The End of the PHE and the Impact on Vaccine & COVID-19 Testing Costs

Originally Posted on PCG’s Health Policy News on March 30, 2023.


On January 31, 2020, Secretary Alex Azar of the US Department of Health and Human Services (HHS) declared a nationwide Public Health Emergency (PHE) related to the COVID-19 pandemic. For the past three years the PHE has been renewed every 90 days, but the expiration date is approaching on May 11, 2023. Last month, the Center for Medicare & Medicaid Services (CMS) issued the anticipated 60-day wind down notice. The notice outlined forthcoming changes to PHE policies as emergency provisions expire. The PHE granted a number of important health care flexibilities that have been imperative in combating the spread of the virus and ensuring Americans maintained their healthcare coverage. With the close of this chapter, many Americans will lose pandemic-era services, including access to free COVID-19 test kits, vaccinations, and treatments. In the sections below, expiring services are detailed and proposed next steps are addressed.  

Vaccine Costs  

Since the COVID-19 vaccine came on the market, the federal government has been purchasing doses from companies like Pfizer and Moderna below cost to encourage widespread vaccination against the virus. This federal investment allowed widespread access to vaccinations, regardless of their ability to pay or insurance status. As the end of the PHE approaches, the federal government has indicated that without further Congressional action they will reduce or cease COVID-19 vaccine purchasing. As the vaccines transition to the commercial market, Pfizer and Moderna could choose to raise prices; current pricing assumptions for Moderna are in the $110 to $130 dollar range per dose, and the same price range is expected for competitor Pfizer. No matter who pays the bill – consumers, employers, or insurers – if only half of US adults receive a booster shot, it is estimated that it will cost payers between $12.4 billion to $14.8 billion. This figure is almost twice as much as the average price paid by the federal government during the PHE. 

Public Insurance  

CMS clarified the implication of the end of the PHE for Medicare and Medicaid beneficiaries, with some continued vaccine and testing cost protection including:   

  • Free vaccines for Medicare and Medicaid recipients through September 30, 2024  
  • Test kits and treatments, without cost-sharing through September 30, 2024 
  • Medicare beneficiaries may face out-of-pocket costs for at-home COVID-19 test kits and treatments. However, they will still be able to receive lab-conducted COVID-19 tests at no cost through their health care provider.  

Private Insurance  

Given the preventive provisions in the ACA, those with employer-based or private insurance are likely protected from rising vaccines costs received from an in-network provider. Some possible cost implications for commercial insurance enrollees include: 

  • Enrollees could potentially be charged for COVID-19 lab tests, even if they are ordered and conducted by an in-network provider. 
  • Presently, there is still an official website operated by the Department of Health and Human Services (DHHS) where people can order four at-home test kits per household. 
  • Commercial health plans are required to cover the cost of eight at-home COVID-19 test kits.  

Implications for the Uninsured  

Those who are uninsured or underinsured are most at risk of paying high out-of-pocket costs for COVID-19 vaccinations, tests, and treatments. This is especially problematic given that the uninsured population is expected to rise with the end of the continuous enrollment provision that paused Medicaid redeterminations during the PHE. It is estimated that between 5 to 14 million people could lose healthcare coverage as a result of the Medicaid redeterminations process.  

As unwinding activities begin at the state and federal level in the coming weeks, it will be important to monitor how Americans are impacted. One possibility is that vaccination rates will drop as COVID-19 vaccines and boosters become less accessible from a cost perspective, especially for those who are uninsured or underinsured. Health Policy News will continue to monitor and report on the effects of these changes and how different populations are affected.  

Posted by PCG

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