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Provider Notice Issued 12/18/2020

Date:    December 18, 2020

 

To:       All Medical Assistance Program Providers

 

Re:      COVID-19 Treatment and Testing Billing Guidance for Uninsured and Insured Patients

 

 

This notice reminds providers of COVID-19 testing and treatment billing instructions issued in a May 18, 2020 provider notice, including provider billing guidance for submitting claims to the appropriate COVID-19 reimbursement program for uninsured patients. As a reminder, providers should not bill uninsured patients for COVID-19 testing, COVID-19 testing-related services, or COVID-19 treatment.

 

It has come to the attention of HFS that some providers are charging uninsured Illinois residents for COVID-19 testing and treatment. Providers should immediately stop these practices and bill claims to the appropriate uninsured COVID-19 reimbursement program, as described below. These reimbursement programs are available regardless of citizenship or immigration status and there is no income limit for reimbursement; income only impacts which program should be billed. Further, providers should reimburse uninsured patients who have paid out-of-pocket for COVID-19 testing and treatment and seek reimbursement through the programs described below instead.

 

Uninsured patients who receive provider bills for COVID-19 treatment or testing can call HFS directly for help at 877-805-5312 and select nine (9) to report that they received a COVID-19 bill. If HFS determines the provider billed the uninsured patient instead of the appropriate uninsured reimbursement program, HFS staff will call the provider and instruct the provider to reimburse the patient and bill the appropriate uninsured COVID-19 program for reimbursement. 

 

 Billing for COVID-19 Treatment

 

In general, if the patient is uninsured, providers should seek reimbursement for COVID-19 treatment from the U.S. Health Resources and Services Administration (HRSA) instead of billing the uninsured patient; this program reimburses regardless of income, citizenship, or immigration status. If the uninsured patient may be eligible for Medicaid or the Illinois Emergency Medical for Noncitizens program, the provider can help the patient apply for those programs, which also cover COVID-19 treatment costs and more.

 

Providers are eligible for reimbursement for COVID-19 treatment for all patients who are Illinois residents regardless of income, citizenship, or immigration status as described below. As such, there is no scenario in which a provider should bill the patient for COVID-19 treatment services in lieu of billing the appropriate uninsured reimbursement program or insurer.


HRSA Uninsured COVID-19 Reimbursement Program

Regardless of income, citizenship, or immigration status, the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured program reimburses providers at Medicare rates for providing COVID-19 treatment, testing, and testing-related services to uninsured patients. 

 

COVID-19 treatment services reimbursed by the HRSA program include office visits (including telehealth), emergency room, inpatient, outpatient/observation, skilled nursing facility, long-term acute care (LTAC), acute inpatient rehab, home health, DME (e.g., oxygen, ventilator), emergency ambulance transportation, non-emergent patient transfers via ambulance, and FDA approved drugs as they become available for COVID-19 treatment when administered as part of an inpatient stay.

 

For reimbursement, providers should submit claims to the HRSA COVID-19 Claims Reimbursement Portal. The date of service must be on or after February 4, 2020. Uninsured individuals should not be charged for these services.

 

The HRSA program does not cover: services that traditional Medicare does not cover, any treatment without a COVID-19 primary diagnosis, expect for pregnancy when the COVID-19 diagnosis may be listed as secondary, hospice services, or outpatient prescription drugs.

 

Illinois’ Emergency Medical for Non-Citizens Program

A diagnosis or suspicion of COVID-19 qualifies as an emergency for non-citizens who otherwise meet federal adult Medicaid eligibility criteria except for immigration status. As a result, providers also have the option of helping these patients apply for Emergency Medical through ABE.Illinois.gov. Information on medical documentation requirements for this application can be found in the COVID-19 Emergency Medical for Non-Citizens policy memo. If the application is approved, providers can then bill Medicaid for payment of COVID-19 treatment. Emergency Medical coverage is authorized for an initial 60 days from the start date of coverage but can be extended beyond 60 days. If the application is not approved, providers should bill the HRSA uninsured program for COVID-19 treatment services, as described above.

 

COVID-19 Treatment Reimbursement for Insured Patients, including Medicaid

For insured patients, including patients who are insured through Medicaid, Medicare, commercial insurance, and employer-sponsored insurance, providers should submit claims to the patient’s insurer for reimbursement for COVID-19 treatment. Many insurers have waived cost-sharing for COVID-19 treatment and testing. 

 

Billing for COVID-19 Testing and Testing-Related Services

 

Health care providers should provide COVID-19 diagnostic testing and testing-related services free of charge to all uninsured Illinois residents, regardless of income, citizenship, or insurance status or immigration status, and HFS has a new eligibility category to reimburse providers for these services. For individuals with insurance, providers should bill the insurer, and should not charge deductibles, co-pays, or co-insurance for medically necessary testing and testing-related services.

 

HFS Uninsured COVID-19 Testing Program

HFS is implementing the Uninsured COVID-19 Testing Program created in the federal Families First Coronavirus Response Act (Families First Act). This program reimburses providers for COVID-19 testing and testing-related services provided to uninsured individuals on or after March 18, 2020. In Illinois, reimbursement through this program is available regardless of income, citizenship, or immigration status.


HFS will reimburse providers for COVID-19 testing and testing-related services at Medicare rates, when the code is listed on the HFS COVID-19 Fee Schedule, regardless of whether the service is provided via telehealth or face-to-face. Any codes not included on the COVID-19 Fee Schedule will be reimbursed at Medicaid rates. 

 

Testing and testing-related services covered under the HFS Uninsured COVID-19 Testing Program include in vitro diagnostic products, as defined by the Food and Drug Administration (FDA), for the detection or diagnosis of COVID-19, including the COVID-19 rapid test, serological tests to detect antibodies, and the evaluation of an individual to determine the need for a COVID-19 test. Reimbursement is provided regardless of whether the COVID-19 test result is positive or negative.   

 

The Department is deploying an online portal that allows providers to bill for COVID-19 testing and testing-related services for Medicaid fee-for-service customers and all uninsured Illinois residents, regardless of income, citizenship, or immigration status, with dates of service beginning March 18, 2020. Claims for Medicaid managed care members should be billed to the appropriate Medicaid managed care health plan. Providers should refer to the September 25, 2020 provider notice for guidance on how to prepare to use the online portal as soon as it is launched.

 

HRSA Uninsured COVID-19 Reimbursement Program

The HRSA COVID-19 Claims Reimbursement Portal is also available to providers and provides reimbursement for uninsured patients at Medicare rates. This program is available when another payer or government program is not available for reimbursement.

 

Illinois providers should use the HRSA portal for COVID-19 testing and testing-related services for uninsured patients with dates of service between February 4 and March 17, 2020. As noted above, providers should also use the HRSA uninsured program for reimbursement for COVID-19 treatment since treatment is not covered under the HFS COVID-19 Testing Program. The HRSA reimbursement portal is available regardless of income, citizenship, or immigration status.

 

COVID-19 Testing Reimbursement for Insured Patients, including Medicaid

For insured patients, including patients who are insured through Medicaid, Medicare, commercial insurance, and employer-sponsored insurance, providers should submit claims for COVID-19 testing and testing-related services to the patient’s insurer. Providers should not charge any deductibles, co-pays, or cost-sharing to the patient for medically necessary COVID-19 testing services in accordance with the federal Families First Act, as amended by the federal Coronavirus Aid, Relief, and Economic Security (CARES) Act.

 

Individuals with short-term limited duration insurance are eligible for enrollment in the HFS Uninsured COVID-19 Testing Program. Additionally, details on COVID-19 testing coverage under the Illinois Medicaid program were first released in a March 13, 2020 provider notice.

 

Questions regarding the information provided above may be directed to the Bureau of Professional and Ancillary Services at 877-782-5565.

 

 

Kelly Cunningham, Administrator

Division of Medical Programs

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