COVID-19 Business Intelligence and Analysis for Clinical Laboratories, Pathology Groups and Hospital Administration

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3 Frequently Asked Questions About COVID-19 Price Transparency Requirements

look at transparency in pricing COVID-19 testing, clinical laboratories

Clinical laboratories should be aware of price transparency requirements in the CARES Act.

The Centers for Medicare and Medicaid Services (CMS) addressed the issues of health insurance coverage and variation in COVID-19 medical care prices when it released guidelines to answer frequently asked questions about price transparency requirements.

The Coronavirus Aid, Relief, and Economic Security (CARES) Act requires that COVID-19 test providers make their cash prices public. CMS released answers to three common questions about these requirements in its May 12, 2020, guidance.

Included in CARES Act

The first question addressed what price transparency requirement is included in the CARES Act passed March 27, 2020.

  • CMS’s answer was that providers of diagnostic tests for COVID-19 must make public the cash prices for a diagnostic COVID-19 test on the healthcare provider’s public website.
  • While not specifically addressed by CMS, the U.S. Department of Health and Human Services (HHS) may fine non-compliant institutions up to $300 per day.


The second question was regarding the duration of this pricing transparency requirement. 

  • CMS answered that the requirement became effective upon the passage of the CARES Act and will continue for the duration of the COVID-19 public health emergency.

FFCRA Extras

The final question addressed how the pricing transparency requirement in the CARES Act relates to other provisions of the CARES Act and the Families First Coronavirus Response Act (FFCRA) of March 18, 2020.

  • CMS noted that under the FFCRA, insurance providers generally must cover COVID-19 testing without imposing any cost-sharing requirements.
  • CMS further explained that the CARES Act amends part of the FFCRA to allow a broader range of diagnostic items and services for COVID-19. Health plans and health insurance issuers must cover without any cost-sharing requirements, according to CMS.
  • CMS also noted that the CARES Act requires insurance providers to reimburse any provider of COVID-19 diagnostic testing at the negotiated rate or, if the insurance provider does not have a negotiated rate with the healthcare provider, they must reimburse them for the cash price listed by the provider on its public website.

Related Resources:

CMS FAQ for Pricing Transparency

Joint Departmental Guidance for Pricing Transparency and Expanded COVID-19 Testing Coverage

CARES Act Provider Relief Fund: For Providers