The Families First Coronavirus Response Act, enacted on March 18, 2020, appropriated $1 billion to reimburse providers for conducting COVID-19 testing for the uninsured. In addition, part of the $100 billion Provider Relief Fund established by the Coronavirus Aid, Relief, and Economic Security Act, enacted on March 27, 2020, will be used to reimburse hospitals and other health care providers for expenses related to the treatment of uninsured individuals with COVID-19.
The Health Resources & Services Administration (HRSA) released guidance on the claims reimbursement process under the COVID-19 Uninsured Program (Program) and opened the COVID-19 Uninsured Program Portal. The timeline for implementation of the claims process is as follows:
- April 27 – Sign up period begins for the program
- April 29 – On Demand training starts
- May 6 – Begin submitting claims electronically
- Mid-May – Begin receiving reimbursement
Eligible claims include qualifying testing for COVID-19 and treatment services with a primary COVID-19 diagnosis, performed on or after February 4, 2020. This includes the following:
- Specimen collection, diagnostic and antibody testing.
- Testing-related visits, including in the following settings: office, urgent care, emergency room or via telehealth.
- Treatment, including office visit (including via telehealth), emergency room, inpatient, outpatient/observation, skilled nursing facility, long-term acute care, acute inpatient rehab, home health, DME (e.g., oxygen, ventilator), emergency ground ambulance transportation, non-emergent patient transfers via ground ambulance, and FDA-approved drugs as they become available for COVID-19 treatment and administered as part of an inpatient stay.
- FDA-approved vaccine, when available.
For inpatient claims, the date of admittance must be on or after February 4th. Services not covered by traditional Medicare will not be covered under the Program. In addition, the following services are excluded:
- Any treatment without a COVID-19 primary diagnosis, except for pregnancy when the COVID-19 code may be listed as secondary.
- Hospice services.
- Outpatient prescription drugs.
A provider on the U.S. Department of Health and Human Services, Office of the Inspector General list of excluded individuals/entities and/or any provider who has had their Medicare enrollment revoked by the Centers for Medicare & Medicaid Services is ineligible to receive funding, directly or indirectly, from the Program.
The HRSA has contracted with UnitedHealth Group to administer the Program. Claims must be submitted electronically and will generally be reimbursed at Medicare rates, subject to available funding. The required steps include: enrolling as a provider participant, checking patient eligibility, submitting patient information, submitting claims, and receiving payment via direct deposit. Providers will be required to attest to the following:
- The provider has checked for health care coverage eligibility and confirmed that the patient is uninsured.
- The provider will accept the Program reimbursement as payment in full.
- The provider agrees not to balance bill the patient.
- The provider agrees to the Program terms and conditions and acknowledges that payment is made subject to potential post-reimbursement audit review.
All claims submitted must be complete and final and no interim bills or corrected claims will be accepted. There will be no adjustments to payment once claims reimbursements are made. Additional information regarding reimbursement rates can be found here.
For additional guidance on this issue, please contact a Jackson Lewis attorney.