Whoever gave the moniker “unwinding” to the work that will be required once the Public Health Emergency (PHE) ends must have a great sense of humor. While “unwinding” usually brings thoughts of relaxation and perhaps a sandy beach and a favorite cocktail or hobby, the “unwinding” that will occur when the U.S. PHE expires will likely be anything but relaxing, especially for those in healthcare or a related field.
So much has happened since January 31, 2020, when the World Health Organization declared a Public Health Emergency of International Concern and the Secretary of the U.S. Health and Human Services Department, Alex Azar, declared a PHE in the U.S. due to COVID. That PHE has been renewed 11 more times, for three-months at a clip, with the latest due to expire January 13, 2023. Don’t panic, yet.
First, the PHE will most likely be extended once again, since the promised 60-day notice before expiration did not occur. Second, the last extension occurred mere days before the PHE was due to end, so advance notice of an extension isn’t necessarily the norm.
While some wonder why we even have a PHE anymore, the healthcare community has to prepare for the unwinding of Federal and state COVID rules, regulations, and protocols, which impact everything from patient care, privacy, and communications to coding, billing, revenue, insurance, and more. To make things more complicated, the timeframes for unwinding vary.
Obviously, the amount of work required to unwind will be impacted based on whether you have a multi-disciplinary practice or focus on one specialty; whether you operate a hospital or medical practice; whether you lead an insurance company/brokerage or telehealth platform; and more.
Still, there’s going to be a lot of work required at the same time you’re likely dealing with the effects of the ongoing labor shortage and uncertain financial environment. As noted by Employee Benefit News, “As we move into 2023, a new sort of “new normal” will likely emerge, but it will take significant effort and communication between healthcare providers, systems, insurance carriers, employers, and employees.” (Schomer, Stephanie. “When COVID is no longer a public health emergency, what happens to healthcare?” November 7, 2022. BenefitNews.com.)
There are a few ways to start preparing to unwind that may be worth consideration now:
- Review changes that took place throughout the PHE and identify which ones will impact your organization once the unwinding begins. Valuable resources include:
– KFF’s detailed summary of changes, timing and implications.
– The Center for Medicare and Medicaid Services’ roadmap for unwinding and fact sheets by medical discipline.
– Medicaid’s dedicated resources, tools and information and the S. Department of Health and Human Services’.
– Georgetown University’s Health Policy Institute state unwinding tracker links to state plans as well as communication tools, FAQs, and more.
– New York State of Health website, toolkit, and communication templates. - If you operate a practice that specializes in one discipline or industry, be sure to get on the email lists of national organizations representing your vertical. This can help you get right to the information that’s most pertinent for your practice.
- Consider establishing a task force now to oversee the overall unwinding process for your organization. Define who should be on the task force, governance, objectives, timelines, milestones, and success measures. Be sure to include legal counsel for accurate interpretation and application of rules, regulations, and protocols.
- Start developing a change management strategy incorporating communication and training. Identify all key constituents and audiences, their information needs, communication channels, key messages, and more. Whether you decide to institute a two-minute start of shift daily meeting to review the latest updates or add a reference page on your Internet/Intranet, using the time available to get an infrastructure in place now can help you when the PHE ends.
While you’re focusing on leading your organization through the unwinding, keep in mind that RBT CPAs can free you up by handling all your accounting, tax, and auditing needs with the highest levels of professionalism and ethics. We’re one of the largest firms in the Hudson Valley and beyond, with a legacy built on one simple belief: we succeed when we help our clients succeed. Interested? Give us a call today.