The public health emergency declared in early 2020 was put in place to provide waivers from the Centers for Medicare and Medicaid Services to ease the burden on hospitals and other providers during the pandemic. It has been extended 12 times since its implementation and is finally slated to end on May 11. 

Heather Meade, principal at Washington Council Ernst & Young, spoke with MobiHealthNews about how the end of the PHE could affect telemedicine companies' funding streams and patients' access to care.  

MobiHealthNews: What are the benefits and detriments to the PHE ending, especially for telehealth?

Meade: I mean, we need permanent policy in these areas. Nationally, it's in some ways been the silver lining, right? When I hear congressional leaders on the Hill talk about things that came out of the pandemic that they would like to keep, telehealth is always on that list. And I think it does give Congress the opportunity now to have a real discussion about the potential of maintaining telehealth on a permanent basis and what that should look like. And I think it's always good for us to have healthy public debate about those areas. 

The learning curve of policymakers can sometimes be pretty steep, and it's hard, particularly in this bipartisan and budget-constrained environment to do all of the things that everyone would like to do. But I'm hopeful that there is enough public pressure and public appreciation of the benefits of telehealth that will really kind of push these policies forward, or at least create some longer term extensions, so that providers can continue to invest in the technology and we can continue to grow. 

MHN: How is the end of the PHE going to affect funding streams?

Meade: It depends. It's very programmatic. For telehealth, it's not going to affect a lot of the funding streams, because we have this temporary extension through 2024 for the reimbursement in the Medicare program. Some states have already started to limit the flexibilities that they made available. Specifically, some states were allowing providers to do a couple of things. One is to charge facility fees when they were, you know, receiving telehealth care as if they were there. Some of those pieces have been pulled back. 

Some states were requiring telehealth to be paid at parity. This is probably the biggest one, and that was a really important piece, particularly for hospitals who were receiving reimbursement for telehealth as if they were providing care in a hospital to that person or in a provider's office to that person.

So, as states pull that back from Medicaid patients, and as the federal government has the opportunity to reevaluate the appropriate level of reimbursement, that does create pretty significant risks to the funding stream in government-paid markets. And it's very likely that the government will not say, "You should receive 100% payment parity in all circumstances."

So we may see, as Congress thinks about it, some potential variation, both by the type of care that's being provided, the location that the care is being provided and the program through which it's being provided. We're going to start to see more variation around that.

MHN: How is the end of the public health emergency going to affect patients overall? 

Meade: I think there's sort of two effects. One is, if hospitals and provider groups where a lot of this is happening feel like there isn't sufficient support, will they pull back on their willingness to invest and engage and provide this?

Patients really like it. We saw a huge spike in utilization [during the height of the pandemic], and we've seen a pretty significant decrease in utilization over 2022. But it is still three-fold above what it was pre-pandemic.  So, it's still really significant. I think the one question is, will there continue to be sufficient investment in it? I think there is patient interest and demand. 

A lot of those pieces are going to vary based on where they got their coverage, what flexibilities they were utilizing. For example, there is a provision that allows telehealth to be offered as a stand-alone product. And so an employer might offer it to their part-time employees who are not enrolled in coverage, and that provision was not extended. And so, if you're that person, it could be a pretty immediate change, right?  But if you're on Medicare, you may not see as big of a change because you have this two-year extension from Congress.