How to Prepare for Health Plan Changes Tied to the End of COVID Emergency Declarations
Workspan Daily
April 07, 2023
Key Takeaways
  • Enter the post-COVID era. The COVID-19 Public Health Emergency and National Emergency will end on May 11,  as will various relief measures.
  • Employers have a choice. Employers must decide whether they’ll continue offering COVID testing and vaccine coverage and related workplace mandates. 
  • Communication is key. Companies must communicate any changes they make in advance to their employees. Doing so will give employees time to prepare for the transition. 


On May 11,  the COVID-19 Public Health Emergency (PHE) and National Emergency (NE) will end, and employers should prepare to modify their group health plans and communicate the changes to employees.  

According to Jeff Levin-Scherz, MD, population health leader at WTW, the end of the emergencies will affect these areas of health coverage and policy: 

  • COVID-19 vaccination. After the PHE, health plans will be required to fully cover vaccines or other preventive services in network, but may cut out-of-network coverage.
  • COVID-19 testing. Plans can, if they choose, require cost sharing, prior authorization or other medical management requirements on coverage for diagnostic testing, including for over-the-counter tests.
  • Virtual-only health care. Pandemic relief allowed large employers to offer standalone telehealth to employees who aren’t eligible for other health coverage. Post-PHE, telehealth must be made a part of the major medical plan to comply.

Informing Employees 

Because these changes would be considered material modifications, they’ll trigger employer obligations under the Employee Retirement Income Security Act (ERISA) to update summary plan documents and communicate the revisions to plan participants. 

“Are you imposing cost sharing for COVID-19 tests or not covering tests out of network? Are there new participant deadlines?” said  Katie Johnson, senior counsel for health policy with the American Benefits Council. Then your organization should be communicating those decisions to employees, she said. 

Johnson added that she’s heard various approaches from employers as they move forward.  “Some say they’ll continue covering [COVID-19] tests just like they cover other tests, while others will stop over-the-counter tests altogether,” she noted. “Others won’t make changes mid-plan, so they’ll continue through the rest of the year.” 

Companies may wonder whether they should target their communication about changes to employees they know are more greatly affected by the COVID-19 pandemic. But that’s not the best approach, according to WTW’s Levin-Scherz.  

“There’s no special reason to have targeted communication,” Levin-Scherz said. “You don’t communicate separately with those who are immunocompromised, nor should you.” Instead, it’s best practice to provide all employees with health plan updates as they arise. 

Employers will also need to confirm proper winding down of extended deadlines for claims and appeals, special enrollment under the Health Insurance Portability and Accountability Act (HIPAA) and continuation coverage elections and payments under the Consolidated Omnibus Reconciliation Act of 1985 (COBRA), which will resume within 60 days of the end of the national emergency.

Updated Guidance

As employers navigate the winding down of COVID-19-era regulations, new guidance issued by by the departments of Labor, Health and Human Services and Treasury may help. And among the actions that should have started are: 

  • Reviewing health plan terms for all COVID-19-related coverage and reviewing offerings made under temporary pandemic relief laws and guidance.
  • Leaning on timely assistance from health insurers and third-party administrators regarding implementation of changes and communication to employees.

Editor’s Note: Additional Content
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