Out of every crisis comes change — nowhere has this been more obvious than in healthcare.

In response to the COVID-19 pandemic, a wide range of new policies and flexibilities were introduced to reduce the burden on overworked healthcare workers, respond to patient needs and help clinicians and staff adapt to the fast-changing environment.

With the world carefully navigating its way out of this health crisis, these policies may soon be rolled back. In the United States, the Department of Health and Human Services’ (HHS) public health emergency declaration is due to expire as early as October 2022. 


While patients’ and providers’ preferences suggest that telehealth will remain a significant part of healthcare moving forward, the landscape remains uncertain. Many flexibilities allowed during the pandemic might be rolled back unless made permanent, including the expanded list of healthcare providers eligible to offer telehealth services, reimbursements for such services and the good faith use of video chat applications such as FaceTime, Zoom and Skype for virtual visits.

Expanded coverage

Analysts estimate that up to 15 million needy adults and children could lose insurance coverage for healthcare once pandemic policies are rolled back. This will require states to begin preparations for coverage expansions to avoid a pandemic of poverty from a lack of access to proper medical care.

Provider financial supports

Financial support for healthcare providers played a crucial role in supporting hospitals and providers with inpatient care and costs. As funding ends, hospitals and other providers must be prepared to return to usual operations without such support and contend with long-term changes in patient volume, costs and revenue. They will also need to prepare for potential audits to ensure that COVID-19 claims and conditions were properly met.

Other provider waivers and flexibilities

Aside from telehealth flexibilities, the pandemic also made way for other emergency blanket waivers for healthcare providers. These include modified care management policies, alternate care sites, expanded provider capacity and workforce and modified reporting and appeals requirements. While some flexibilities could be extended through rulemaking, providers will need to begin preparing for the rollback of some waivers and consider changes in protocols for the care of COVID-19 patients, changes in staffing and licensing, reconfiguration of care spaces and changes in how certain services are billed. 

Emergency use authorisation and other product access authorisations

In response to the pandemic, steps were taken to expedite access to vaccines, therapeutics, tests and other medical products used to prevent and treat infections. Once pandemic policies are no longer in place, medical device and product manufacturers and sponsors will likely need to adhere to different authorisation and clearance rules. Likewise, healthcare providers that have relied on vaccines, therapeutics and medical devices will need to pay close attention to which products continue to be available and for how long.  

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