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A cottage industry has been created around the reporting of charity care.

The U.S. Department of Health and Human Services (HHS) provides claims reimbursement to healthcare providers, generally at Medicare rates, for testing uninsured individuals for COVID-19, treating uninsured individuals with a COVID-19 diagnosis, and administering COVID-19 vaccines to uninsured individuals.

This includes testing or treatment for uninsured individuals with a COVID-19 primary diagnosis on or after Feb. 4, 2020. Providers can request claims reimbursement through the applicable program electronically.

To participate, providers must attest to the following at registration:

  • They have checked for healthcare coverage eligibility and confirmed that the patient is uninsured;
  • They accept defined program reimbursement as payment in full; and
  • They agree not to balance-bill the patient (also in the “No Surprises Act.”)

It all sounds great, doesn’t it? Well, the devil is in the details, and what happens if you billed, but don’t get paid under this program? Hospitals have a competing interest in this process.

Hospitals that receive Disproportionate Share Hospital (DSH) payments receive allocations from a large payment pool, based on the amount of charity care they provide. They have to submit listings of claims written off as charity every year. Hospitals are specifically told to remove claims paid through the COVID-19 program. 

Hospitals are in a catch-22 with unpaid claims billed under this program. Do they submit them in their list of charity? If they submit them as charity claims, do they have to track the claims and make reversals in future periods if the claim is paid?  A cottage industry has been created around the reporting of charity care. It seems that while the payments made under these programs are welcome, the complications continue to make charity care the “full employment act” for consultants.

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Timothy Powell, CPA

Timothy Powell is a nationally recognized expert on regulatory matters, including the False Claims Act, Zone Program Integrity Contractor (ZPIC) audits, and U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) compliance. He is a member of the RACmonitor editorial board and a national correspondent for Monitor Mondays.

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