Examining COVID-19 test prices and payment policy

July 17, 2020

As the COVID-19 pandemic grows, so will the number of tests performed, however outside of the Medicare program, there is no federal regulation of the price of COVID-19 diagnostic tests or other related tests and visits, addresses Peterson-KFF. They found that for hospitals with 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. 

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. 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. 

While the FFCRA and the CARES Act attempted to reduce COVID-19 testing costs for consumers, the cost and growing volume of testing could affect the cost of insurance overall. We do not currently know what insurers actually pay providers for COVID-19 testing, though analyzing cash prices gives us a range of possible charges incurred by self-pay patients, patients paying up-front for out-of-network testing, and insurers paying for out-of-network providers. The list prices posted by 78 hospitals for COVID-19 tests vary widely and, in most cases, are significantly higher than the amount Medicare allows. 

Many privately insured patients who do receive full coverage for COVID-19 testing as intended under the law may still see the impact of testing costs reflected in their premiums for the following year. Other patients might not be protected from receiving bills for COVID-19 testing or testing-related services, however; in addition to the test itself, patients may incur charges for related services, including the visit (in-person or telehealth) during which the patient is evaluated, the collection of test specimen, and other diagnostic tests or procedures ordered to confirm COVID-19 or rule out other possible conditions. These prices can also be high and unpredictable. Further complicating any effort to identify or categorize prices, the charges for COVID-19 testing and related services may be in a bundle, or the patient may receive separate bills from the hospital or testing facility, the attending health professional, the laboratory, and other providers involved in care. 

In an attempt to make the cost of care more transparent for patients and increase competition among providers and insurers, CMS released a final rule in November 2019 requiring hospitals to make public their standard charges, discounted charges, and insurer-negotiated rates for common services, effective January 2021. This rule was challenged in court and only recently upheld; it remains to be seen how it will be implemented and whether federally mandated price the cost of inpatient hospital services more transparent. 

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. 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. 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. 

Medicare covers testing without cost-sharing for patients and reimburses providers $51 or $100 dollars per diagnostic test, depending on the type of test. However, since there are no regulations on pricing in the private market, the price insurers must pay in-network hospitals and providers under current law is their established and negotiated rate for the service. The CARES Act requires insurers to reimburse out-of-network providers the cash price of COVID-19 tests posted on the provider’s website, though they may choose to bargain that price down on a claim-by-claim basis. 

Twelve hospitals listed the exact discounted rate or price of COVID-19 diagnostic tests for self-pay individuals, which ranged between $36 to $180 per test. A number of additional hospitals indicated on their websites that uninsured or self-pay individuals who didn’t qualify for governmental programs such as Medicaid could receive free or discounted care through hospital financial assistance programs. Patients receiving discounts would be charged for a portion of the listed price (e.g. 75% or 50% of the list price), though finding the exact amount of the discount can be challenging and often entails contacting the hospital to apply for discounted care. 

Aside from the cost of a diagnostic test itself, hospitals also bill for specimen collection and the office visit itself, whether in-person or through telemedicine. In most cases, the total cost of care for a test and its related services was not easily distinguishable on hospital websites. However, 13 hospitals clearly posted the list price for specimen collection, which ranged from $18- $200. One hospital listed three different charges based on where the specimen was collected – in a skilled nursing facility, at home, or an outpatient setting. 

Many hospitals require patients to receive provider referral for testing or require patients to meet CDC guidelines for symptoms before they can receive a test. For self-pay individuals, the cost of screening as well as testing may add up. For instance, one hospital’s price estimator tool demonstrated that the price of COVID-19 screening would be $77 before discounts, and $31 after applying a 60% discount for qualifying self-pay individuals. Such charges in addition to the cost of a diagnostic test and specimen collection can be financially burdensome or prohibitive for uninsured or self-pay patients, especially given the current labor market and high rates of unemployment. 

Antibody tests look for antibodies created by the immune system in response to an infection, and for the most part are used to signify a prior infection, rather than diagnosing a current one. Fewer hospitals (29) presented information on the price of antibody tests than diagnostic tests, resulting in 38 distinct prices for antibody tests. Prices ranged between $36 – $300, with 82% of posted prices below $150. To note, not all hospitals offer antibody tests to their patients. 

For out-of-network COVID-19 tests, private plans are required to pay the full price that is posted online. However, federal law is silent with respect to the amount a health plan must pay for out-of-network testing and related services if the provider has not posted a cash price online and if the health plan and the provider cannot agree on a negotiated rate. Guidance issued by the federal government notes only that the out-of-network provider who fails to post prices online may be liable for a civil money penalty of up to $300 per day. 

The article authors are Nisha Kurani, Karen Pollitz, Dustin Cotliar, Nicolas Shanosky, and Cynthia Cox  

Peterson-KFF has the report

More COVID-19 coverage HERE.