User:Shawndouglas/sandbox/sublevel1

The COVID-19 pandemic has unquestionably put the U.S. health care system in a tough spot. That health care system, with all its warts^[1]^[2]^[3], has arguably not done well to handle so many unanticipated health issues from a broad portion of the population.^[3]^[4]^[5]^[6]^[7]^[8] From a provider side, proper reimbursement for COVID-19 testing is among the many issues that must be addressed. One key aspect of ensuring proper reimbursement in a reasonable time frame is first making sure a clear preregistration process that captures critical patient and facility information is conducted. (This can be facilitated and made easier as a first-step process in a clinical informatics solution, for example.) Critical patient and facility information includes (but is not limited to):

name, date of birth, and gender
race and ethnicity
demographic information such as full address and phone number
ordering physician or attending health care provider for test (if applicable)
facility's National Provider Identifier (NPI)
patient insurance company name, policy ID, group ID, insured's name, and insured relationship to patient (if insured)
whether or not it's the patient's first test (federal reporting requirement)
whether or not the patient is a resident of a congregate care setting (federal reporting requirement; also, e.g., additional Medicaid reimbursement may be available in some states^[9])
whether or not the patient is a healthcare worker (federal reporting requirement; also, e.g., may affect the patient's worker's compensation claim^[10]^[11])
whether or not the patient is pregnant (federal reporting requirement; also, e.g., Medicare will only accept a COVID-19 code as secondary if the primary diagnosis code is viral disease complicating pregnancy, childbirth, or puerperium^[12]^[13])

Secondarily, it's also important to have a plan in place for testing the uninsured. While the Families First and Coronavirus Relief Act (FFCRA) and the National Disaster Management System (NDMS) have historically provided legal mechanisms for reimbursement for what should otherwise be free patient testing for SARS-CoV-2 and the associated visit, ambiguities of these mechanisms and how they were enforced still managed to cause problems.^[14] For example, while providers could turn to the NDMS (until funds ran out) to pay uninsured claims at 110% of Medicare rates—with states' opting to cover those costs through their Medicaid program—providers were not obligated by the law to seek reimbursement from those entities and could optionally bill the uninsured patient directly, which was against the spirit of the FFCRA.^[14]^[15]^[16] Given these past problems and any lingering questions about existing programs like the HHS and HRSA coverage assistance programs^[12], it's important to know what your lab's policy will be on managing uninsured patient claims. How will you get reimbursed if you're accepting uninsured patients? Resources that may help with these decisions include the Health Resources & Services Administration's information page and associated FAQ.

For Medicare, Medicaid, and otherwise insured patients, the lab will likely have (or presumably acquire) someone on hand with billing experience. However, the preregistration information previously mentioned will still be important to implement. And staying up-to-date regarding billing issues is also important (e.g., CMS' October 2020 announcement about payment for high-throughput COVID-19 tests and turnaround times^[17]

For further guidance on billing issues, you may wish to consult with CMS' extensive document titled COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing. Also, the next chapter addresses code sets for reporting and billing, which may prove useful.