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The End of the COVID-19 Public Health Emergency

Explore key NASHP resources on how states are responding to the end of the federal COVID-19 public health emergency.

The federal COVID-19 public health emergency (PHE) allowed for a range of state and federal policy flexibilities in programs such as Medicaid. As the PHE ends, states need to unwind many policy changes implemented in response to the pandemic — from the easement of federal telehealth restrictions to ending Medicaid’s continuous coverage protection. 

In addition, state leaders are also looking beyond the PHE, identifying lessons learned from the pandemic, and finding opportunities to strengthen and improve public health, behavioral health, and the broader health care system. To learn about states’ emergency orders and actions designed to safeguard residents during the COVID-19 pandemic, check out our tracker.

Unwinding Medicaid

During the PHE and as a condition for enhanced federal funding, states were required to suspend disenrollments for Medicaid enrollees to provide coverage stability for millions — this is often referred to as the Medicaid continuous coverage requirement.

Since March 2020, Medicaid enrollment increased significantly due to the unpredictable economy and changing job market — with estimates around 90.6 million people now eligible for the program. With the enactment of the Consolidated Appropriations Act in December 2022 and the delinking of the Medicaid continuous coverage requirement from the PHE, states now have a definitive date of April 1, 2023 for resuming Medicaid disenrollments.

States have been preparing for the challenge of redetermining eligibility for millions and disenrolling those who are no longer eligible when the Medicaid continuous coverage requirement ends. This includes strategies to help ensure that eligible people remain enrolled and that people who are eligible for other sources of coverage, like the health insurance marketplace, are successfully transferred to those programs. Strategies around staffing, communications, data and engaging health plans, providers, and other community partners are critical to preparing for these changes.

The Future of Telehealth

During the pandemic, previous telehealth restrictions were relaxed at the federal and state level. This expanded access to a variety of virtual health services, including primary care, chronic disease, prescription drug management, and more. States are now considering whether to extend telehealth policies beyond the pandemic as they seek to ensure quality access to health care.

Looking beyond the PHE

As policymakers begin to look past the immediate PHE, the pandemic continues to pose many challenges to public health and the broader health care system. This includes behavioral health systems, which have experienced a spike in demand coupled with diminished provider capacity. States can apply lessons learned from the pandemic to strengthen and modernize these systems.

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