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COVID-19

HHS’s New Reimbursement Program for Uninsured COVID-19 Patients

By Chris Emper

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As a result of the March 2020 CARES Act and the Provider Relief Fund it established, in April the U.S. Department of Health and Human Services (HHS) announced the launch of a new program to provide claims reimbursement to healthcare providers for testing uninsured individuals for COVID-19 and treating uninsured individuals with a COVID-19 diagnosis.

To participate in the program, providers must enroll through HHS’s designated portal, check patient eligibility, submit patient information and claims, and agree to receive payment via direct deposit. HHS will pay eligible claims at Medicare rates.  

What’s Covered

For dates of service or admittance on or after February 4, 2020, providers will be eligible to seek reimbursement for COVID-19 testing and testing-related visits for uninsured individuals, as well as treatment for uninsured individuals with a COVID-19 diagnosis. Reimbursement will be made for qualifying testing for COVID-19 and treatment services with a primary COVID-19 diagnosis as determined by HRSA, which include the following:

  • Specimen collection, diagnostic, and antibody testing
  • Testing-related visits including in the following settings: office, urgent care, emergency room, or telehealth
  • Treatment, including office visit (including telehealth), emergency room, inpatient, outpatient/observation, skilled nursing facility, long-term acute care, acute inpatient rehab, home health, DME, ambulance transportation, and FDA approved drugs as they become available for COVID-19 treatment and are administered as part of an inpatient stay
  • FDA-approved vaccine, when available

Services not covered by Medicare will not be covered under this 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

For dates of service or discharges on or after April 1, 2020, providers must use primary diagnosis ICD-10 code U07.1 to indicate COVID-19 is the primary reason for treatment. Detailed information and a full list of eligible diagnostic and billing codes can be found here.  

All claims will be subject to the same timely filing requirements required by Medicare and all claims submitted must be complete and final. Interim bills, corrected claims, late charges, voided claim transactions, and appeals will not be accepted under this program.

For Federally Qualified Health Centers (FQHCs) and other providers that need to submit cost reports, payments received under this program should be treated in the same manner as claims reimbursements received from other payers (commercial, Medicaid, Medicare).   

Who’s Covered 

Uninsured individuals in the United States without healthcare coverage are eligible. A patient is considered uninsured if the patient does not have coverage through an individual or employer-sponsored plan, a federal healthcare program, or the Federal Employees Health Benefits Program at the time the services were rendered.

In the course of determining insurance status, providers may submit a claim for uninsured individuals before a Medicaid eligibility determination is complete. However, if the provider learns that an individual is retroactively enrolled in Medicaid as of the date of service, the provider must return any payments received for that patient.

To document patient eligibility, providers will need to submit unique identifiable information about uninsured individuals as specified by HRSA here.  

Within HHS, the program is being run the Health Resources and Services Administration (HRSA) and has been officially labeled the “HRSA COVID-19 Uninsured Program.” To participate, providers must sign an initial attestation that they will accept the program reimbursement as payment in full and not balance bill patients for which claims are submitted under this program. Other terms and conditions also apply.  

The Bottom Line

From community health centers with large uninsured patient populations to multispecialty groups with primarily insured patients, this program offers physician practices across the country a significant opportunity to provide care for uninsured COVID-19 patients while getting paid to do so. And regardless of the size, specialty, or focus of a practice, during this crisis, every little bit helps – both for patients and physicians.

Practices interested in learning more about the program should view HRSA’s program website here. 


Chris Emper

Government Affairs Advisor, NextGen Healthcare

Chris Emper, JD, MBA, is government affairs advisor at NextGen Healthcare and president of Emper Healthcare Advisors—a health IT industry advisory and consulting services firm in Washington, D.C. that specializes in helping healthcare providers and technology companies successfully navigate and comply with complex regulations and value-based reimbursement models. Prior to forming Emper Healthcare Advisors in 2016, Chris was vice president of Government Affairs at NextGen Healthcare (NASDAQ: NXGN) and Chair of the Electronic Health Record Association (EHRA) Public Policy committee…

Chris Emper, JD, MBA, is government affairs advisor at NextGen Healthcare and president of Emper Healthcare Advisors—a health IT industry advisory and consulting services firm in Washington, D.C. that specializes in helping healthcare providers and technology companies successfully navigate and comply with complex regulations and value-based reimbursement models. Prior to forming Emper Healthcare Advisors in 2016, Chris was vice president of Government Affairs at NextGen Healthcare (NASDAQ: NXGN) and Chair of the Electronic Health Record Association (EHRA) Public Policy committee.

An expert in The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), The Patient Protection and Affordable Care Act (ACA), and The 21st Century Cures Act, Chris is a frequent speaker at industry conferences and has written or appeared in articles in publications such as Politico, Health Data Management, Accountable Care News, and Medical Economics. From 2016-2019, Chris served as Chair of the HIMSS Government Relations Roundtable, a leading coalition of health IT government affairs professionals.

Prior to joining NextGen Healthcare in 2013, Chris served as a Domestic Policy Advisor for former Massachusetts Governor Mitt Romney’s 2012 Presidential Campaign, where he advised the campaign on policy issues including healthcare, technology, and innovation. He holds a law degree and an MBA from Villanova University and a BA from Boston College.

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