HRSA COVID Uninsured Fund: Testing Risk & Compliance Service Sheet
Mitigate Risk & Ensure Compliance
September 16, 2022DownloadsDownload Service Sheet
The HRSA Fund was created at the height of the COVID-19 pandemic to make testing available for the uninsured. The program had specific requirements for validating that a patient was uninsured. New diagnosis, procedure and testing codes were created and certain special waivers were put in place, leading to potential misuse and misconduct.1
Risks Our Experts See Increasing
The HRSA Fund was created at the height of the COVID-19 pandemic to make testing available for the uninsured. The program had specific requirements for validating that a patient was uninsured. New diagnosis, procedure and testing codes were created and certain special waivers were put in place, leading to potential misuse and misconduct.
Our experts are seeing a rise in regulatory scrutiny related to miscoding of COVID-19 tests and associated provider visits that often lead to an overpayment. For other government payers, regulators such as CMS, HHS, DOJ and OIG may be questioning the frequency of testing performed on some patients or the codes that are being billed in conjunction with COVID-19 lab tests. In addition, both commercial payers and regulators are questioning the fees (price gouging) along with the bundle of services charged and reported for COVID testing.2
How We Help
Our experts support providers, health plans, and testing laboratories to ensure compliance with billing and coding as well as through investigations and disputes.
Internal Proactive Compliance
Our experts provide 3rd party assessments of risks associated with Federal funding (including HRSA, Medicare, Medicaid) and covid testing. We help clients ensure compliance, identify potential risk areas, and remediate any historical issues.
Billing & Coding
We provide guidance on the use of COVID-19 testing codes based on the lab requirements associated (i.e., CLIA-waived, CLIA Independent or high complexity lab, etc.), as well as guidance related to additional codes that providers may have been billing in conjunction with the testing codes. For providers who billed a separate code although the actual test collection was embedded in the evaluation and management (E/M) visit, our experts help clients to assess repayment needs and correct related issues going forward.
Investigations and Disputes
Clients rely on our advanced data and analytics capabilities to support them through investigations and disputes. Our team brings extensive experience with lab billing and pricing disputes and investigations including experience serving as an IRO to support our clients. We also have economists on our team who have dealt with price gouging and economic issues.