PHE renewed again but start planning now for flexibilities to end

by A.J. Plunkett (

If your organization has not already done so, start drawing down now from using compliance waivers granted under the COVID-19 public health emergency (PHE) declaration. On October 13, the PHE was renewed for another 90 days but it remains uncertain if it will be renewed again.

The next renewal date would be on or before Wednesday, January 11, 2023. Just before the PHE was renewed in October, CMS published a blog “Creating a Roadmap for the End of the COVID-19 Public Health Emergency,” with attached links to memos about the waivers for each provider type.

The 22-page memo for hospitals discusses how the end of the PHE will be managed, including such things expectations for payments for COVID-19 vaccines, that temporary expansion sites should be closed and a warning that flexibilities for the physical environment will end.

Patton Healthcare Consultants, in their September newsletter to clients, advises to start planning now for the end of the PHE.

“This detailed memo should be reviewed very carefully by clinical and financial leadership so that you can plan to be compliant with previously waived requirements and ensure continued payments for services you have been providing or modification of service arrangements,” according to the newsletter.

“CMS also provides guidance on flexibilities that are planned to end such as CAH bed count, off site patient screening, alcohol-based hand rub quantity waivers, discharge planning, verbal orders, nursing care plans and many other issues. Going back and restarting practices that were ceased because they were thought to be nonessential will be a difficult task with a workforce that may still be stressed from the pandemic, resignations and retirements,” said Patton Healthcare.

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