and out-of-network basis. But once the emergency ends in May, that requirement changes, meaning medical plans, including employer-sponsored plans, do not have to pay for testing and will have to decide how to proceed.

"That's a bit of a decision point," Symons said. "Employers will have to decide: How are we going to cover COVID testing going forward? Are we going to continue to do what we did before and pay for it? Are we going to limit it to in-network only? Are we going to restrict further how employees can get over-the-counter tests?"

COVID-19 vaccines work a little differently than testing, as the government has been funding the vaccines, while employer plans and insurers have often paid for the associated administration cost. The PHE requires that nongrandfathered group health plans cover COVID-19 vaccines without cost-sharing, but that will change soon. Vaccines will be required to be covered as a preventive service going forward, but only on an in-network basis, Symons said.

Employers ultimately have to decide not only what to do in terms of COVID-19-related coverage, but when to do it. For instance, if they decide to stop paying for testing, will they make that change immediately when the PHE is over? Or will they wait until the beginning of the plan year? All those considerations are in play, Symons said.

For some employers, continuing to cover the costs of testing or vaccines may be beneficial.

"Even though the public emergency is ending, that doesn't mean that the virus has gone away," Symons said. "People are still concerned about this, and employers want to minimize the impact it has on them."

Employees who test and are aware of infections, for instance, are less likely to come into a workplace and infect co-workers. And ensuring that costs are covered will likely convince workers to take tests when they need to.

Covering testing may be worth it for employers, especially considering the backlash they may face if they make their employees pay for it, Symons said.

Changes Coming for Medicaid, Special Enrollment

The end of the PHE will also mark a couple of changes as far as health plan enrollment. One change is to Medicaid: Enrollment in the government health care program has soared in the past three years as COVID-19 rules barred states from kicking people off it 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 plans, Symons said.

In addition to more enrollment, this will also likely result in a rise in claims and the cost of premiums.

Additionally, the end of the national emergency—which is different than the PHE—will end provisions that allowed for extended time for special enrollment in plans due to life events such as losing coverage, getting married or having children. Typically, employees have 30 days to enroll in a plan after such an event, but the national emergency gave people up to a year to enroll.

The special enrollment provision ends July 10, which is 60 days after the national emergency ends. That date will also mark the end of some COBRA-related relief, in which employees had extra time to pay their COBRA premiums and decide whether they wanted to use the coverage.

Both the special enrollment and the Medicaid change will impact employers. "It's something that we're certainly telling employers to start thinking about and planning for, especially those that are in industries where [additional enrollment] might be a more likely scenario, like retail or hospitality," Symons said. "Budget for some additional bodies coming onto your plan."

Employers also will no longer have relaxed restrictions on telehealth and virtual care. Under the PHE, organizations were allowed to extend those services to workers not eligible for major medical plans, such as part-time or temporary workers.

How to Prepare

Employers need to do a few things in anticipation of the pandemic emergencies ending, experts said. Reviewing health plan terms for COVID-19-related coverage and reviewing benefits terms or offerings made under temporary pandemic relief laws and guidance is a good first step. Additionally, getting assistance and guidance from insurers and third-party administrators is important, Symons said. HR and benefit leaders would be wise to talk with them about how they want to handle the end of the emergencies and what changes they need to make in their plans.

Another important piece is communicating with employees about the end of the PHE and national emergency and how it will affect them, said Kim Buckey, vice president of client services at Optavise, a Carmel, Ind.-based benefits administration firm.

"More communication will be required around the end of the public health emergency come May 11, and employers should start preparing now for how they will communicate changes to employees, especially since previous extensions have made it confusing," she said.

Communication with employees about cost changes is especially important, as employees have gotten used to COVID-19 tests and vaccines being covered at no cost.

Employers also need to make sure employees are aware of the special enrollment changes, Symons said.

"Communication is really important to let employees know, 'OK, now you no longer have that extended window of time; we are back to our old 30-day window to request enrollment,' " he said. " 'And we're back to the normal COBRA premium payment deadline.' "

Ultimately, "[t]here are a lot of changes that will need to be administratively handled at the employer level, but also communicated out," Symons said.