Many areas of the country are experiencing resurgences of COVID-19, and it is foreseeable that second and perhaps third waves of the virus will hit pockets of the country throughout the remainder of 2020. As healthcare organizations struggle to balance their continued response efforts to the pandemic, with preparations for future waves, we have received many questions from provider organizations regarding how best to prepare their organizations.

The situation is further complicated by an impending expiration of the Public Health Emergency Declaration (under Section 319 of the Public Health Service Act), which served as a catalyst for many of the relaxed regulatory requirements that enabled providers to quickly go-to-market with telehealth services (e.g. relaxation of HIPAA requirements, etc.). Given the current political environment, we believe provider organizations should be prepared for the expiration of the Public Health Emergency Declaration on July 25, 2020; and, even if there is an extension, the termination of the emergency will likely occur in the next couple of months...