The End of the PHE is Near

by Tiffany Ferguson, LMSW, CMAC, ACM
Published on Feb 06, 2023

This article appeared on on February 6, 2023

During the COVID-19 pandemic, our health system saw significant benefits under the federal public health emergency (PHE) waivers. Whether it was the expansion of telehealth or the removal of the three-day inpatient-stay skilled nursing facility (SNF) requirement, healthcare organizations were able to open care to their patients in ways they have not been able to in the past. Socially, we have learned that the PHE provided significant relief of healthcare expenditures for hospitals, particularly with the expansion of Medicaid. 

Research now provides evidence that the ripple effect of the PHE has also improved our country’s unemployment rate and decreased concerns over housing insecurity and eviction rates (Bailey, V. 2023). However, as we have already seen, many states are planning to roll back their Medicaid coverage when the PHE ends.

It is estimated that when the PHE ends, tentatively scheduled for May 11, between 5.3 million and 14.2 million Americans will lose coverage, and all Medicaid patients will be required to go through the redetermination process for eligibility. Starting in April, states are expected to meet the requirements for an unwinding process to phase out the continuous enrollment provisions from the PHE (Tolbert, J., & Ammula, M., January 11, 2023).  

This is going to have significant impact on our healthcare system, as patient registration and financial services will need to increase efforts to help patients complete their redeterminations, which all likely will result in a huge burden. At any level in the healthcare setting, we can expect changes in Medicaid coverage when patients may be unaware that they have lost their coverage or have a change in coverage. This also will result in delays for services, accessing care, medications, and post-acute transitions. Financially, healthcare will likely experience a rise in denials, bad debt, and uncompensated care. The Centers for Medicare & Medicaid Services (CMS) does have a z-code for those who have insufficient social insurance or are on welfare support: Z59.7.

So, what can health systems do to prepare?

Revenue cycle teams and patient financial services will need to have a good understanding of what will happen in their state when the PHE ends. CMS on Jan. 5 released requirements for each state to develop an operational plan for how they will be “unwinding” coverage from the PHE to their state Medicaid coverage determinations. I have included below a link put together by Georgetown University of each state’s plan and where they are in the process of preparing for the Medicaid rollback. 

Connecting with the local department of health and human services (HHS) offices will be vital to ensure that all access points for patient care provide information regarding the changes that will be coming in your local area. Frontline registration, scheduling, and financial assistance staff will want to be aware, and start helping patients obtain information regarding requirements for eligibility, which typically includes submitting updated income statements, tax returns, and proof of home address, such as copies of utility bills. If your hospital does not provide this, it may be a good time to start having conversations, so your healthcare system is not stuck with a significant number of uninsured patients.

Is your hospital or healthcare system prepared for the Medicaid changes when the PHE ends?   

Programming note: Listen to Tiffany Ferguson’s live reporting every Tuesday on Talk Ten Tuesdays with Chuck Buck and Dr. Erica Remer, 10 a.m. EST.

References & Resources

Bailey, V. (January 18, 2023) Medicaid Expansion Helped Reduce Eviction Rates, Housing Insecurity. Public Payer News, Health Payer Intelligence.  Retrieved from Medicaid Expansion Helped Reduce Eviction Rates, Housing Insecurity (

Tolbert, J. & Ammula, M., (January 11, 2023) 10 Things to Know about the Unwinding of the Medicaid Continuous Enrollment Provision. Retrieved from

50- State Unwinding Tracker: