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No one in the medical field is free from the impact of COVID-19, including labs. With the onset of the Delta variant, daily average cases in the US reached over 100,000+. The need to accelerate testing for as many patients as possible in shorter time windows and ensuring appropriate treatment has significantly burdened the healthcare ecosystem.
As a lab billing and revenue cycle management services provider, we are routinely approached on COVID-19 billing and reimbursement for uninsured patients. For independent lab owners, it is a call to assist the community by testing as many patients as possible. The same also offers a business opportunity, as reimbursements for COVID-19 tests increase revenues and provide the lab an opportunity to maximize the return on the capital investment in expense lab equipment and resources.
In this article, we offer a simple primer on billing claims for uninsured patients and the coding guidelines for billing COVID-19 tests.
The HHS launched COVID-19 Uninsured Program Portal through the Health Resources & Services Administration (HRSA) which provides claims reimbursement typically at Medicare rates for testing uninsured individuals for COVID-19.
But a recent survey has shown that there is confusion over codes and requirements for COVID-19 claims which has led to increased workloads, inconsistent claim volumes and an overall decrease in productivity. Amid such challenges, there is also a lack of expertise and resources to ensure accurate coding and billing is done as well.

Following is a guideline of the process to claim reimbursement for the uninsured:
What is covered?
Under this program, reimbursement will be given for COVID-19 specimen collection, diagnostic and antibody testing as determined by HRSA (subject to adjustment as may be necessary).
How to bill and get reimbursed for COVID-19 testing?
Step 1 – Enrollment
◘ Validate Tax Identification Number (validation may take 1-2 business)
◘ Add Provider Roster (5-7 business days after TIN validation)
◘ Setup Optum Pay ACH to get direct deposit (7-10 business days)
Step 2 – Patient Eligibility 
◘ Confirm that the patient is uninsured and check for patients’ healthcare coverage eligibility
◘ Non-US citizens are also considered eligible under this provision
Step 3 – Add and Attest to Patient Roster
◘ Complete patient attestation and upload patient roster with the following information (contrary to the notion that SSN is mandatory, any of the following details can be used for patient attestation):
→ 1/  First name, last name, and date of birth
→ 2/  Any state identification e.g., driver’s license
Step 4 – Claim Submission
◘ Payer ID information is required at this step
◘ All claims submitted must be complete and final
Step 5 – Receive Electronic Payment
Claims that are eligible for reimbursement are typically processed and paid within 30 business days.

HRSA COVID-19 Uninsured Program Coding Guidelines:
Testing Codes for Independent Labs 
Independent labs are dependent on the diagnosis information indicated by the provider and may not know the reason for testing when ordered by another provider. Therefore, the eligibility for claim reimbursement by diagnostic testing services performed by independent labs is different compared to hospital labs. HRSA will reimburse for specific COVID-19 diagnostic testing services (individual procedure codes) for any diagnosis only when performed by independent labs.
For testing to be eligible for reimbursement billed by an independent lab, claims submitted must include one of the following diagnosis codes:
Z03.818 – Encounter for observation for suspected exposure to other biological agents ruled out (possible exposure to COVID-19)
Z20.828 – Contact with and (suspected) exposure to other viral communicable (confirmed exposure to COVID-19)
Z11.59 – Encounter for screening for other viral diseases (asymptomatic)
Z11.52 – Encounter for screening for COVID-19, asymptomatic
Z20.822 – Contact with and (suspected) exposure to COVID-19
Z86.16 – Personal history of COVID-19
As an exception to the above requirement, single line-item claims for the following procedure codes with any diagnosis may also be eligible for reimbursement:
COVID-19 Tests:
U0001, U0002, U0003, U0004, 87635, 87426, 87428, 87636, 87637, 87811, 0225U, 0226U, 0240U, 0241U
Antibody Tests:
86318, 86328, 86769
Specimen Collection:
G2023, G2024

Looking for COVID-19 billing assistance?