Provider Notice issued 12/18/2025

COVID-19 Uninsured Population with No Social Security Numbers- Payment Update

This notice advises providers regarding an update to the special claim payment process for COVID-19 services rendered to uninsured individuals for whom no Social Security Number (SSN) could be determined, and therefore no recipient identification number (RIN) could be authorized through the COVID-19 Uninsured Portal.

As part of this process, the Department of Healthcare and Family Services (HFS) received submissions from 56 unique providers for over 800,000 claims for hundreds of thousands of alleged Illinois residents who were both uninsured and did not have a Social Security Number.

Provider requirements for claim submissions were laid out in Provider Notices dated 2/8/2021 and 10/14/2021.  General claim submission requirements may be found in 89 Ill. Admin. 140.20.

It was the provider’s responsibility to ensure that they were not seeking reimbursement from this process for services provided to individuals who have other coverage, whether that coverage is Medicaid, Medicare, or commercial insurance. In reviewing the files submitted by providers, it was determined that a high number of individuals for which providers are seeking reimbursement had other medical coverage on the date of service. These claims have been rejected.  If these individuals were identified as having Medicaid eligibility on the date of service no timely filing override will be allowed for the provider to bill these claims through MMIS, or to the applicable HealthChoice Illinois (HCI) Managed Care Organization (MCO) plan, at this point in time.

In addition to that, the Department received thousands of claims in which the provider had already been reimbursed for the services rendered to the specific individual on the specific date of service from other sources (i.e. federal HRSA portal) prior to the date in which these files were submitted. These claims have been rejected.

Thousands of claims were also received in which the date of death preceded the date of service for the individual in which reimbursement is being sought. These claims have been rejected.

Providers submitted thousands of claims where they have reported the home address of the individual to be their own office. These claims have been rejected.

The Department primarily has visibility only into the population that is receiving Medicaid services, which is roughly 25% of the population of Illinois. But it has been widely reported, through both the media and through criminal indictments, that significant amount of fraud had occurred related to providers seeking reimbursement related to services allegedly rendered to uninsured individuals. 

As such, it has been determined that any file submissions that have claim rejections in excess of 25% of their submission will be rejected in their entirety. 

The Department of Healthcare and Family Services (HFS) developed a file format for providers to identify unpaid COVID-19 services for the uninsured population for whom no SSN could be determined for the purpose of ensuring that all Illinois residents could receive necessary care regardless of their insurance status or regardless of whether the individual had a valid SSN. However, the providers had a responsibility to perform due diligence in determining the patient does not already possess a Recipient Identification Number (RIN), have other insurance, or an SSN.

Providers that are determined to have done their due diligence will soon receive payments for their billed services. Providers who are determined to have submitted claims not eligible for payment will be notified separately. Where deemed necessary, referrals have been made to the Office of Inspector General for additional potential investigation. 

For those receiving payment, HFS will make a one-time payment per provider NPI for the services submitted via a manually created payment voucher outside of the normal claim processing system.

Questions regarding this notice may be directed to the Bureau of Professional and Ancillary Services at 877-782-5565.

Laura Phelan, Administrator
Division of Medical Programs