Looking Ahead as Public Health Emergency Winds Down

As discussion continues about how to extend the enhanced subsidies in the American Rescue Plan, which will expire at the end of 2022, there are calls for improving affordability of both premiums and out-of-pocket costs in marketplace plans. Lowering out-of-pocket costs by making Gold-level plans affordable could improve access to primary care, particularly for lower-income enrollees.
Many temporary COVID-19-related Medicare payment and other waivers are tied to the duration of the national Public Health Emergency (PHE). The American Rescue Plan (ARP) included temporary funding and other temporary policy changes that have significant implications for the primary care community. The table below lists and tracks some important expiration dates.



Public Health Emergency (PHE) declaration from Secretary of Health and Human Services

Renewed 4/21/21 for 90 days; expected to be renewed through CY 2021

Provisions of $1.9 trillion American Rescue Plan

Medicaid state option for 12 months postpartum

5 years beginning April 2022

Enhanced FMAP (85%) for optional state community mobile crisis intervention services

5 years beginning April 2022

Two year 5% FMAP incentive (on all Medicaid populations) for states that have not yet expanded Medicaid (on top of 6.2% FMAP if during PHE)

2 years after state enactment

COVID-19 vaccine coverage for Medicaid/CHIP 100% match; state option for uninsured coverage

End of first quarter after 12 months after end of PHE

Temporary expansion of ACA marketplace APTCs

Expire at end of CY 2022

$8.5 billion for new fund for rural providers to cover losses due to COVID-19

Funds available until expended (providers must apply)

$9.1 billion for public health workforce-related grants; $100 million for Medical Reserve Corps; $800 million National Health Service Corps; $200 million Nurse Corps; $330 million for Teaching Health Centers GME (THCGME) programs

FY 2021; available until expended;

All programs extended through FY 2023

Community Health Center funding of $7.6 billion

End of FY 2022

$1.5 billion for Community Mental Health Block Grants; $1.5 billion for Prevention and Treatment of Substance Abuse Grants

FY 2021; expended by 9/30/25

Consolidated Appropriations Act, 2021

Medicare 2% sequestration suspended through 3/31/21; Congress extended again in April 2021

Expires end of CY 2021

Medicare PAY-GO cuts of 4% to be triggered by ARP deficit spending unless Congress acts

Congress must act by 9/30/21

One-time 3.75% ($3 billion) bump in Medicare physician fees to mitigate offsets in 2021 Physician Fee Schedule

CY 2021

Postponed complex E&M codes for Medicare billing

Until 1/1/2024

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