HHS-OIG Audit A-02-21-01013 — Report in Brief: HRSA UIP Payments for Insured Individuals (July 2023)

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Report in Brief 
Date: July 2023 
Report No. A-02-21-01013 
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  
 
What OIG Found 
In the context of unprecedented challenges related to the COVID-19 national 
emergency, HRSA implemented a program to distribute funds to providers for 
COVID-19 testing and treatment for uninsured individuals in a fast and 
effective manner.  However, we determined that HRSA made payments to 
providers through the UIP for claims for COVID-19 testing and treatment 
services that did not comply with Federal requirements.  
For 240 of our 300 sampled patients, UIP payments to providers for claims for 
COVID-19 services met program terms and conditions, and were made on 
behalf of uninsured individuals.  Furthermore, we determined that providers 
in the sample had effective processes to ensure that they did not engage in 
balance billing or charge patients any type of cost-sharing.  However, UIP 
payments for 58 sampled patients totaling $294,294 were improper because 
they were made on behalf of individuals who had health insurance coverage 
or were made for testing and treatment services that were not provided or 
were unrelated to COVID-19.  We were unable to determine whether UIP 
payments for two other sampled patients complied with Federal 
requirements because the providers were unresponsive to our requests for 
supporting documentation.  
On the basis of our sample results, we estimated that nearly $784 million of 
$4.2 billion (or 19 percent) in UIP payments made to providers during our 
audit period for approximately 3.7 million of 19.2 million patients were 
improper.  We understand that HRSA’s operational objective for the UIP was 
to rapidly disburse funds for COVID-19 testing and treatment to ensure 
uninsured individuals were receiving vital health care services and to prevent 
the spread of COVID 19.  However, if HRSA or another HHS agency 
administers any programs of a similar nature in the future, the agency should 
consider the information included in this report. 
What OIG Recommends and HRSA Comments  
We made a series of recommendations to HRSA, including that it recover 
$294,294 in improper UIP payments identified in our sample and identify 
additional improper UIP payments for services provided to insured individuals 
or services unrelated to COVID-19, which we estimate to be nearly 
$784 million, and take remedial action.  We also made procedural 
recommendations for HRSA to improve future programs of a similar nature.
Why OIG Did This Audit  
Congress passed a series of bills to 
provide funds to eligible hospitals 
and other health care providers for 
COVID-19 testing and treatment for 
uninsured individuals.  The Health 
Resources and Services 
Administration (HRSA), within HHS, 
was selected to provide day-to-day 
oversight and management of the 
COVID-19 Uninsured Program (UIP).  
HRSA entered into an agreement 
with a contractor to administer the 
UIP, which allowed providers to 
enroll and submit claims for 
reimbursement of COVID-19 testing 
and treatment made to uninsured 
individuals (patients).  This audit is 
part of OIG’s oversight of HHS’s 
COVID-19 response and recovery 
efforts. 
 
Our objective was to determine 
whether claims for COVID-19 testing 
and treatment services reimbursed 
through the UIP complied with 
Federal requirements. 
 
How OIG Did This Audit 
Our audit covered claims for 
19 million patients with associated 
UIP provider payments totaling 
$4.2 billion with service dates from 
March 1 through December 31, 2020.  
As part of our audit, we interviewed 
HRSA officials and HRSA’s contractor 
and analyzed health insurance 
coverage data as well as medical and 
billing records.  We reviewed a 
stratified random sample of 300 
patients with associated provider 
payments totaling $2.8 million. 
The full report can be found at https://oig.hhs.gov/oas/reports/region2/A022101013.asp. 

 
 
 
The full report can be found at https://oig.hhs.gov/oas/reports/region2/A022101013.asp. 
In written comments on our draft report, HRSA partially concurred with our 
first recommendation and concurred with our second and third 
recommendations.  In addition, HRSA provided information on actions that it 
has taken or plans to take to address our recommendations.   
We commend HRSA for its actions and acknowledge that the UIP was 
administratively designed to be responsive to the pandemic and 
expeditiously reimburse providers.  Regarding HRSA’s comments on our first 
recommendation, we note that payments per the UIP terms and conditions 
were for testing or treatment of COVID-19 for individuals who did not have 
any health insurance coverage at the time the services were provided.  
Therefore, we maintain that our findings and associated recommendation 
are valid because we determined that improper UIP payments were made to 
providers on behalf of individuals who had health insurance coverage at the 
time of services.

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