Five points particular to clinical laboratories were clarified in new multiagency guidance addressing the responsibilities of insurers paying for COVID-19 testing.
The Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief, and Economic Security (CARES) Act address multiple aspects of the reimbursement for COVID-19 testing by insurers. Since both laws went into effect, the broad coverage afforded through them has generated uncertainty, questions, and issues.
In response, the US Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Department of the Treasury recently prepared joint answers for frequently asked questions about the implementation of health coverage issues relating to COVID-19. This document was released June 23, 2020, as “FAQs About Families First Coronavirus Response Act And Coronavirus Aid, Relief, and Economic Security Act Implementation Part 43”.
While the joint federal guidance is quite extensive, multiple points are clarified within that affect clinical laboratories. These include:
- Specific guidance on which COVID-19 tests are required to be covered under FFCRA, with five different types of test authorization pathways required to be covered;
- Clarification on what is attending provider: “An attending provider for purposes of section 6001 of the FFCRA is an individual who is licensed (or otherwise authorized) under applicable law, who is acting within the scope of the provider’s license (or authorization), and who is responsible for providing care to the patient.”;
- Clarification that plans and insurers are required to cover COVID-19 tests intended for at-home testing;
- Clarification that plans and insurers are not responsible for covering COVID-19 testing for surveillance or employment purposes under FFCRA; and
- Clarification that plans and issuers are required to cover individuals who receive multiple diagnostic tests for COVID-19.
Clinical laboratories wanting more information should review the over 8,000-word document in its entirety to better understand the implications of the recent clarifications and guidance.