Provider Notice Issued 12/18/2020

Date:    December 18, 2020

To:       AllMedical Assistance Program Providers

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

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

It has come to the attention of HFS that some providers are charginguninsured Illinois residents for COVID-19 testing and treatment. Providersshould immediately stop these practices and bill claims to the appropriateuninsured COVID-19 reimbursement program, as described below. Thesereimbursement programs are available regardless of citizenship or immigrationstatus and there is no income limit for reimbursement; income only impactswhich program should be billed. Further, providers should reimburse uninsured patients who have paidout-of-pocket for COVID-19 testing and treatment and seek reimbursement throughthe programs described below instead.

Uninsured patients who receive provider bills for COVID-19 treatmentor 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 providerbilled the uninsured patient instead of the appropriate uninsured reimbursementprogram, HFS staff will call the provider and instruct the provider to reimbursethe patient and bill the appropriate uninsured COVID-19 program forreimbursement. 

 Billing for COVID-19 Treatment

In general, if the patient is uninsured, providers should seekreimbursement for COVID-19 treatment from the U.S. Health Resources andServices Administration (HRSA) instead of billing the uninsured patient; thisprogram reimburses regardless of income, citizenship, or immigration status. Ifthe uninsured patient may be eligible for Medicaid or the Illinois EmergencyMedical for Noncitizens program, the provider can help the patient apply forthose programs, which also cover COVID-19 treatment costs and more.

Providers are eligible for reimbursement for COVID-19 treatment forall patients who are Illinois residents regardless of income, citizenship, orimmigration status as described below. As such, there is no scenario inwhich a provider should bill the patient for COVID-19 treatment services inlieu 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-19Claims Reimbursement to Health Care Providers and Facilities for Testing,Treatment, and Vaccine Administration for the Uninsured program reimbursesproviders at Medicare rates for providing COVID-19 treatment, testing, andtesting-related services to uninsured patients. 

COVID-19 treatmentservices reimbursed by the HRSA program include office visits (includingtelehealth), emergency room, inpatient, outpatient/observation, skilled nursingfacility, long-term acute care (LTAC), acute inpatient rehab, home health, DME(e.g., oxygen, ventilator), emergency ambulance transportation, non-emergentpatient transfers via ambulance, and FDA approved drugs as they becomeavailable for COVID-19 treatment when administered as part of an inpatientstay.

For reimbursement, providers should submit claims to the HRSA COVID-19 ClaimsReimbursement Portal. The date of service must be on or afterFebruary 4, 2020. Uninsured individuals should not be charged for theseservices.

The HRSA program does notcover: services that traditional Medicare does not cover, any treatmentwithout a COVID-19 primary diagnosis, expect for pregnancy when the COVID-19diagnosis may be listed as secondary, hospice services, or outpatientprescription drugs.

Illinois’ Emergency Medicalfor Non-Citizens Program

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

COVID-19 Treatment Reimbursementfor Insured Patients, including Medicaid

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

Billing for COVID-19 Testing and Testing-Related Services

Health care providers should provide COVID-19 diagnostic testing andtesting-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 theseservices. For individuals with insurance, providers should bill theinsurer, and should not charge deductibles, co-pays, or co-insurance formedically necessary testing and testing-related services.

HFS Uninsured COVID-19 Testing Program

HFS is implementing the Uninsured COVID-19 Testing Program created inthe federal FamiliesFirst Coronavirus Response Act (Families First Act). This programreimburses providers for COVID-19 testing and testing-related services providedto uninsured individuals on or after March 18, 2020. In Illinois, reimbursementthrough this program is available regardless of income, citizenship, orimmigration status.

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

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

The Department is deploying an online portal that allows providers tobill for COVID-19 testing and testing-related services for Medicaidfee-for-service customers and all uninsured Illinois residents, regardless ofincome, citizenship, or immigration status, with dates of service beginningMarch 18, 2020. Claims for Medicaidmanaged care members should be billed to the appropriate Medicaid managed carehealth plan. Providers should refer to the September25, 2020 provider notice for guidance on how to prepare to use theonline portal as soon as it is launched.

HRSA Uninsured COVID-19 Reimbursement Program

The HRSACOVID-19 Claims Reimbursement Portal is also available to providers andprovides reimbursement for uninsured patients at Medicare rates. This programis available when another payer or government program is not available forreimbursement.

Illinois providers should use the HRSA portal for COVID-19 testing andtesting-related services for uninsured patients with dates of service betweenFebruary 4 and March 17, 2020. As noted above, providers should also use theHRSA uninsured program for reimbursement for COVID-19 treatment since treatmentis not covered under the HFS COVID-19 Testing Program. The HRSA reimbursementportal 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 throughMedicaid, Medicare, commercial insurance, and employer-sponsored insurance,providers should submit claims for COVID-19 testing and testing-relatedservices to the patient’s insurer. Providers should not charge any deductibles,co-pays, or cost-sharing to the patient for medically necessary COVID-19testing services in accordance with the federal Families First Act, as amendedby the federal Coronavirus Aid, Relief, and Economic Security (CARES) Act.

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

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

Kelly Cunningham, Administrator

Division of Medical Programs

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