FAQs for COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment and Vaccine Administration

When HRSA's contractor, UnitedHealth Group, receives a claim for payment through the HRSA COVID-19 Uninsured Program, they check to see if the patient receiving eligible COVID-19 related testing and/or treatment services has other health care coverage through standard eligibility transactions. When they learn that a patient is enrolled in Medicaid but with limited benefits, the HRSA COVID-19 Uninsured Program will deny claims for COVID-19 related testing, but will reimburse claims for COVID-19 related treatment. This is because the authorizing statutes define uninsured differently. 

For Testing: Uninsured individuals, for purposes of the Families First Coronavirus Relief Act (FFCRA) Fund, are defined in the FFCRA statute as individuals who are not enrolled in: 1) a Federal health care program (as defined under section 1128B(f) of the Social Security Act (42 U.S.C. 1320a-7b(f), including an individual who is eligible for medical assistance only because of subsection (a)(10)(A)(ii)(XXIII) of Section 1902 of the Social Security Act; or 2.) A group health plan or health insurance coverage offered by a health insurance issuer in the group or individual market (as such terms are defined in section 2791 of the Public Health Service Act (42 U.S.C.300gg-91)), or a health plan offered under chapter 89 of title 5, United States Code. 

For Treatment: In the Provider Relief Fund, as appropriated in the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Paycheck Protection Program and Health Care Enhancement Act (PPPHCEA), uninsured individuals are defined as individuals who do not have any health care coverage at the time the services were rendered.

Individuals who are enrolled in limited benefit Medicaid plans, including those for family planning services, do not meet the definition of "uninsured" for the purposes of reimbursement from the FFCRA Relief Fund (the "testing fund"). Individuals with limited benefit Medicaid plans ARE considered to be uninsured for the purposes of reimbursement from the Provider Relief Fund (the "treatment fund").