THE END OF THE PUBLIC HEALTH EMERGENCY

BY MARIA GONZALEZ CHAVEZ, Pharm.D. Candidate 2023, Ferris State University

The end of the federal Public Health Emergency (PHE) declaration for COVID-19 is rapidly approaching, leaving many questions. In February, the Department of Health and Human Services (HHS) announced the PHE would end on May 11, 2023. The announcement cites the Biden administration’s COVID-19 vaccination efforts and the decrease in daily COVID-19 reported cases, hospitalizations and deaths as evidence the time has come to return to normal. This has left many wondering how this will affect many public health changes enacted by PHE, such as vaccines, treatment and tests for COVID-19.

COVID-19 vaccines and boosters will remain free of charge – with a caveat. The federal government purchased vaccines to stockpile. The vaccines will continue to be free until the federally-purchased supply runs out, or if there are any changes to vaccine recommendations.

For example, a new formula booster for the fall would not be covered by the government but would still be covered under private or public insurance. Unfortunately, this may leave the underinsured vulnerable. Similarly, COVID-19 treatments like Paxlovid™ will still be available while the federal stockpile remains. Because the government recently purchased a significant amount from Pfizer, this stockpile will likely last through the end of 2023. After the government supply is gone, it will transition to the commercial market. Again, those with private or public insurance will continue to have access to it, albeit with a copay.

Lastly, at-home COVID-19 antigen tests will also be affected by the end of the PHE. Insurers will no longer be required to cover at-home tests. Private insurers, including Medicare Advantage plans, may continue to cover the at-home tests.

Traditional Medicare will not cover these tests. For those with Medicaid, at-home tests will remain covered completely through September 2024.

Another area that will be affected is controlled substance prescribing. Prescribers with a valid DEA license could prescribe controlled substances (Schedule 2-5) via telehealth visits. Once the PHE ends, this flexibility will end and in-person visits will be required. However, the DEA has issued a proposed rule allowing practitioners to prescribe controlled medications via telemedicine without an in-person visit under limited circumstances. The rule is not in effect and will go before public comment.

How will this affect pharmacies?

• Food and Drug Administration (FDA) Emergency Use Authorizations (EUA) for vaccines and COVID-19 treatments will not be affected because they are not dependent on the HHS Public Readiness and Emergency Preparedness (PREP) Act. Patients can continue to receive COVID-19 vaccines and therapies at no cost while the federal stockpile remains.

• At-home COVID-19 tests will be covered for Medicaid recipients through September 2024. For those with private insurers, costs may vary. This is the same case for pharmacist-provided COVID-19 testing.

• The end of the PHE also signals the impending end of the PREP Act, which is set to expire in October 2024. Pharmacists are qualified persons under PREP Act, providing pharmacists, student pharmacists and technicians with liability coverage to order and administer COVID therapeutics. Access liability coverages under the PREP Act may be affected by the end of the PHE. This may affect pharmacists’ ability to order and administer COVID-19 therapeutics.

• Medicaid patients may have their coverage affected as Michigan restarts Medicaid eligibility renewals starting April 2023. Patients must prepare for eligibility renewals by ensuring their contact information is current (address, register with MI Bridges, contact MDHHS office for renewal packet).

References available upon request