HHS-OIG Audit A-02-23-02009 — Health Centers Received Duplicate COVID-19 Testing Reimbursement (December 2025)

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OIG.HHS.GOV 
December 2025 | A-02-23-02009     
Some Selected Health Centers 
Received Duplicate Reimbursement 
From HRSA for COVID-19 Testing 
Services 
 
 
 
 
 
 
 

 
OIG.HHS.GOV 
 
December 2025 | A-02-23-02009 
 
Some Selected Health Centers Received Duplicate Reimbursement From 
HRSA for COVID-19 Testing Services 
Why OIG Did This Audit   
• Congress appropriated $8.2 billion for COVID-19 supplemental grant funding for the Health Resources 
and Services Administration (HRSA) Health Center Program from 2020 through 2022.   
• Separately, during the same period, HRSA reimbursed providers more than $24.5 billion in COVID-19 
Uninsured Program (UIP) funds for providing COVID-19 testing and treatment services to uninsured 
individuals.   
• Prior OIG audit work identified that some health centers charged costs for processing COVID-19 tests 
to their COVID-19 supplemental grant funding and also submitted claims and received reimbursement 
for the same services from the UIP.   
What OIG Found 
• Twelve of 106 sampled health centers charged $313,270 in laboratory costs for processing COVID-19 
tests to their COVID-19 supplemental grants, submitted claims for the same services to the UIP, and 
received reimbursements from the UIP for these services.   
• On the basis of our sample results, we estimated that health centers in our sample frame claimed 
$673,962 in COVID-19 supplemental grant funds that were also reimbursed by the UIP for the same 
services.    
What OIG Recommends 
We made two recommendations to HRSA, including that it require the 12 health centers to refund $313,270 to 
the Federal Government.  The full recommendations are in the report.  HRSA concurred with both 
recommendations. 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
 
TABLE OF CONTENTS 
 
INTRODUCTION ........................................................................................................................... 1 
 
Why We Did This Audit ................................................................................................... 1 
 
Objective ......................................................................................................................... 1 
 
Background ..................................................................................................................... 1 
 
The Health Center Program .................................................................................. 1 
COVID-19 Supplemental Grant Funding ............................................................... 2 
HRSA COVID-19 Uninsured Program .................................................................... 2 
 
How We Conducted This Audit ....................................................................................... 3 
 
FINDING....................................................................................................................................... 3 
 
 
Health Centers Used COVID-19 Supplemental Grant Funds for Testing  
   Services Also Paid for by HRSA’s COVID-19 Uninsured Program ................................. 4 
 
RECOMMENDATIONS ................................................................................................................. 5 
 
HEALTH RESOURCES AND SERVICES ADMINISTRATION COMMENTS ........................................ 5 
 
APPENDICES 
 
A: Audit Scope and Methodology ................................................................................... 7 
 
B: Statistical Sampling Methodology .............................................................................. 9 
 
C: Sample Results and Estimates .................................................................................. 10 
 
D: Health Resources and Services Administration Comments ..................................... 11 
 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
1 
INTRODUCTION 
 
WHY WE DID THIS AUDIT 
 
In response to the COVID-19 public health emergency (PHE), Congress appropriated 
approximately $8.2 billion for supplemental grant funding for the Health Resources and 
Services Administration (HRSA) Health Center Program from 2020 through 2022.  HRSA 
awarded this funding to health centers and made the funds immediately available to help 
detect, prevent, diagnose, and treat COVID-19.  
 
Separately, during the same period, HRSA reimbursed providers more than $24.5 billion in 
COVID-19 Uninsured Program (UIP) funds for providing COVID-19 testing and treatment 
services, to uninsured individuals.  The UIP terms and conditions stated that recipients should 
consider payments from the UIP to be payment in full for COVID-19 testing and testing-related 
items and services, care or treatment, or administration of COVID-19 vaccinations.  According 
to HRSA, health centers should not have charged any costs reimbursed through the UIP to their 
COVID-19 supplemental grant funding, including any difference between amounts claimed to 
the UIP and what the UIP reimbursed. 
 
A prior Office of Inspector General (OIG) audit report identified that some health centers 
charged costs for processing COVID-19 tests to their COVID-19 supplemental grant funding and 
also submitted claims and received reimbursement for these same services from the UIP.1  This 
audit focused on health centers that submitted claims for COVID-19 testing and received 
reimbursement from the UIP. 
 
OBJECTIVE 
 
Our objective was to determine whether health centers that submitted claims for COVID-19 
testing and received reimbursement from the UIP also received reimbursement from other 
COVID-19 supplemental grant funding for the same services. 
 
BACKGROUND 
 
The Health Center Program  
 
The Health Center Program, authorized under section 330 of the Public Health Service Act 
(42 U.S.C. § 254b), awards grants to health centers to provide primary health care services to 
populations with limited access to health care.  Health centers focus on integrating care for 
their patients across a full range of statutorily required and additional services, including 
medical, dental, mental health, substance use disorder, and vision services.  Within HHS, HRSA 
administers the Health Center Program. 
 
1 OIG, Seventeen of Thirty Selected Health Centers Did Not Use or May Not Have Used Their HRSA COVID-19 
Supplemental Grant Funding in Accordance With Federal Requirements (A-02-21-02005), issued May 18, 2023. 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
2 
 
COVID-19 Supplemental Grant Funding 
 
From fiscal years 2020 through 2022, HRSA awarded approximately $8.2 billion in supplemental 
grant funding to 1,387 health centers nationwide to respond to the COVID-19 PHE.2, 3  The 
funding was intended to support health centers’ activities related to the detection, prevention, 
diagnosis, and treatment of COVID-19, including expanding COVID-19 testing and administering 
COVID-19 vaccines.4  HRSA separately awarded grants under each of the COVID-19 
supplemental grant funding appropriations with different activity codes to support its tracking 
of COVID-19-related spending.  
 
To expedite the distribution of the COVID-19 supplemental grant funding, HRSA did not require 
health centers to apply for these funds.  Instead, HRSA made the funds immediately available to 
health centers and generally required them to submit activity overviews and budget 
information within 30 days of the award release date.5  Health centers were also required to 
submit quarterly progress reports to HRSA on the status of activities supported with each 
supplemental grant funding appropriation.6  HRSA provided guidance to the health centers on 
allowable uses of the supplemental funds, including terms and conditions in its grant award 
notices.  The grant terms stated that health centers were not to use their COVID-19 
supplemental grant funding to support costs reimbursed or compensated by other Federal or 
State programs that provide for such benefits, including the UIP.7 
 
HRSA COVID-19 Uninsured Program 
 
HRSA also administered the UIP, a Federal program established to address the COVID-19 PHE.  
The UIP allowed health care providers, including health centers, to enroll and submit claims for 
reimbursement of COVID-19 testing and treatment services, and vaccine administration 
 
2 This included funding from four COVID-19 appropriation bills: (1) the Coronavirus Aid, Relief and Economic 
Security (CARES) Act ($1.32 billion), (2) the Paycheck Protection Program and Health Care Enhancement Act ($583 
million), and (3) the Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020 ($100 
million), and (4) the American Rescue Plan (ARP) Act ($6.2 billion).  We refer to the amount appropriated through 
these laws as COVID-19 supplemental grant funding. 
 
3 This audit did not include health center look-alikes, which meet all health center program requirements but do 
not receive health center program funding through the Public Health Service Act. 
 
4 All COVID-19 supplemental grant funding appropriations could be used to support COVID-19 testing and 
laboratory costs. 
 
5 During a normal grant application process, this information is usually submitted to, reviewed, and approved by 
HRSA before funds are awarded to a grant recipient. 
 
6 HRSA reviewed quarterly progress reports submitted by health centers for each award and monitored health 
centers’ drawdown activities. 
 
7 Program Specific Terms in Notice of Grant Award. 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
3 
provided to uninsured individuals.8  HRSA reimbursed providers more than $24.5 billion in UIP 
funds for providing COVID-19 testing and treatment services, and vaccine administration to 
uninsured individuals. 
 
To process UIP claims, HRSA launched an online UIP portal.  Providers submitted claims using 
patient information and the providers’ associated taxpayer identification number (TIN).9  Prior 
to submitting claims, providers were required to attest to UIP terms and conditions related to 
testing and treatment.  Specifically, providers were required to accept reimbursement from the 
UIP for services provided as payment in full and not to engage in balance billing or charge 
patients any type of cost-sharing. 
 
HOW WE CONDUCTED THIS AUDIT 
 
Our audit included health centers that (1) were awarded COVID-19 supplemental grant funding 
during fiscal years 2020 through 2022, (2) received $5,000 or more in reimbursement from the 
UIP for COVID-19 testing claims based on the associated TIN and (3) were not previously 
reviewed by OIG.  We identified 315 health centers that met these conditions and selected for 
audit a stratified random sample of 106 health centers.  We limited our review of grant funds 
claimed by the health centers to expenditures associated with COVID-19 testing services, which 
totaled $3,467,792 for our sample.10 
 
We conducted this performance audit in accordance with generally accepted government 
auditing standards.  Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 
based on our audit objectives.  We believe that the evidence obtained provides a reasonable 
basis for our findings and conclusions based on our audit objectives. 
 
Appendix A contains the details of our audit scope and methodology, Appendix B contains our 
statistical sampling methodology, and Appendix C contains our sample results and estimates. 
 
FINDING 
 
Twelve of the 106 sampled health centers charged $313,270 in laboratory costs for processing 
COVID-19 tests to their COVID-19 supplemental grants and received reimbursements from the 
UIP for the same services.  This occurred because although HRSA provided supplemental grant 
 
8 Division A, Title V of the Families First Coronavirus Response Act defines an uninsured individual as someone who 
is not enrolled in: (1) a Federal health care program (e.g., Medicare or Medicaid), (2) an individual health insurance 
coverage or a group health plan, or (3) the Federal Employees Health Benefits Program. 
 
9 UIP payment data is based on the billing entity’s TIN and may include claims submitted by other types of facilities 
such as hospitals that also bill under the same TIN as the health center.  This audit only focused on claims 
submitted by health centers. 
 
10 Our audit did not cover services related to the treatment of COVID-19 or COVID-19 vaccine administration. 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
4 
funding guidance, these health centers did not always follow the guidance.  Also, the health 
centers did not always implement financial management systems and internal controls to 
ensure that only allowable and allocable costs were charged to their COVID-19 supplemental 
grant funding and the UIP.   
 
On the basis of our sample results, we estimated that health centers in our sampling frame 
claimed $673,962 in COVID-19 supplemental grant funds that were also reimbursed by the UIP 
for the same services.11  These funds could have been used to provide essential testing services 
to monitor and suppress COVID-19. 
 
HEALTH CENTERS USED COVID-19 SUPPLEMENTAL GRANT FUNDS FOR TESTING SERVICES 
ALSO PAID FOR BY HRSA’S COVID-19 UNINSURED PROGRAM 
 
Health centers were not to use their COVID-19 supplemental grant funding to support costs 
reimbursed or compensated by other Federal or State programs that provide for such benefits, 
including the UIP.  Grant recipients were to consider payments from the UIP to be payment in 
full for COVID-19 testing and/or testing-related items and services, care or treatment, or 
administration of COVID-19 vaccinations.12 
 
Twelve of the 106 sampled health centers charged laboratory costs for processing COVID-19 
tests to their COVID-19 supplemental grants, submitted claims for the same services to the UIP, 
and received reimbursements from the UIP for these services.  In total, the 12 health centers 
charged $1,930,010 in laboratory costs related to COVID-19 testing to their COVID-19 
supplemental grants.  Of this amount, $313,270 was associated with services for which the 
health centers also claimed and received UIP reimbursement.13  According to HRSA, health 
centers should have accepted any payments from the UIP as payment in full and should not 
have charged the costs to their COVID-19 supplemental grant funding, including any difference 
between amounts claimed and subsequently reimbursed by the UIP.14 
 
 
11 The 90-percent confidence interval for the grant funds that were also reimbursed by the UIP in the sampling 
frame was $366,628 to $981,296. 
 
12 HRSA, Terms and Conditions for Participation in the HRSA COVID-19 Claims Reimbursement to Health Care 
Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program. 
 
13 Our analysis of UIP COVID-19 testing claims was limited to claims that included procedure codes which we 
identified as relating to COVID-19 testing services.  Reimbursement for these procedure codes varied and often 
exceeded the cost of the laboratory test.  This resulted in a difference between the total laboratory costs 
reimbursed under the COVID-19 Supplemental grant funding and the payment amount of the matching UIP claim.  
UIP reimbursements, associated with the laboratory services that the 12 health centers charged to their COVID-19 
supplemental grants, totaled $557,462.   
 
14 For example, if a health center submitted a UIP claim for $100 and received reimbursement for $75, the balance 
of $25 should not have been charged to their COVID-19 supplemental grant funding. 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
5 
On the basis of our sample results, we estimated that health centers in our sampling frame 
claimed $673,962 in COVID-19 supplemental grant funds that were also reimbursed by the UIP 
for the same services.  These funds could have been used to provide more services related to 
the detection, prevention, diagnosis, and treatment of COVID-19. 
 
Although HRSA provided supplemental grant funding guidance, including guidance on allowable 
uses of these funds, these health centers did not always follow HRSA’s guidance.  Also, the 
health centers did not always implement financial management systems and internal controls 
to ensure that only allowable and allocable costs were charged to their COVID-19 supplemental 
grants and the UIP.  Specifically, officials at the 12 health centers that claimed duplicate 
reimbursements identified several challenges faced during the COVID-19 pandemic that may 
have contributed to the errors.  For example, three health centers noted that a lack of 
communication between their billing and accounting departments led to certain testing 
services being charged to both the COVID-19 supplemental grants and the UIP.  Six health 
centers explained that they were short staffed during the COVID-19 PHE or that the staff 
responsible for billing and management had been replaced, making it difficult to identify the 
root cause of the issue.  Finally, eight of the health centers stated that HRSA provided limited 
guidance while funds were being rapidly distributed.15 
 
RECOMMENDATIONS 
 
We recommend that the Health Resources and Services Administration: 
 
• require the 12 health centers that charged unallowable COVID-19 supplemental grant 
costs to refund $313,270 to the Federal Government and  
 
• reiterate guidance to these 12 health centers for developing and maintaining financial 
management systems and internal controls that ensure that only allowable and 
allocable costs are charged to future HRSA programs similar in nature. 
 
HEALTH RESOURCES AND SERVICES ADMINISTATION COMMENTS  
 
In written comments on our draft report, HRSA concurred with our recommendations.  
Specifically, in response to our first recommendation, HRSA indicated that it will work with the 
12 identified health centers to determine the amount of unallowable costs charged to their 
grants and require health centers to refund these amounts to the Federal Government.  
Regarding our second recommendation, HRSA indicated that it will provide education and 
technical assistance to the 12 health centers and conduct operational site visits at the health 
centers to review each health centers’ financial management and accounting systems.   
 
 
15 The total number of health centers referenced exceeds 12 because some health centers identified multiple 
causes for the duplicate reimbursements. 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
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HRSA also provided technical comments, which we addressed as appropriate.  HRSA’s 
comments, excluding the technical comments, are included as Appendix D. 
 
 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
7 
APPENDIX A: AUDIT SCOPE AND METHODOLOGY 
 
SCOPE 
 
We identified a sampling frame of 315 health centers that received $2,293,199,746 in COVID-19 
supplemental grant funding during the period from January 20, 2020, through March 31, 2023 
(audit period)16 and, based on the associated TIN, also received $5,000 or more in 
reimbursement from the UIP for COVID-19 testing claims.  We reviewed a stratified random 
sample of 106 health centers.  We limited our review of COVID-19 supplemental grant funds 
claimed by the health centers to expenditures associated with COVID-19 testing services, which 
totaled $3,467,792 for our sample. 
 
We did not assess HRSA’s or the health centers’ overall internal control structure.  Rather, we 
limited our review of HRSA’s and the sampled health centers’ internal controls to those 
applicable to our objective.  This included reviewing policies and procedures related to 
COVID-19 supplemental grants and the UIP. 
 
We conducted our audit work with HRSA and the health centers from November 2023 through 
June 2025. 
 
METHODOLOGY 
 
To accomplish our objective, we: 
 
• reviewed applicable Federal laws, regulations, and guidance;  
 
• met with HRSA officials to gain an understanding of COVID-19 supplemental grant 
funding requirements and HRSA’s oversight activities related to awarding, monitoring, 
and drawdown processes; 
 
• obtained from the HRSA’s grants database a list of the 1,387 health centers that 
received COVID-19 supplemental grant funding during the audit period, totaling 
$8,193,955,317; 
 
• obtained HRSA UIP data for health centers that received reimbursement from the UIP 
for COVID-19 testing services;17 
 
• assessed the reliability of the HRSA data by (1) performing electronic testing for 
accuracy and completeness, (2) confirming the COVID-19 supplemental grant amounts 
 
16 The HRSA UIP stopped accepting claims for testing services as of March 22, 2022; however, HRSA’s contractor 
continued to adjudicate and pay claims that were submitted before the program submission deadline. 
 
17 Our analysis of UIP COVID-19 testing claims was limited to those claims which included procedures codes which 
we identified as related to COVID-19 testing services. 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
8 
with each of the sampled health centers, and (3) confirming UIP reimbursements in 
instances for which we identified duplicate reimbursements, and determined that the 
data were sufficiently reliable for the purpose of accomplishing our objective;  
 
• constructed a sampling frame of 315 health centers that received reimbursement from 
COVID-19 supplemental grant funding and, based on the associated TIN, also received 
$5,000 or more in reimbursement from the UIP for COVID-19 testing claims, and 
selected a stratified random sample of 106 health centers;  
 
• for each of the 106 sampled health centers, we requested and reviewed grant award 
notices, Federal Financial Reports, accounting records for all grant expenses, applicable 
laboratory records (e.g., invoices and patient data), and other records, to determine 
whether the health center: 
 
o submitted claims to the UIP for the same COVID-19 testing services by 
comparing the patient’s name, date of birth and date of service on the UIP 
claims and in the laboratory records for testing costs charged to the grants and 
 
o complied with grant terms prohibiting the use of COVID-19 supplemental grant 
funding to support costs that were reimbursed or compensated by the UIP; 
 
• met with the 12 health centers that claimed duplicate reimbursements to determine the 
cause of the duplicate reimbursements; 
 
• used the results of the sample to estimate the amount that health centers in our 
sampling frame claimed in COVID-19 supplemental grant funds that were also 
reimbursed by the UIP for the same services (i.e., COVID-19 testing); and 
 
• discussed the results of our audit with HRSA officials. 
 
We conducted this performance audit in accordance with generally accepted government 
auditing standards.  Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 
based on our audit objectives.  We believe that the evidence obtained provides a reasonable 
basis for our findings and conclusions based on our audit objectives.   
 
 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
9 
APPENDIX B: STATISTICAL SAMPLING METHODOLOGY 
 
SAMPLING FRAME 
 
Our sampling frame contained 315 health centers that received COVID-19 supplemental grant 
funding totaling $2,293,199,746 during the audit period and, based on the associated TIN, also 
received $5,000 or more in reimbursement from the UIP for COVID-19 testing claims and were 
not previously reviewed by OIG. 
 
SAMPLE UNIT 
 
The sample unit was a health center. 
 
SAMPLE DESIGN AND SAMPLE SIZE 
 
We used a stratified random sample.  We divided the sampling frame into three strata based on 
the total UIP payments received by health center TIN for COVID-19 testing claims:  
 
Stratum 
Range of Total UIP Payments 
by Heath Center TIN 
Frame 
Count 
Frame Dollar Value 
(COVID-19 supplemental 
grant funding) 
Sample 
Size 
1 
> $5,000 and ≤ $98,343 
225 
$1,396,004,402 
50 
2 
> $98,343 and ≤ $1,559,188 
84 
$830,226,076 
50 
3 
> $1,559,188 
6 
$66,969,268 
6 
 Totals 
315 
$2,293,199,746 
106 
 
SOURCE OF RANDOM NUMBERS 
 
We generated the random numbers with the OIG, Office of Audit Services (OAS) statistical  
software.  
 
METHOD OF SELECTING SAMPLE UNITS 
 
We sorted the items in strata 1 and 2 by health center TIN in ascending order and then 
consecutively numbered the items in each stratum in the sampling frame.  We selected all six 
health center TINs in stratum 3 for review.  After generating random numbers according to our 
sample design, we selected the corresponding frame items for review. 
 
ESTIMATION METHODOLOGY 
 
We used the OIG, OAS statistical software to calculate the point estimate and 90-percent 
confidence interval for the total amount of COVID-19 supplemental grant funding claimed for 
costs reimbursed under the UIP in the sampling frame. 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
10 
APPENDIX C: SAMPLE RESULTS AND ESTIMATES 
 
Sample Details and Results 
 
Stratum 
Number 
of Health 
Centers in 
Frame 
Frame Dollar 
Value 
Sample 
Size 
Sample 
Expenditures 
Associated with 
COVID-19 
Testing Services 
Health Centers with 
Duplicate 
Reimbursements 
Total 
Number  
Total Value 
1 
225 
$1,396,004,402 
50 
$1,892,406 
7 
$52,365 
2 
84 
830,226,076 
50 
1,575,386 
5 
260,905 
3 
6 
66,969,268 
6 
0 
0 
0 
Totals 
315 
$2,293,199,746 
106 
$3,467,792 
12 
$313,270 
 
 
Estimated Value of COVID-19 Supplemental Grant Funding Claimed for Costs Reimbursed 
Under the UIP in the Sampling Frame 
(Limits Calculated for a 90-Percent Confidence Interval) 
 
 
Total Value of 
Health Center 
Duplicate 
Reimbursements 
Point Estimate 
$673,962 
Lower Limit 
$366,628 
Upper Limit 
$981,296 
 
 
 
 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
11 
APPENDIX D: HEALTH RESOURCES AND SERVICES ADMINISTRATION COMMENTS 
 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
12 
* 
* OIG Note: We limited our review of COVID-19 supplemental grant funds claimed by the 
health centers to expenditures associated with COVID-19 testing services and therefore did not 
assess the overall operations of the Health Center Program. 

 
HRSA COVID-19 Supplemental Grant Funding for Health Centers (A-02-23-02009) 
13 
 

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