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Federal and state agencies have waived or relaxed regulatory requirements and expanded reimbursement for services for over three years because of the COVID-19 public health emergency (PHE) — but the end is near.

Some states terminated their emergency exceptions earlier, and the federal PHE concluded on May 11th. If you’re unsure about how to unwind PHE-era policies and practices, read these tips on how to ensure a smooth transition.

Tip 1: Identify Policies Affected
As soon as possible, identify the policies your practice changed due to PHE waivers to determine if you need to change them back or transition to a new policy. Some providers have already transitioned back to their old policies, while others never changed their policies to begin with and don’t have to switch back. Check your state’s policies and regulations to ensure compliance.

Tip 2: Determine Expiring Waivers
Once you’ve identified the policies revised for the PHE, check to see if the changes have been extended, dropped, or made permanent via legislation or Medicare rulemaking — including telehealth flexibilities. For example, CMS temporarily modified the requirement for a supervising physician to be immediately available to include virtual presence via real-time audio and video technology. However, this flexibility will end with the PHE.

Pay attention to the particulars when evaluating your telehealth policies and procedures. While major telehealth flexibilities will remain in place until Dec. 31, 2024, the waivers that expanded the types of healthcare professionals who can provide telehealth services and allowed coverage for audio-only telehealth have only been extended to end 151 days after the PHE concludes.

Tip 3: Create a Transition Plan
When you have your final list of policies that need to revert to pre-PHE rules, it’s time to draw up a plan for doing so. Designate who oversees the individual policy changes and set clear deadlines. Use pre-PHE policies to guide you when needed.

Tip 4: Train Staff
Educate staff on the new policies. Keep in mind that staff has had two years to get used to waiver-allowed policies, and it may take time to get them compliant with the old requirements.

Tip 5: Audit for Compliance
Audit to confirm that you’re compliant with post-PHE procedures, then provide training based on any errors found. The pattern of errors detected should guide whether you train all staff or individuals.

Tip 6: Boost Infection Control Protocol
It’s likely that staff will encounter patients and family members whose vaccinations are not up to date, and may have symptoms, but have not been tested. Clinics should step up precautionary measures and encourage staff to be vigilant about their safety after the pandemic officially ends.

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