COVID-19 Private Payer Coverage Guidance

March 20, 2020

MEMORANDUM

To assist members in navigating private payer policies during the COVID-19 public health emergency, IHA has compiled a list of private payer telehealth coverage policies, prior authorization and member cost-sharing waivers, and billing requirements for COVID-19 testing services. This memorandum also outlines recent federal measures to regulate individual and group health plans. Please note that this information is subject to change in this rapidly evolving environment.  

IHA will provide detailed information on state and federal efforts to address COVID-19 coverage for Medicaid, Medicaid Managed Care Organizations (MCOs), and the uninsured in a forthcoming communication.

Families First Coronavirus Response Act
On March 18, President Trump signed the Families First Coronavirus Response Act (H.R. 6201). Among other emergency relief measures, effective March 18, 2020, the legislation prohibits all individual health insurance coverage and group health plans from applying cost-sharing (deductibles, copayments, and coinsurance) for COVID-19 testing and testing-related services. Covered services include in vitro diagnostic products approved by the Food and Drug Administration, provider office visits, urgent care center visits, and emergency department visits that result in an order for or administration of testing. In addition, the law prohibits small and large group health plans, individual market plans, and Medicare Advantage (MA) from applying prior authorization or other utilization management requirements for services.

Please note that the law does not apply to short-term, limited duration policies and health care sharing ministries; however, individuals with such non-ACA-compliant policies are considered “uninsured” under the Act. Hospitals may be eligible for Medicaid or federal reimbursement for testing and screening services provided to the uninsured per the Act. It also does not speak to whether these limitations apply to out-of-network providers or to reimbursement for these services. Current payer requirements regarding network status are identified here.

Additional Information
Please check IHA’s Novel Coronavirus/COVID-19 webpage for the latest IHA updates and other resources for member hospitals and health systems. Contact us with questions regarding this memorandum.