The Biden administration announced late Monday that the public health emergency (PHE) will officially end on May 11, 2025. This announcement is a major development for the behavioral health sector, as the end of public health emergency behavioral health provisions will usher in significant regulatory changes. Over the past three years, the PHE dramatically reshaped how behavioral health services are delivered, including expanded access to telehealth and medication-assisted treatment (MAT).
“The COVID-19 national emergency and public health emergency were declared by the Trump Administration in 2020,” the White House Office of Management and Budget said in a statement. “They are currently set to expire on March 1 and April 11, respectively. At present, the administration’s plan is to extend the emergency declarations to May 11, and then end both emergencies on that date.” This extension aligns with the administration’s commitment to provide at least 60 days’ notice prior to termination, helping providers prepare for the end of public health emergency behavioral health changes.
How the PHE Changed Behavioral Health Care
The PHE fundamentally transformed behavioral health care delivery. Telehealth quickly became a primary mode of care, ensuring patients continued receiving essential mental health and substance use services. Access to MAT, including initiation of buprenorphine and methadone treatments, also expanded during this period, allowing providers to reach patients remotely.
Medicaid coverage extended to millions of vulnerable Americans, which prompted many behavioral health operators to expand services and pilot innovative programs to address mental health and addiction crises. “During the PHE, the Medicaid program has operated under special rules to provide extra funding to states to ensure that tens of millions of vulnerable Americans kept their Medicaid coverage during a global pandemic,” the administration said. “In December, Congress enacted an orderly wind-down of these rules to ensure patients did not lose access to care unpredictably and that state budgets don’t face a radical cliff. If the PHE were suddenly terminated, it would sow confusion and chaos into this critical wind-down.”
Telehealth and MAT: Permanent Changes
Telehealth has emerged as one of the most significant long-term impacts of the PHE. In November 2024, the Centers for Medicare & Medicaid Services (CMS) finalized rules permanently covering certain telehealth services for Medicare beneficiaries in their homes. Research from the Kaiser Family Foundation indicates that most state Medicaid programs plan to maintain telehealth coverage for behavioral health services even after the end of public health emergency behavioral health measures.
Flexibilities for MAT also played a critical role. Providers were able to initiate OUD treatments remotely, reducing barriers and expanding access. At the end of 2024, the federal government proposed rules to extend these flexibilities further, allowing physicians to provide both buprenorphine and methadone-assisted treatments via telehealth. Additionally, the Mainstreaming Addiction Treatment (MAT) Act, signed into law on Dec. 29, 2024, made some of these telehealth provisions permanent, ensuring continuity of care beyond the PHE.
Medicaid Coverage: Challenges and Opportunities
The end of public health emergency behavioral health may affect Medicaid coverage, potentially impacting patient access to care. The Families First Coronavirus Response Act (FFCRA) prohibited states from disenrolling Medicaid beneficiaries during the PHE, but its expiration could leave many Americans without coverage. To mitigate this, CMS has proposed a special enrollment period for state and federal marketplaces, allowing individuals to select a plan 60 days before or 90 days after losing Medicaid coverage.
The proposal also includes measures to improve access to behavioral health care, including designating mental health facilities and substance use disorder treatment centers as essential community providers (ECPs). These changes aim to ensure patients continue receiving care even as temporary PHE protections expire.
What Providers Should Know
Behavioral health providers must now prepare for the end of public health emergency behavioral health provisions while adapting to the permanent regulations. Key steps include:
- Updating administrative and billing processes as temporary PHE rules are phased out
- Maintaining and enhancing telehealth infrastructure to ensure continuous patient access
- Guiding patients through Medicaid coverage transitions and state marketplace options
- Adhering to updated MAT protocols while taking advantage of permanent telehealth flexibilities
While these changes present challenges, they also offer opportunities for providers to advocate for permanent policies that improve access and continuity of care.
Global Context and Looking Ahead
Even as the U.S. prepares to end its PHE, the World Health Organization (WHO) continues to classify COVID-19 as a global public health emergency. This emphasizes the need for ongoing adaptability in healthcare policy and delivery, particularly in behavioral health.
Ultimately, the end of public health emergency behavioral health represents both a transition and a chance to solidify gains from the past three years. Telehealth, expanded MAT access, and Medicaid innovations have reshaped the landscape, and providers now have the opportunity to build a more resilient, accessible, and patient-centered behavioral health system.
