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COVID-19 Post-PHE Implications for Your Practice’s Revenue Cycle

The unwinding of the COVID-19 Public Health Emergency (PHE) has wide-reaching implications for all healthcare practices. Policies that were put in place to allow fast and simple continuation of care are now being rolled back, causing confusion and creating minefields for your revenue cycle. Read on to learn more about how to protect your practice.

Patient Financial Responsibility Will Increase Again, Resulting In Unpaid Bills.


While most Medicare patients will not see their costs go up, there will likely be a lot of confusion about what is or is not covered. For instance, COVID-19 testing will still be free when ordered by a doctor, but the provision allowing patients to receive 8 free tests from the pharmacy has ended. Patients may delay treatment or decline services because they are unclear on their benefits.


The Consolidated Appropriations Act of 2023 decoupled the Medicaid continuous enrollment provision from the PHE and terminated this provision on March 31, 2023. As of April 1, 2023, states have resumed Medicaid disenrollments. The HHS estimates that approximately 9.5 percent of Medicaid enrollees (8.2 million) will leave Medicaid due to loss of eligibility and will need to transition to another source of coverage. If your practice serves a large Medicaid population, you will likely see an increase in bad debts as these patients experience gaps in insurance coverage.

Private Insurance

For those with private insurance, cost-sharing will go back into effect for COVID-19 testing and treatment, meaning they will be subject to deductibles and then copays. There are also new and different stipulations for when a test or treatment will be covered. For example, many private insurers are now requiring a prescription in order to cover a PCR test, meaning they also need to be seen by a clinician. Patients will incur increased costs at each point in the process from testing to return-to-work documentation. 

Any time patient financial responsibility increases across the board, your practice is likely to see a reduction in patient encounters while spending more time chasing payments, from patients and payors alike. 

Inaccurate COVID-19 Coding Will Result In Claims Denials.

Changes in coverage will correspond with alterations in coding, resulting in an increased administrative burden as the Public Health Emergency (PHE) unwinds. It is of paramount importance for healthcare providers and coding managers to proficiently identify emergency use codes and diligently maintain their systems to reflect these changes.

Already, six new CPT Codes have been approved for COVID-19 immunizations. All existing CPT codes that describe COVID-19 vaccine products and associated administration codes that end in “A” for products that are no longer covered under an existing Emergency Use Authorization (EUA) or Biologics License Application (BLA) from the US Food and Drug Administration (FDA) will be deleted effective Nov. 1, 2023.

If providers within your practice were accepting insurance coverage through provisional credentialing, there may also be a gap in their ability to accept certain plans. Be sure to review credentialing relative to the PHE carefully and submit applications for regular credentialing in a timely manner.

Fines, Fees, and Overdue A/R Can Quickly Add Up.

While any one instance of an incorrect code or an overdue patient bill might not be a big deal, repeat instances of these problems can cause a major hit to your bottom line

It costs money to collect overdue patient bills, and the best mitigation strategy is to communicate post-PHE changes to patients and provide a clear financial policy.  The recent federal changes in not allowing credit reporting on balances less than $500 will further imperil these balances!

While you’re waiting for a denied claim to be re-reviewed you could find your overdue A/R growing out of control, and unfortunately, it’s not feasible for an outsource vendor to simply help you catch up. We highly recommend a post-PHE chart & billing audit to make sure your practice is set up for success and help create a relationship with a vendor you trust before your cashflow is negatively impacted.

If an encounter is coded incorrectly, that same code could be used multiple times each day, having an exponential effect in terms of the fines you could face once the coding error is caught by the payor - or the money you could cost yourself by not coding correctly.

In conclusion, the post-Public Health Emergency (PHE) landscape presents significant challenges and implications for your healthcare practice's revenue cycle. 

As we navigate the changes ahead, it's crucial to be proactive in safeguarding your practice's financial health. Remember that being proactive and well-informed is key to mitigating the challenges posed by the post-PHE era. By staying vigilant and responsive, your practice can navigate these changes successfully, ensuring the continued financial health of your organization.

If you need support managing your practice’s billing and coding, get in touch today.

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