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Provider Notice Issued 09/18/2020

Date:   September 18, 2020                                                                                    


To:      Laboratories and Long-Term Care Providers


Re:      Lab Testing and Claim Submittal for Individuals in a Long-Term Care Facility





This notice is intended to provide guidance to laboratories when billing claims for COVID-19 testing to individuals in a long-term care setting. This billing guidance is effective with dates of service beginning March 18, 2020 and applies to claims for participants covered under both traditional Medicaid

fee-for-service and Medicaid managed care plans as well as uninsured individuals being tested in the long-term care setting.


Please note all providers must be enrolled in the Department’s IMPACT enrollment system to be reimbursed by Medicaid and the state’s uninsured testing program. 


The following billing guidelines should be followed when billing services rendered to individuals in long-term care settings:


  • For patients eligible through one of the Department’s medical programs, bill the Department or the Medicaid managed care plan

  • For patients with Medicaid and Medicare Part B (no Medicare covered stay), laboratories should bill Part B and if not covered, laboratories should bill the Department on the HFS 2211 Laboratory/Portable X-Ray Invoice paper claim form with a copy of the Medicare Explanation of Benefits and request a C89/R36 override.  

  • For patients with Medicaid and Medicare Part A, if Medicare covers the stay, Medicare considers the test inclusive of the skilled nursing benefit §1861(h) and the long-term care facility is responsible.

  • For patients with Medicare Part A only (no Medicare Part B and no Medicaid), the Department continues to work with federal CMS. The Department will follow up with more information.

  • For patients who have hospice eligibility, generally the Department does not cover these services; however, an exception is being made and the service will be covered. Programming to accommodate this exception is not implemented. Until system changes are implemented, laboratories are instructed to hold fee-for-service claims if a patient has hospice eligibility. 

  • For patients who have private insurance, bill the private insurance


Laboratories rendering services to individuals in a long-term care setting who are not insured should follow the guidelines below:


  • For dates of service between February 4, 2020 and March 17, 2020, laboratories may be eligible for claim reimbursement through the Health Resources and Services Administration (HRSA) COVID-19 Uninsured Program. Providers may reference the Provider Notice dated May 18, 2020 for more information. 

  • For dates of service effective March 18, 2020 and after, labs should hold these claims until HFS issues further billing guidance for the uninsured testing group. The Department is currently developing an online portal. A provider notice and file layout will be published soon. When implemented, the Department will allow providers 180 days from the date of the portal’s implementation to submit claims.


The Department is aware that commercial companies are not reimbursing laboratories for all

COVID-19 laboratory-related services to individuals although they may be insured; for example, routine tests for “return to work” or “return to care”. The Department is working in conjunction with the Illinois Department of Insurance, Illinois Department of Public Health, federal CMS, and Governor Pritzker’s office to provide guidance and will publish information when available. Services rendered to patients who are insured should not be billed to HRSA or HFS. 


The Department will provide updated information in the near future. Providers who are not already enrolled to receive electronic notification of new releases from the Department are encouraged to subscribe.


Questions regarding this notice may be directed to the Bureau of Professional and Ancillary Services at 877-782-5565 for fee-for-service issues or to the applicable MMAI/HealthChoice Illinois health plan for managed care issues.



Kelly Cunningham

Interim Medicaid Administrator