Tuesday, June 01, 2021

HHS devotes $4.8 billion to COVID-test the uninsured. P.S. How about insuring them?

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HHS announced today that it is dedicating $4.8 billion in American Rescue Plan funds to reimburse providers for providing Covid-19 testing to the uninsured, at no cost to the uninsured patient. That's a continuation of a program initiated last spring. So far, $2.5 billion has been allocated by the Health Resources and Services Administration (HRSA) for such reimbursement.

Am I letting a current preoccupation distort my vision in seeing something of a lost opportunity (and irony) in this HHS statement?

There are approximately 29 million uninsured individuals living in the United States. While this administration has been focused on decreasing the uninsured rate, as evidenced by the more than 1 million people who have enrolled into quality health coverage through the Special Enrollment Period (SEP), much work remains. By ensuring programs like the HRSA COVID-19 Uninsured Program remains adequately funded, this administration is removing cost impediments so anyone exposed to COVID-19 may seek appropriate testing and care.

The funding announced today is dedicated to COVID-19 testing. HRSA also helps uninsured individuals’ access COVID-19 treatment and vaccinations through the COVID-19 Uninsured Program.  The program reimburses providers at national Medicare rates for providing these services.

Question: While providing testing and vaccination to the uninsured, why not...insure them?  According to KFF estimates, 63% of the currently uninsured are eligible for free or subsidized coverage, through Medicaid or the ACA marketplace. Yes, this release refers to HHS's efforts to decrease the uninsured rate. But those efforts for the most part do not extend to COVID-19 testing and vaccination -- procedures in which the uninsured are positively identified and present.  Shouldn't they?

It's true that the COVID-19 Uninsured Program is a reimbursement program that interacts with providers, not patients. But the providers obviously have direct contact with the patients, and the program's requirements could include making them aware that free or subsidized health coverage is likely available to them, and that the above-referenced SEP runs through August 15? At a minimum, that could entail handing out HHS-produced literature. Is it unrealistic to imagine the provision interpolated in red below into the current requirements for reimbursement?

Reimbursement under this program will be made for qualifying testing for COVID-19, for treatment services with a primary COVID-19 diagnosis, and for qualifying COVID-19 vaccine administration fees, as determined by HRSA (subject to adjustment as may be necessary), which include the following:

  • You have checked for health care coverage eligibility and confirmed that the patient is uninsured. You have verified that the patient does not have coverage through an individual, or employer-sponsored plan, a federal healthcare program, or the Federal Employees Health Benefits Program at the time services were rendered, and no other payer will reimburse you for COVID-19 vaccination, testing and/or care for that patient.

  • You have informed the patient that free or subsidized health coverage may be available and provided information about how to seek coverage.

  • You will accept defined program reimbursement as payment in full.

  • You agree not to balance bill the patient.

  • You agree to program terms and conditions and may be subject to post-reimbursement audit review.

Some providers that are doing COVID-19 testing and vaccinating do provide enrollment assistance. Federally Qualified Health Centers have their own dedicated federal funding stream for enrollment assistance, and so seek to enroll qualifying patients in Medicaid or other coverage. Many hospitals also provide enrollment assistance.

As far as I can tell, though, there is no federal initiative, and little to no state or local government initiative, to target health insurance enrollment assistance to those who self-identify as uninsured when receiving COVID-19 testing or vaccination.  I hope to report further on current enrollment outreach efforts at vaccination sites that do exist, mostly if not exclusively initiated by private enrollment assistance providers.

Photo by Jakayla Toney on Unsplash

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