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Billing and Cost Sharing for COVID-19 Vaccination, Testing, and Treatment

Before billing patients for COVID-19 vaccination, testing, or treatment, you should see if there are available reimbursement, funding, or compensation sources. This is a requirement of the Health Center Program. You should also look for any cost sharing restrictions or prohibitions. 

  • If there are out-of-pocket costs for a patient, and there are no contract restrictions or conditions of participation that explicitly prohibit patient cost sharing, apply your sliding fee discount(s) to these costs, consistent with your established policies and procedures. For example, in the case of no or only partial coverage by private insurance for testing or treatment that results in costs to the patient, you would apply your sliding fee discount(s).
  • If there are prohibitions on patient cost sharing, such as for vaccine administration fees, after you submit the patient’s claim for reimbursement to the applicable payor source(s), you would not charge the patient for any out-of-pocket costs.
  • You may use Health Center Program operational funding (H80) or COVID-19 supplemental funding for allowable costs related to COVID-19 vaccines, testing, and treatment that are not covered by payor sources. 

Review the table below for details about billing and patient cost-sharing for specific COVID-19-related services and supplies. This is not an exhaustive list. You are responsible for following the most recent requirements or restrictions for each payor source, program, and the terms and conditions of awards. Note: HRSA award recipients may not use Health Center Program grant funds for costs that are reimbursed or compensated by other federal or state programs. For additional questions, use the BPHC Contact Form.

COVID-19 Related Service or Supply Reminders for Reimbursement, Compensation, and Funding Sources Sliding Fee Applicability
Vaccine or Vaccine Administration

You cannot charge uninsured or underinsured adult vaccine recipients for vaccine that is provided free to your health center by the U.S. government such as through the CDC Bridge Access Program. This includes charging any administration fees, copays, or coinsurance. 

For patients with insurance coverage, you must seek reimbursement for COVID-19 vaccine-related costs by billing Medicare, Medicaid, CHIP, or other public and private insurance or assistance programs, as applicable.  

You may use HRSA Health Center Program operational funding (H80) or COVID-19 supplemental funding to support the administration of in-scope COVID-19 vaccines.

Not applicable – If you receive vaccine from the CDC Bridge Access Program, COVID-19 vaccines and their administration must be provided at no cost to all uninsured or underinsured vaccine recipients. 

For patients with insurance coverage through most private and public sources (Medicare, Medicaid and CHIP), you will provide vaccines and their administration at no cost (i.e., without patient cost-sharing).

Applicable if you do not participate in the CDC Bridge Access Program and  there are out-of-pocket costs for uninsured or underinsured patients related to COVID-19 vaccines and their administration.  You would apply your sliding fee discount(s) based on income and family size.

In addition, you may adjust your sliding fee and billing and collections policies (with board approval) or change your operating procedures in response to COVID-19. Such changes must be consistent with applicable statutory, regulatory, and policy requirements. These flexibilities may include but are not limited to:

  • Eliminating nominal charges for patients at or below 100% of the Federal Poverty Guidelines.
  • Expanding the circumstances you will consider when waiving or reducing fees or payments due to a patient’s inability to pay.
At-Home Self-Tests 

The at-home self-tests provided through the HRSA COVID-19 Testing Supply Program are given to health centers at no cost. You must provide them to recipients free of charge regardless of coverage status or ability to pay.

If you obtain at-home self-tests from other programs, you would comply with any conditions or restrictions related to cost sharing applicable to those programs.

You may use HRSA Health Center Program operational funding (H80) or COVID-19 supplemental funding to support distribution, staff time, storage, or other related costs for at-home self-tests.

Not applicable if you participate in the HRSA Health Center COVID-19 Testing Supply Program. You may not charge recipients for the costs of at-home self-tests received from HRSA.

May be applicable if you obtain at-home self-tests from other programs and are permitted to charge for these tests. If so, you may apply sliding fee discount(s), provide the tests at flat discounts, or provide them at cost.

Point-of-Care, Rapid Antigen Testing 

If you receive point-of-care testing supplies at no cost from the HRSA COVID-19 Testing Supply Program, you cannot seek reimbursement for the cost of the tests but may seek reimbursement from payor sources for administering the tests. However, you may not seek any reimbursement, including through balance billing, from patients.

You would seek reimbursement for the cost of administering the tests by billing Medicare, Medicaid, CHIP, or other public and private insurance or assistance programs, as applicable.

If you do not participate in the HRSA COVID-19 Testing Supply Program, you would seek reimbursement for point-of-care testing supplies and the cost of administering the tests.

You may also use HRSA Health Center Program operational funding (H80) or COVID-19 supplemental funding to support costs associated with staff time to prepare and administer point-of-care tests. 

Not applicable if you participate in the HRSA COVID-19 Testing Supply Program. You may not charge patients for the cost of point-of-care tests received from HRSA or for any test administration fees.

Applicable if you do not participate in the HRSA COVID-19 Testing Supply Program. You may charge patients out-of-pocket costs for test administration fees. If you do, you would apply your sliding fee discount(s)based on income and family size.

PCR Testing, Including Lab Fees

You would seek reimbursement for the cost of administering COVID-19 PCR tests and for any laboratory fees through Medicare, Medicaid, CHIP, or other public and private insurance or assistance programs, as applicable.

If there are prohibitions on patient cost-sharing, after submitting claims for reimbursement to the applicable payor source(s), you may not charge patients for such costs. However, you may use HRSA Health Center Program operational funding (H80) or COVID-19 supplemental funding for any costs not covered by the payor source or for patients without insurance coverage. 

Applicable if there are any patient out-of-pocket costs and cost-sharing is permitted. You would apply your sliding fee discount(s)based on income and family size.
Oral Therapeutics, Including Prescribing and/or Dispensing Fees

If you participate in the HRSA Health Center COVID-19 Therapeutics Program, you may not charge patients for the cost of oral antivirals received through this program. The oral antivirals from this program are made available at no cost. You would provide them to patients regardless of their insurance coverage status or ability to pay.

You would seek reimbursement for costs related to prescribing or dispensing COVID-19 oral antivirals through Medicare, Medicaid, CHIP, private insurance, or other sources, as applicable.

If you purchase and administer therapeutics from a source other than the HRSA Health Center COVID-19 Therapeutics Program, you would also seek reimbursement for applicable costs.

If there are  prohibitions on patient cost-sharing, after submitting your claims for reimbursement to the payor source(s), you may not charge patients for such costs. However, you may use HRSA Health Center Program operational funding (H80) or COVID-19 supplemental funding for any costs not covered by the payor source or for patients without insurance coverage.

Not Applicable if you participate in the HRSA Health Center COVID-19 Therapeutics Program. You may not charge patients for the cost of oral antivirals received from HRSA. 

Applicable if you do not participate in the HRSA Health Center COVID-19 Therapeutics Program and if there are any patient out-of-pocket costs for prescribing or dispensing oral antivirals. If cost-sharing is permitted you would apply your sliding fee discount(s) based on income and family size.

N95 Masks 

Masks provided through the HRSA COVID-19 N95 Mask Program, which ended in June 2022, were given to health centers at no cost. They were provided to recipients free of charge regardless of coverage status or ability to pay.

You may use HRSA Health Center Program operational funding (H80) or COVID-19 supplemental funding for the purchase of additional masks for staff, patients, and community members. You may also use this funding for any mask distribution, staff time, storage, or other related costs.

Not applicable – You may not charge recipients for masks received through the HRSA Health Center COVID-19 Mask Program or purchased using COVID-19 supplemental funds. 



 

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