HRSA uninsured program to stop accepting claims for testing and vaccination

On March 15, 2022, the acting director of the Office of Management and Budget and the White House coordinator for COVID-19 response jointly sent a letter to Speaker of the House Nancy Pelosi, Vice President Kamala Harris, and others addressing the status of funds available to the Health Resources & Services Administration (HRSA). Prior to this letter, the senders requested $22.5 billion in emergency funding by mid-March to continue to provide COVID related services. The requested funding has not been received and significant disruptions to programs administered by HRSA and other COVID-19 response efforts are expected as a result. The lack of funding comes at a critical time as a new hybrid variant of COVID-19 emerges in the United States and Europe.

As a result of the lack of funding, providers will soon be prohibited from submitting claims to HRSA for testing, treatment, and vaccination. Starting March 22, HRSA will stop accepting new claims for testing and treatment. On April 5, HRSA will stop accepting vaccination claims.

The HRSA program is intended to create access to COVID-19 medical services for uninsured patients. Eliminating the ability of providers to seek reimbursement for such services will result in providers being required to absorb the cost of the treatment, which is an extremely costly endeavor for providers who continue to experience decreased revenue as a result of the pandemic. For providers who are unable to cover the cost of such services for their uninsured patients, they will be forced to turn away uninsured patients, leaving those individuals without testing, treatment, or vaccinations. To maximize the chance of reimbursement for these services, it is recommended that providers submit their claims as soon as possible. However, even though HRSA has identified specific dates that claims will no longer be accepted, there is no guarantee of payment for claims submitted prior to those dates and any payment will be contingent upon the availability of existing funds.

The lack of funding is expected to also impact the availability of booster doses and variant specific vaccines for all U.S. citizens because the federal government simply will not have the money to purchase such vaccines. This will lead to vaccine shortages and could increase community spread of existing and future variants, and may cause future surges to spike higher than necessary.

Additionally, the lack of funding will decrease the availability of monoclonal antibodies, which have previously been provided to U.S. citizens free of charge. Starting the week of March 20, state allocations for monoclonal antibody will be decreased by more than 30%.

Other programs expected to be impacted by the lack of funding include preparatory efforts to combat future COVID-19 surges. These efforts include the purchase of oral antiviral pills, pre-purchases of promising new antivirals, acceleration of the creation of a next-generation, pan-COVID vaccine that would provide broad protection against a range of COVID-19 variants, and maintenance of domestic testing capacity beyond June 2022. Without funding, these efforts will cease or be dramatically reduced, thereby impacting the ability to continue to combat COVID-19 and its future variants. Additionally, the lack of funding will lead to reduced purchases of treatments for immunocompromised individuals. It will also reduce the country’s ability to monitor emerging variants.

The lack of funding is likely to impact most providers, but will hit safety net providers the hardest. Uninsured patients could face limited treatment options. In addition to submitting claims timely to HRSA, providers impacted by the lack of funding should consider contacting their state and Congressional representatives or working with lobbying agencies to bring awareness to the consequences of this lack of funding.

For more information, please contact the attorneys below.

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