OIG Sounds the Warning on Improper COVID-19 Vaccination Billing

Labs and providers that furnish COVID-19 testing and vaccination services need to look ahead and prepare for the massive federal false billing crackdown that is sure to come if and when the pandemic crisis finally tails off. The latest rumblings from the federal enforcement volcano occurred on April 15 when the OIG issued a relatively rare “Message From HHS-OIG Leadership” (Message) to let it be known that the agencies are hearing reports of false billing and “remain vigilant and committed to holding perpetrators of [COVID-19-related] fraud schemes accountable.” Compliance managers at labs and vaccination facilities are well advised to audit whether their organizations are currently meeting the billing and reimbursement rules the Message summarizes

6 Things to Check to Ensure Proper Billing of COVID-19 Vaccination

The Message specifically reminds providers is being provided by the federal government at no cost to recipients. It then runs down the six ground rules of billing and reimbursement under the CDC COVID-19 Vaccination Program under which participating providers:

1. Must administer the vaccine with no out-of-pocket costs to the recipient: YES [ ] NO [ ];
2. May not vaccination to anyone based on the person’s coverage or network status: YES [ ] NO [ ];
3. May not charge for an office visit or other fee if COVID-19 vaccination is the only medical service provided: YES [ ] NO [ ];
4. May not require a recipient to get additional medical services to receive the vaccination: YES [ ] NO [ ];
5. May seek appropriate reimbursement from a program or plan that covers COVID-19 Vaccine administration fee for the vaccine recipient, such as: YES [ ] NO [ ]
   • The vaccine recipient’s private insurance company;
   • Medicare or Medicaid reimbursement;
   • HRSA COVID-19 Uninsured Program for non-insured recipients;
6. May not seek any reimbursement, including via balance billing, from the vaccine recipient.

The OIG is “aware of complaints” that providers are charging recipients when they get their vaccines, the Message warns. It then calls on providers that have been charging impermissible fees to refund them and stop charging them in the future. However, the CDC does allow providers to bill payors for an administration fee in accordance with payor program rules.

Takeaway

Almost from the moment the pandemic began, the OIG has been sounding the warning on COVID-19-related fraud and abuse. The agency is currently investigating a series of rumored coronavirus billing ripoffs, including:

• Bundling of COVID-19 and non-COVID-19 tests;
• Performing medically unnecessary add-on tests on COVID-19 test recipients; and
• On a larger scale, use of telemarketing, text messages, social media platforms, and door-to-door visits to perpetrate scams to steal money and personal information from vulnerable people.