Public Health

Page Updated: March 11, 2024

CHA Advocacy Principle: Support planning for future public health emergencies and leverage lessons learned during the COVID-19 pandemic.

What Has Been Completed:

Origin: On May 11, 2023, the COVID-19 public health emergency (PHE) expired. The formal PHE declaration includes numerous regulatory flexibilities to support hospital capacity.

Background: The PHE was first declared in January 2020. Both state and federal agencies released guidance regarding the wind-down of the PHE.

Public Health Orders: All public health orders have been terminated but some requirements have been made permanent through rulemaking. Hospitals are still required to maintain an infectious disease mitigation, vaccine, and treatment plan as well as report hospital bed capacity data to state and federal partners. Additionally, on May 31, 2023, CMS released a final rule that rescinds the health care worker vaccine mandate. Additional information can be found in CHA’s June 2023 Regulatory Update. 

Telehealth: CHA successfully advocated to include an extension of pandemic-era telehealth flexibilities in the 2023 federal spending bill. Subsequently, core telehealth flexibilities will extend through December 2024. HHS has a list of permanent Medicare changes, changes authorized through December 2024, and temporary changes. 

Outstanding Items: 

Medicaid Redetermination: Colorado is facing a Medicaid enrollment cliff that could result in hundreds of thousands of Coloradans losing health care coverage when the federal Medicaid enrollment provisions tied to the federal PHE evolve beginning in April. Starting April 1, the federal government decoupled Medicaid enrollment from the end of the PHE. In Colorado, HCPF will be responsible for completing renewals for the approximately 1.6 million Coloradans currently enrolled in Colorado’s Medicaid Program. The redetermination effort will be a massive undertaking, and more than 700,000 Colorado residents could lose access to Medicaid and Child Health Plan Plus coverage. Colorado hospitals continue to partner with HCPF to share messaging to ensure that Health First members update their addresses and are not inadvertently disenrolled due to administrative barriers.

Resources: 

• • Executive Brief on the End of the PHE
  • AHA Resources on the end of the PHE
  • CMS Resources on the end of the PHE
  • CHA’s Emergency Preparedness Regulatory Compliance Page
  • CMS Coronavirus Flexibility Waivers
  • CMS PHE Inquiry Training
  • CDPHE’s Public Health Order Page 

Meetings/Dates of Note:

CHA Staff Contact: Megan Axelrod, CHA director of regulatory policy and federal affairs, [email protected]