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The End is Here: How the End of The PHE Will Affect the Revenue Cycle

Analysis  |  By Amanda Norris  
   May 09, 2023

The COVID-19 public health emergency (PHE) is ending this week, make sure your revenue cycle staff are prepared.

More than three years after the COVID-19 PHE was declared, it is now set to end on Thursday, which will be impacting revenue cycle reimbursement.

Multiple emergency declarations and waivers that were implemented granting flexibilities to state Medicaid operations and most healthcare organizations are coming to a halt, leaving revenue cycle staff scrambling to ensure minimal disruption to their billing and operations.

Here is a look at what could be affecting your revenue cycle:

Telehealth reimbursement waivers: These waivers allowed hospitals to provide telehealth services to patients without prior authorization, and reimbursements for telehealth visits were increased. With the end of the PHE, these waivers may end, and hospitals may have to seek prior authorization for telehealth services, and reimbursements may return to pre-pandemic levels.

Waivers for Medicare coinsurance and deductible payments: During the public health emergency, Medicare waived Part B coinsurance and deductible payments for COVID-19 treatment. With the end of the PHE these waivers may end, and hospitals may have to bill patients for the coinsurance and deductible payments, which could negatively impact your organizations' patient financial experience.

Suspension of Medicare sequestration: The PHE suspended the 2 percent Medicare sequestration, which was a reduction in Medicare payments to hospitals. With the end of the public health emergency, this sequestration may resume, reducing Medicare payments to hospitals.

Reintroduction of the three-day stay skilled nursing facility (SNF) requirement: To qualify for SNF reimbursement, Medicare patients must have first spent three consecutive midnights in the hospital as an inpatient. These inpatient days must meet medical necessity requirements, and the clock starts ticking when the physician writes the inpatient order.

In order to receive proper reimbursement, revenue cycle staff should be clear on the following Medicare requirements for SNF coverage:

  • The patient must have completed a three-day inpatient stay
  • The stay must have extended through three midnights, beginning at the time the physician wrote the inpatient order

Note that time spent in observation or the emergency department does not count toward the three-midnight requirement.

For even more information, HHS released a policy roadmap detailing policies that will simultaneously end with the PHE, as well as flexibilities that have been extended for various time periods.

As the end of the PHE inches closer, revenue cycle professionals must ensure their organization is in compliance throughout the transition. Review the transition roadmap and other fact sheets to determine the timeline of flexibility expirations.

Amanda Norris is the Director of Content for HealthLeaders.


As the end of the PHE comes to a close this week, revenue cycle leaders must ensure their organization is in compliance throughout the transition.

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