The PHE Ends May 11. Here is What ASCs Should Be Doing Now.

The federal Public Health Emergency expires on May 11, 2023. For ambulatory surgery centers that have spent three years operating under blanket Section 1135 waivers, the wind-down is not a single switch. It is a methodical reversal of dozens of small accommodations that quietly became standard practice.

The risk is not that any one waiver expires. The risk is that something a clinical team has been doing since April 2020 is no longer permissible on May 12, and nobody noticed because the policy that authorized it was never formally rescinded.

Step one: inventory what you actually used

Most ASCs invoked more waivers than they remember. The list to walk through, department by department, includes at minimum:

• Verbal order authentication timelines (the 48-hour countersignature requirement)
• Emergency credentialing and disaster privileges granted to locum or temporarily reassigned providers
• Pre-operative history and physical timing, and the 30-day H and P update
• Telehealth use for pre-op and post-op visits
• Suspended QAPI reporting cadences and paused infection prevention logs
• CLIA waivers for point-of-care testing locations
• Modified medical record signature timing

For each one, the question is the same. Did we use this? Where is the policy document that authorized the deviation? When does that policy revert, and who signs off?

Step two: revert the policies, not just the practices

Surveyors do not ask whether a center stopped doing something. They ask to see the policy that governs the current practice and the evidence that staff have been trained on it. A center that quietly resumed 48-hour verbal order countersignatures on May 12 but never retired the COVID-era policy permitting 96 hours has a finding waiting to happen.

Every waiver-era policy needs one of three dispositions: rescinded, revised to remove the temporary language, or retained with a clear effective-date stamp showing the deviation period ended. Anything ambiguous will be read against you.

Step three: re-anchor credentialing

Disaster privileges and emergency credentialing were a lifeline in 2020 and 2021. They were also, by design, a documentation shortcut. Centers that granted temporary privileges under the waiver framework need to either complete full credentialing on those practitioners or formally terminate the privileges. Leaving disaster privileges active after the underlying authority expires is a survey-cycle problem and a liability problem.

The same goes for any expiration dates that were administratively extended. Licenses, BLS, ACLS, PALS, fit testing, and competency assessments that were rolled forward under pandemic flexibilities need to be brought current and re-anchored to verified source documents.

Step four: restart what was paused

Compliance logs that went dormant are the easiest to overlook. Hand hygiene audits, environmental rounds, temperature logs for medication storage, sterilization biological monitoring, eyewash station checks any of these that lapsed need to resume on a documented schedule before survey teams notice the gap. A six-month silence in a log book is harder to defend than a finding written into a corrective action plan.

Step five: train and document

Reverting a policy without retraining staff is the same as not reverting it. Every clinical team member who has been operating under pandemic-era flexibilities needs documented attestation that they have read and understood the post-PHE protocols. This is the piece centers are most likely to skip and most likely to be cited for.

How DocForms helps

Policies and Procedures gives you a single source of truth for which version of which policy is active, with effective dates and revision history. Filtering for pandemic-era edits and routing them through review and sign-off is a contained workflow rather than a six-tab spreadsheet exercise.

Credentialing and Privileging surfaces every disaster privilege, temporary appointment, and administratively extended expiration in one view, so the post-PHE re-anchoring is a worklist rather than an archaeology project.

Compliance Logs tracks recurring obligations and flags gaps. The logs that quietly stopped in 2020 are the ones that need a documented restart date and an owner, both of which the module enforces.