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The COVID-19 Public Health Emergency Is Ending – Is Revenue Cycle Ready?

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Hemant Apte, Chief Executive OfficerApril 04, 2023
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As of May 11, 2023, the COVID-19 public health emergency (the PHE) is ending in the United States. While many are breathing a sigh of relief, revenue cycle professionals will be navigating a potentially confusing mix of shifting reimbursements and waivers, some of which support a decision to outsource medical billing. 

For example, the extension of telehealth services during the PHE has been extended through the end of 2024 (as part of the Consolidated Appropriations Act) but the continuous enrollment provision from the PHE ended on March 31, 2023. And this is just at the federal level. Many waivers and reimbursements are subject to state decisions and management. 

So, what does this mean for revenue cycle leaders? First, make sure you’re taking time to understand your specific starting point. CMS has published a list of 16 fact sheets, and it will be worth reviewing the one that applies to you (for example, some options are available for home health, hospitals, or durable medical equipment) [1]. 

Beyond this, now is a good time to start reviewing your patient mix. Facilities with a large proportion of Medicaid users will see more disruption than those who don’t. This is because, since March 2020, continuous coverage has been required and terminations were barred, but as of April 1, 2023, states are reviewing eligibility, meaning families and individuals could be thrown off the roles and might need support in maintaining coverage. 

At the same time, it’s worth being mindful of internal disruption. Your employees will likely be impacted by the end of the PHE, from vaccine access to benefits that are available to friends and family, so consider a few conversations to make sure you understand how your staff might be affected. 

But ultimately, this change is right around the corner and might be too much to handle for revenue cycle leaders who already have enough to deal with. The vast majority of RCM leaders should look for areas where options to outsource medical billing can ease their work and free them up to manage the sea of change that’s on the horizon in the healthcare revenue cycle.

[1] U.S. Centers for Medicare & Medicaid Services, "Coronavirus waivers & flexibilities," 23 February 2023. Available: https://www.cms.gov/coronavirus-waivers.

Hemant Apte, Chief Executive Officer

Hemant Apte is the Founder and CEO of 3Gen Consulting, a leading healthcare revenue cycle management and technology company serving providers, ACOs, and health plans across the U.S. Since founding 3Gen in 2006, Hemant has guided the company’s evolution from a boutique consulting firm into a data-driven organization at the forefront of AI-powered RCM innovation. With decades of experience in U.S. healthcare operations, Hemant continues to provide thought leadership to clients navigating financial, compliance, and technology challenges in an increasingly value-based care environment.

Is Your Revenue Cycle Ready for the End of the PHE?

Learn how to navigate post-pandemic reimbursement shifts and minimize revenue disruption.

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Connect with our experts to:

  • Review post-PHE billing changes
  • Identify revenue risks early
  • Simplify transitions with outsourcing

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FAQs

The FAQ section simplifies key information about 3Gen Consulting’s services, helping partners navigate our offerings, methodologies, and value.

Talk to an ExpertTalk to an Expert

It marks the rollback of temporary waivers, rate adjustments, and coverage provisions that supported billing flexibility during the pandemic.

As continuous coverage ends, expect eligibility reviews and disenrollments, creating billing delays and higher claim denials.

Yes. The Consolidated Appropriations Act extended many telehealth flexibilities through the end of 2024.

Audit your payer contracts, review CMS fact sheets by specialty, and update workflows for changing coverage rules.

Outsourcing adds bandwidth, stabilizes collections, and ensures compliance amid changing payer requirements.

3Gen offers expert billing teams, AI-powered tools, and flexible staffing to help providers adapt quickly and maintain revenue continuity.