The HRSA Uninsured Testing Gold Rush

That promise was necessary. A pandemic testing system cannot work if uninsured people avoid tests because they fear the bill. So Congress and HHS created a reimbursement channel. Providers could submit claims and receive payment, generally tied to Medicare rates, for testing, treatment, and later vaccines for uninsured patients.¹

The weak point was in the word "uninsured."

HHS-OIG found that HRSA made COVID-19 Uninsured Program payments on behalf of people who had health insurance and for services unrelated to COVID-19. In its sample, OIG identified improper payments and estimated nearly $784 million in additional improper payments for insured individuals or unrelated services.² That estimate is not the same as a fraud finding against every provider. It is a measurement of a payment-control failure.

The audit put the cause in the program's design: HRSA's contractor verified a patient's coverage only if the provider submitted the patient's Social Security number.² One named enforcement case involved the same kind of claim. CityMD agreed in 2024 to pay more than $12 million to resolve False Claims Act allegations that it submitted or caused false claims to the Uninsured Program for COVID testing of people who had insurance coverage. CityMD denied the allegations. The settlement included no determination of liability; CityMD received credit for disclosure, cooperation, and remediation.³

The federal government wanted no-cost access. Providers wanted reimbursement. Labs and urgent-care chains had volume.

If the program pays only when the patient is uninsured, the claims system has to know whether the patient is uninsured before paying. A paper attestation or erroneous requisition can turn a public-health access program into a duplicate-payment channel.

A provider might have a patient's insurance card on file and still route the claim to the Uninsured Program. A lab might depend on the ordering provider's uninsured designation. A patient might not understand what was being billed at all. The person getting swabbed was often not the person choosing the payer.

HRSA paid quickly because testing mattered. Years later, OIG and DOJ were left sorting which claims belonged to uninsured relief and which ones belonged to insurers, patients, or nobody.

Notes

1. CRS PRF/UIP overview, Source document; HHS-OIG Uninsured Program audit, Source document. ↩
2. HHS-OIG, HRSA Made COVID-19 Uninsured Program Payments to Providers on Behalf of Individuals Who Had Health Insurance Coverage and for Services Unrelated to COVID-19, Source document. ↩₁ ↩₂
3. DOJ/CityMD settlement summary and agreement and Source document. ↩