By  Nisha Kurani, Karen Pollitz, Dustin Cotliar, Nicolas Shanosky, and Cynthia Cox

July 15, 2020

Testing for COVID-19 remains a key strategy to identify active infections and contain the spread of the virus. The Centers for Disease Control and Prevention (CDC) recommends testing for persons with symptoms when there is a concern of potential COVID-19. As the pandemic grows, so will the number of tests performed. In the United States, over 695,000 COVID-19 daily test results were confirmed on average in early July, compared to an average of 400,000 daily test results in early June. Some people may require regular testing if they are at higher risk for infection, such as essential workers who come into contact with large numbers of people, or residents in long-term care facilities and other congregate settings. Additionally, as more workplaces re-open, some employers may consider periodic testing of employees as a protective screening measure.

Two major legislative efforts passed at the onset of the pandemic in March 2020 – the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief, and Economic Security (CARES) Act – required health coverage for COVID-19 testing – including the test itself, the related visit, and other services related to testing – with no cost-sharing for people covered by most private health plans, Medicare, and Medicaid. Federal laws also made resources available to finance free testing for uninsured individuals, but does not guarantee access to free COVID-19 testing for the uninsured. Importantly, there are limits to federal law coverage requirements that mean some patients with health coverage may nonetheless receive bills for COVID-19 diagnostic testing and related services, and those bills often can be widely different from patient to patient.

Outside of the Medicare program, there is no federal regulation of the price of COVID-19 diagnostic tests or other related tests and visits. Much like for other health services, hospitals and laboratories can set their own rates for privately insured and uninsured individuals. Private health insurers negotiate allowed charges with hospitals and providers participating in their network. In the absence of a negotiated rate for out-of-network providers, insurers must pay the provider’s cash price – sometimes called the list price – for COVID-19 testing and related services. The CARES Act requires providers to post the cash price on their public website for insurer use. These CARES Act coverage and payment requirements apply during the duration of the public health emergency, which is scheduled to end July 25, 2020, although it may be extended.

Negotiated rates between payers and their in-network providers for COVID-19 testing is not publicly available. However, the CARES Act price transparency rule provides a unique opportunity to examine what insurers pay for out-of-network care that is required to be covered. In this brief, we first present the findings from our search for COVID-19 test prices. For each state, we searched for COVID-19 test prices posted on public websites of the two largest hospitals. Despite the CARES Act requirement for prices to be posted, we were unable to find COVID-19 test prices on nearly one in four (24%) of the hospital websites we examined. For those that did have publicly available price information, COVID-19 diagnostic tests ranged from $20 – $850 per single test, not including the price of a provider visit, facility fee, specimen collection, or any other test that may have been included during testing. These services may be covered by insurance, but it is not guaranteed for all patients. Some patients may be billed for testing-related care from the hospital, a provider, or the insurer. We examine federal requirements and guidance on who can be charged for COVID-19 testing and related services. We then end with a broad discussion on how the uncertainty around what patients will be charged for health care services interacts with federal attempts at price transparency.

CONTINUE READING…