What the end of the PHE means for CHCs

The Biden administration announced the COVID-19 Public Health Emergency (PHE) will end on May 11, 2023. Read on to learn what the end of the PHE means for community health centers and their patients:
On January 30, the Biden administration announced the COVID-19 Public Health Emergency (PHE) would end on Thursday, May 11, 2023. The federal government first declared the PHE in January 2020 because of the COVID-19 pandemic, and the PHE has subsequently been extended in 90-day increments, most recently in January of this year. 
What does the PHE allow the federal government to do?
Declaring a PHE allows the U.S. Department of Health and Human Services (HHS) to access different funding sources to respond to the emergency, modify the practice of telemedicine, and waive or modify certain Medicare, Medicaid, or Children's Health Insurance (CHIP) and Health Insurance Portability and Accountability (HIPAA) Privacy Rule Requirements.1
How will the end of the PHE affect Medicaid? 
More than 30% of community health center patients in Tennessee are covered by TennCare, the state's Medicaid program.2 Throughout the COIVD-19 pandemic, states received enhanced federal funding to maintain the continuous coverage requirement. During this time, no Medicaid eligibility redeterminations were made, allowing additional folks to receive and maintain coverage. A provision in the FY23 omnibus spending package, passed in December 2022,de-linked the status of the COVID-19 PHE with the requirement to provide continuous coverage in Medicaid and requires states to begin the process of re-determining eligibility by April 1, 2023.  
This week, TennCare presented its unwinding plan to legislative committees: 
  • TennCare is currently in the education phase of its plan, which includes increased communication to enrollees to let them know the renewal period is beginning soon.  
  • The agency will begin processing redeterminations in March; however, no one will be removed from the program prior to April 1, 2023.  
  • TennCare will conduct as many auto-renewals as possible using existing data sets. 
  • Individuals whose coverage cannot be auto-renewed will be sent a packet by mail or an email notification to renew using the TennCare Connect portal. 
  • These individuals will have a 40-day window to return the packet plus 20 days to return any need information. 
View TennCare's presentation before the House Finance, Ways & Means Committee  >>> 
How will the end of the PHE affect telehealth? 
During the COVID-19 pandemic, community health centers relied on telehealth to continue to provide high-quality care to their patients while keeping patients and providers safe. The PHE allowed for several flexibilities related to telehealth services in Medicare that allowed health centers to sustain telehealth operations. Congress passed legislation to extend current Medicare flexibilities through December 31, 2024 separate from the status of the PHE including: 
  • Community health centers can serve as distant site providers for non-behavioral health services.
  • A patient's home is recognized as an originating site.
  • A waiver of geographic restrictions for non-behavioral health services.
  • Audio-only telehealth can be used for some non-behavioral health services. 
  • A waiver of the requirement of an in-person visit within 6 months of a telehealth behavioral health service.3 
How will the end the PHE affect access to COVID-19 tests and vaccines? 
Throughout the COVID-19 pandemic, health centers served on the frontlines, providing COVID-19 tests, vaccines, and treatments to their communities. Following the end of the PHE, cost-sharing for COVID-19 tests and vaccines will increase for many people. In addition to the end of the PHE, this can be partially attributed to the federal government running out of funds to purchase items like tests and oral antivirals. Folks with private insurance will likely have some sort of cost-sharing for COVID-19 tests and antiviral treatments.4 Those who are uninsured will no longer be able to receive COVID-19 testing, vaccines, or treatments under a Medicaid eligibility pathway.5 Folks with insurance should still be able to receive COVID-19 vaccines without cost-sharing.6  
[1]  A ?public health emergency declaration (no date) Public Health Emergency Declaration. HHS. Available at:
[2]  Tennessee Health Center Program Uniform Data System (UDS) data.(no date). HRSA. Available at: 
[3]  Telehealth policy changes after the COVID-19 public health emergency (no date) HHS. Available at: 
[4]  Cubanski, J. et al. (2023) What happens when covid-19 emergency declarations end? implications for coverage, costs, and access, KFF. Kaiser Family Foundation. Available at: (Accessed: February 2, 2023). 
[5]  Ibid.
[6]  Ibid.



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