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Important Benefit Changes as the COVID-19 Public Health Emergency and National Emergency Declarations Come to an End

Published: May 4 2023 10:45AM



During the last three years, you were entitled to certain benefits as the result of the Public Health Emergency (PHE) and National Emergency declarations for COVID-19.  The President of the United States has declared that the PHE will end on May 11, 2023 and signed legislation that the National Emergency ended on April 10.  As a result, certain benefits that you have had access to during the COVID-19 PHE and National Emergency periods will change.  Please review this information carefully to see how your benefits will be impacted.

COVID-19 Vaccines

During the PHE, your benefit plan waived cost share and medical management (including prior-notification) requirements for authorized COVID-19 vaccines and boosters.  This means that you received these free-of-charge, regardless of whether you received them from an in-network or out-of-network provider.

Effective on May 12, 2023:

• If your benefit plan covers Affordable Care Act (“ACA”) preventive health care services, you will continue to be eligible to receive COVID-19 vaccines and boosters free-of-charge from an in-network provider.  
• COVID-19 vaccines or boosters obtained from an out-of-network provider will only be covered if there are no in-network providers available in your area.  Medical management, (including prior notification) requirements, may apply.  Check with your medical benefits administrator to learn more.  
• If your benefit plan does not cover ACA preventive health care services, the COVID-19 vaccine and boosters will not be covered.

If you are unsure if your benefit plan covers ACA preventive health care services, please call your medical benefits administrator at the phone number listed at the end of this article.

COVID-19 Over-the-Counter (“OTC”) Diagnostic Tests

Since January 15, 2022, you were able to obtain up to eight free FDA-authorized COVID-19 OTC diagnostic test kits each month from a participating retail pharmacy or online through the Express Scripts® Pharmacy.

Effective on May 12, 2023:

• COVID-19 OTC test kits will no longer be available to you free-of-charge.  You will be responsible for the full cost of any OTC test kit that you purchase.  However, if you have a Health Care FSA, you may generally use your FSA funds to cover the cost of the OTC test kits.

COVID-19 Lab-Based Diagnostic Testing

During the PHE, your benefit plan waived cost share and medical management (including prior notification) requirements for certain COVID-19 lab-based diagnostic testing and the related medical visit.  This means that you were able to be tested for COVID-19 free-of-charge, regardless of where the test was performed (e.g., physician’s office, urgent care center or emergency room) or whether you received the test from an in-network or out-of-network provider.

 Effective on May 12, 2023:

• FDA-approved or authorized COVID-19 lab-based tests (and related services) that are ordered and rendered by a physician or health care provider will still be covered under your benefit plan, subject to any applicable copayment, deductible or coinsurance amount and medical management (including prior notification) requirements.

COVID-19 Medical TeleHealth Visits

During the PHE, you were able to access certain medical services from a covered provider via online video, chat or telephone, rather than a physical office visit.  Fixed-dollar copayments were not waived for these digital/telephonic visits, so your applicable payment was required just the same as if you had seen your provider in person.

 Effective on May 12, 2023:

• Medical telehealth visits will no longer be covered under your benefit plan.  Any claims for virtual medical telehealth visits occurring after May 11 will not be paid by the benefit plan.
• Note that the PHE did not affect your benefits available through Teladoc.  You may continue to access virtual medical telehealth visit benefits through Teladoc. 

COVID-19 Mental Health and Substance Use Disorder TeleHealth Visits

During the PHE, you were able to access mental health and substance use disorder care from a covered provider via online video, chat or telephone, rather than a physical office visit.  Fixed-dollar copayments were not waived for these digital/telephonic visits, so your applicable payment was required just the same as if you had seen your provider in person.

 Effective on May 12, 2023:

• Mental health and substance use disorder telehealth visits with a covered provider will continue to be covered under your benefit plan, subject to any applicable copayment, deductible or coinsurance amounts.
• Virtual counseling for mental health will also be available through Teladoc.  Additional details will be provided.  Please check https://yourtracktohealth.com for further information.

Administrative Deadlines

During the National Emergency, certain administrative timeframes and deadlines were delayed until the earlier of (1) one year from the date of the applicable deadline (determined on an individual basis), or (2) 60 days after the end of the National Emergency.  This period during which the deadline is delayed is referred to as the “Outbreak Period.”  The Outbreak Period extended the following administrative deadlines:
• 60-day election period for COBRA continuation coverage.
• Special enrollment period under HIPAA (which includes special enrollment rights due to loss of eligibility for Medicaid or CHIP coverage).
• COBRA continuation coverage premium payment due date.
• Deadline for COBRA continuation coverage qualified beneficiaries to notify the applicable plan(s) of a qualifying event or determination of disability.
• Deadline for a plan to provide COBRA continuation coverage election notices.
• Claims and appeals filing deadlines (including a request for an external review of claims).

Effective on June 10, 2023 (or as of a later date declared by the regulatory agencies):

• The delay of administrative deadlines will no longer apply and the applicable timeframes and deadlines specified in the applicable plan’s summary plan description will resume.

If you have any questions regarding these changes, please contact:

For Medical Benefit Questions:
• Your Track to Health 24/7 Nurses & Health Specialists: 1-866-735-5685 (toll free) 24 hours a day, 7 days a week
• Aetna: 1-833-327-2386 (toll free) 24 hours a day, 7 days a week
• Highmark/Blue Cross Blue Shield: 1-866-267-3320 (toll free) Mon-Fri 8 a.m.-8 p.m. ET
• UnitedHealthcare: 1-800-842-5252 (toll free) Mon-Fri 8 a.m.-8 p.m. ET 

For Behavioral Health and Mental Health and Substance Use Questions:
• United Behavioral Health:  1-866-850-6212 (toll free) 24 hours a day, 7 days a week

For Prescription Drug Benefit Questions:
• Express Scripts:  1-800-842-0070 (toll free) 24 hours a day, 7 days a week 

For Teladoc Questions:
• Teladoc:  1-800-Teladoc (835-2362)