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
