On Monday, April 27, the Health Resources and Services Administration (“HRSA”) released guidance on how healthcare providers can be reimbursed for their expenses related to the COVID-related treatment of uninsured individuals. This is based on earlier appropriations from the Families First Coronavirus Response Act and the CARES Act.

What is Included

Eligible claims include certain testing and treatment for COVID-19 services performed on or after Feb. 4, including:

  • Specimen collection, diagnostic and antibody testing
  • Testing-related visits to providers’ offices, telehealth, urgent care and emergency rooms
  • Treatments, including at providers’ offices, telehealth, emergency room, inpatient, outpatient, skilled nursing facilities, acute inpatient rehab, home health services and equipment, ambulance transfers and FDA-approved drugs as they become available
  • FDA-approved vaccines when they become available

Eligible healthcare providers providing these services to uninsured patients can file claims to be reimbursed at Medicare rates, subject to available funding.


The timeline for the claims process is as follows:

  • April 27: Healthcare providers can start enrolling on the COVID-19 Uninsured Program Portal as a program participant
  • April 29: On-demand program training begins
  • May 6: Claims may be submitted electronically (and only electronically)
  • Mid-May 2020: Reimbursements to be received


To participate in this program, eligible healthcare providers must attest to the following:

  • The provider must have confirmed that patient is uninsured and that patient does not have coverage from individual or employer-sponsored insurance policies, Medicare or Medicaid programs and no other payer will reimburse the provider that patient’s care
  • The provider will accept defined program reimbursement as payment in full
  • The provider must not charge any patient for COVID-19 treatment above what they would pay for as an in-network provider, commonly referred to as “balanced billing”
  • The provider must agree to program terms and conditions, which may include post-reimbursement audit review

All claims submitted must be final and complete. There will be no adjustments to payments once reimbursements are made.

Please reach out to GHJ’s COVID-19 Response Team if you have any questions as the firm has an experienced team of consultants specializing in cash-flow projections, strategy and operations consulting and re-organizations. We are here to assist organizations to succeed in these very challenging times.