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

Consistent with Health Center Program requirements, prior to billing recipients for COVID-19 vaccination, testing, or treatment, health centers should assess whether there are available reimbursement, funding, or compensation sources, as well as any related cost sharing restrictions or prohibitions. 

  • If there are no contract restrictions or conditions of participation that explicitly prohibit patient cost sharing, and there are patient out-of-pocket costs, health centers would apply their sliding fee discounts to these costs, consistent with their established policies and procedures. For example, a health center would apply sliding fee discounts in the case of no or only partial coverage by private insurance for certain testing or treatment which could result in costs to the recipient.
  • If there are prohibitions on patient cost sharing, such as for vaccine administration fees, after submitting their claims for reimbursement to the applicable payor source(s), health centers would comply with these prohibitions and would not charge recipients for any out-of-pocket costs.
  • Health centers may utilize Health Center Program operational funding (H80) and COVID-19 supplemental funding for awardees and look-alikes to absorb any allowable costs not covered by the payor source or for individuals without insurance coverage.

The table below provides a summary of considerations for billing and patient cost-sharing for specific COVID-19 related services and supplies. This is not an exhaustive list, and health centers should refer to the specific and most recent requirements or restrictions for each payor source or program. Please note that HRSA award recipients may not use Health Center Program grant funds for costs that are reimbursed or compensated by other federal or state programs that provide for such benefits. For additional questions on HRSA Health Center COVID-19 programs or funding, use the BPHC Contact Form.

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

COVID-19 vaccination providers, including health centers, cannot charge vaccine recipients for the vaccine which is provided free to enrolled providers by the U.S. government. Providers cannot charge vaccine recipients for any administration fees, copays, or coinsurance. 

Health centers would seek reimbursement for COVID-19 vaccine administration costs by billing Medicare, Medicaid, CHIP, and other public and private insurance or assistance programs, as applicable.

Health centers may also use HRSA Health Center Program operational funding (H80), as well as COVID-19 supplemental funding, as necessary to support the administration of in-scope COVID-19 vaccinations.

Not applicable – COVID-19 vaccines must be provided at no cost to all vaccine recipients.
At-Home Self-Tests 

The at-home tests provided through the HRSA COVID-19 Testing Supply Program are made available to the health center at no cost and are provided to recipients free of charge regardless of coverage status or ability to pay.

Health centers that distribute or procure at-home tests from other programs would comply with any conditions or restrictions related to recipient cost sharing applicable to those programs.

Health centers may use HRSA Health Center Program operational funding (H80), as well as COVID-19 supplemental funding, as necessary to support any distribution, staff time, storage, or other related costs.

Not applicable for health centers participating in the HRSA Health Center COVID-19 Testing Supply Program. Participating health centers may not charge recipients for the costs of at-home tests.

May be applicable for health centers that procure at-home tests from other programs and are permitted to charge for these tests and may provide discounts based on their sliding fee discount program.

Point-of-Care, Rapid Antigen Testing 

Health centers that receive point-of-care testing supplies at no cost from the HRSA COVID-19 Testing Supply Program are ineligible for reimbursement for the cost of the tests but may seek reimbursement from payor sources for the service of administering the test. However, health centers may not seek any reimbursement, including through balance billing, from the recipient.

Health centers would seek reimbursement for the cost of administering COVID-19 point-of-care tests by billing Medicare, Medicaid, CHIP, and other public and private insurance or assistance programs, as applicable.

Health centers administering these tests that are not participating in the HRSA COVID-19 Testing Supply Program, would seek reimbursement for point-of-care testing supplies and the cost of administering the tests.

Health centers may also use HRSA Health Center Program operational funding (H80), as well as COVID-19 supplemental funding, as necessary to support any costs associated with staff time to prepare for and administer point-of-care tests. 

Not applicable for health centers participating in the HRSA COVID-19 Testing Supply Program. Participating health centers provide point-of-care testing at no cost to the recipient. No cost or charge, including test administration fees, may be charged directly to the recipient.

Applicable for health centers administering these tests that are not participating in the HRSA COVID-19 Testing Supply Program and charge patient out-of-pocket costs for test administration fees. In these cases, health centers would apply their sliding fee discounts, which are based on income and family size.

PCR Testing, Including Lab Fees

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

If there are any applicable prohibitions on patient cost-sharing, after submitting their claims for reimbursement to the applicable payor source(s), health centers may not charge patients for such costs, but may use HRSA Health Center Program operational funding (H80) as well as COVID-19 supplemental funding to absorb 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. Health centers would apply their sliding fee discounts, which are based on income and family size.
Oral Therapeutics, Including Prescribing and/or Dispensing Fees

Health centers participating in the HRSA Health Center COVID-19 Therapeutics Program may not charge recipients for the cost of oral antivirals. The oral therapeutics provided through this program are made available at no cost to authorized providers and are provided to patients regardless of the recipient’s insurance coverage status or ability to pay.

Health centers would seek reimbursement for costs related to prescribing and/or dispensing COVID-19 oral therapeutics through Medicare, Medicaid, CHIP, private insurance, or other sources, as applicable.

Health centers purchasing and administering therapeutics that are not participating in the HRSA Health Center COVID-19 Therapeutics Program would also seek reimbursement for applicable costs.

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

Not Applicable for health centers participating in the HRSA Health Center COVID-19 Therapeutics Program. Participating health centers may not charge recipients for the cost of oral antivirals. 

Applicable if there are any patient out-of-pocket costs for prescribing and/or dispensing the oral antivirals. Health centers would apply their sliding fee discounts, which are based on income and family size.

IV/Infusion Therapeutics -Monoclonal Antibody (mAb) or Antiviral

Health centers would seek reimbursement (PDF - 93 KB) for costs related to administering COVID-19 IV/infusion therapeutics through Medicare, Medicaid, CHIP, private insurance, or other sources, as applicable. 

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

Applicable if there are any patient out-of-pocket costs for administering COVID-19 IV/infusion therapeutics. Health centers would apply their sliding fee discounts, which are based on income and family size.
N95 Masks 

Masks provided through the HRSA COVID-19 N95 Mask Program are made available at no cost to the health center and are provided to recipients regardless of the recipient’s coverage status or ability to pay.

Health centers may use HRSA Health Center Program operational funding (H80), as well as COVID-19 supplemental funding, as necessary to support any distribution, staff time, storage, or other related costs.

Not applicable – Health centers participating in the HRSA Health Center COVID-19 Mask Program may not charge recipients for the cost of masks.

 

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