The federal Public Health Emergency expired at the end of the day on May 11, 2023. For ASCs, the meaningful question is not what changed at midnight. It is what the next 90 days look like, and whether the work of returning to pre-pandemic operations is being documented in a way that will survive a survey 18 months from now.
Three years of accommodations do not unwind in a press release. Below is a practical sequence for the first quarter post-PHE.
Days 1 to 30: retrain to pre-pandemic protocols
Every clinical staff member hired since March 2020 was onboarded into a workflow shaped by waivers. For many of them, the post-PHE protocols are not a return to normal but an introduction to a normal they have never worked under.
The retraining list is not glamorous, but it is concrete:
- Verbal order authentication and countersignature timing
- Pre-op H and P timing, including the 30-day update requirement
- Visitor and escort policies that were modified during the pandemic
- PPE use outside of universal masking, including risk-based donning
- Infection prevention rounds and the standard surveillance cadence
- Medication administration documentation timing
Each topic needs an attestation, a date, and a verifiable record. Training that lives in a manager inbox is training that did not happen, from a surveyor perspective.
Days 1 to 45: audit every temporarily-issued privilege
Disaster privileges, emergency credentialing, and waiver-extended appointments all need an explicit disposition. The four possible outcomes:
- Full credentialing completed, privileges converted to standard appointment
- Temporary privileges expired and provider is no longer practicing at the center
- Temporary privileges formally terminated with documentation
- Active disaster privileges still in place this is the bucket that creates exposure
The fourth bucket should be empty by the end of day 45. Any provider still operating under disaster privileges after that point is operating under an authority that no longer exists.
Quick win
Run a roster of every provider with any temporary, disaster, or emergency privilege type granted since March 2020. Assign each one a disposition owner and a target close date. Do this in week one.
Days 30 to 60: close out COVID-specific incident logs
COVID-specific event tracking exposure notifications, staff isolation logs, patient screening positive results, surge staffing decisions was a parallel reporting stream for three years. It is now neither required nor abandonable. The events that occurred during that period are still part of the QAPI record and still subject to subpoena and survey review.
Close the parallel stream into the standard incident reporting system. Tag the historical events so they are searchable. Do not delete them, and do not leave them in a side spreadsheet that the person who maintained it took with them when they left.
Days 60 to 90: update emergency preparedness, on the merits
This is the step centers are most likely to defer, because the COVID waivers technically ended and the temptation is to declare emergency preparedness done. It is not done.
The CMS Emergency Preparedness rule has not gone anywhere. The annual training, the two exercises per year, and the all-hazards risk assessment are all still required. What has changed is the depth of recent experience to draw on. Your 2023 risk assessment should reflect three years of actual evidence about supply chain interruption, staffing surge, IT continuity during remote operations, and communication failures. The plan written in 2019 does not reflect what your center now knows.
Specifically, the after-action review of pandemic operations belongs in the EP plan. Not as a COVID appendix, but woven into the all-hazards framework. The next disruption will not be a respiratory pandemic. The lessons are about response capability, not pathogen specifics.
What this looks like in 90 days
By August 11, a well-run center will have documented retraining for every clinical FTE, a closed disposition on every temporary privilege, a clean migration of COVID-specific incidents into the standard tracking system, and an updated EP plan that reflects post-pandemic reality. Anything less than that will not produce a citation tomorrow. It will produce one in 2024 or 2025, when a survey team asks for the evidence and it does not exist.
How DocForms helps
Learning Management handles the assignment, completion tracking, and attestation for retraining the entire clinical roster on post-PHE protocols. Completion is auditable per user, per module, per date.
Staff Records consolidates competencies, licenses, and training attestations into a single per-person record that does not depend on whichever manager owned the spreadsheet.
Incident Reporting brings the COVID-era parallel logs into the standard QAPI-aligned event stream, with tagging that preserves the historical context without leaving the events stranded in a side system.
Emergency Preparedness support keeps the annual risk assessment, training, and exercise documentation on a defensible cadence, so the 2023 update is a structured revision rather than a rebuild.