There’s a laundry list of reasons you might need a Covid test: you’re experiencing symptoms, you know you’ve been exposed, you want to visit your grandma, you want to return to work, the list goes on. And before this year, testing for different reasons could result in vastly different out-of-pocket costs. But in February 2021, the Department of Health and Human Services (HHS) and the Labor and Treasury Departments issued new guidance for insurers and medical providers on coverage for Covid testing and vaccines.

The covid testing and vaccine guidance from HHS, Treasury and Labor Departments

As of February 26, 2021, comprehensive health insurance plans must cover Covid testing, vaccines and related costs without cost sharing. This coverage includes people who are asymptomatic, people who don’t suspect they’ve been exposed and people who want to test just to make sure they’re not exposing a vulnerable loved one to the disease. The guidance also guarantees free testing for uninsured patients. What it doesn’t cover is surveillance testing or return-to-work requirements.

As long as your Covid test is for the purpose of individual diagnosis (i.e. you’re taking the test to see whether or not you have Covid), insurers must cover both PCR and rapid Covid tests in a variety of settings. Including:

• Your doctor’s office

• Walk-up testing site

• Drive through testing site

• Locally administered testing sites

• Hospital

• Your employer’s onsite medical clinic

Federal law requires insurers must also cover the items and services provided during the medical visit in which you receive your test including the administration of the vaccine.

So is that it? All Covid vaccines are 100% free? Not exactly.

Why you could still receive a bill for your covid vaccine

Like most legislation there are several loopholes and caveats to the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Recovery and Economic Security (CARES) Act. The following are some of the reasons you might receive a bill for out-of-pocket expenses related to receiving a Covid vaccine or test.

1. Your health insurance plan is one of the few plans that was considered “grand-fathered in” after the Affordable Care Act (ACA) went into effect, your insurance provider is exempt from complying with the FFCRA and CARES Act and the February 26th guidance. That means you could be subject to out-of-pocket costs associated with receiving a Covid test or vaccine. If you’re unsure what your insurance plan covers, reach out to your plan administrator or your HR department.

2. You’re tested regularly as part of a workplace safety policy, a public health surveillance program, or some other reason that is not meant for your individual diagnostic purposes.

3. You bought a rapid home test off the internet. If you bought a test off the internet, your insurance might not cover it. But you can use your HSA or FSA to pay for this test.

4. You sought emergency care because you were experiencing Covid-like symptoms, but you didn’t receive a test at the hospital because they didn’t have a test. If that’s the case, your deductible would be applied to your hospital visit. Even if you take a test later that confirms you did, indeed have Covid.

5. You receive your Covid test or vaccine at an out-of-network provider. Non-grandfathered plans and providers are required to reimburse participants or out-of-network providers for tests and vaccines administered at an out-of-network facility. So if you receive a bill, you may have to pay the out-of-network provider first and get reimbursed by your health insurance company later. Or you could use your HSA or FSA to pay for the service.

Another reason you could receive a bill is: the out-of-network provider doesn’t list the cash price for the Covid test on their website. Here’s why that’s important. First, there’s no federal regulation on the price of Covid tests or related visits (outside of Medicare). The KFF organization found the cost varies between $20 and $1,419. Not including the cost of the provider visit, facility fee or specimen collection. That’s quite a swing.

The CARES Act requires plans and insurers to pay the list cash price for the Covid tests their participants receive at out-of-network providers, and it requires all providers to list the cash price of a Covid test online so that out-of-network insurance plans know how much they’re required to pay for said test. It’s also so they know that all out-of-network plans are billed the same.

However, some providers don’t list the cash price (even though they’re subject to fines). So when an insurer tries to pay the bill for the services their plan participant received, they end up in a negotiation with the out-of-network provider because it’s not stated anywhere what the cost of the test should be. And if your insurance company and the provider are at an impasse, you could be responsible for paying out-of-pocket costs related to the Covid test or vaccine.

How to ensure you don’t get a surprise bill for Covid testing or vaccine

1. If you’re receiving a Covid test because you want to know whether or not you have Covid (regardless of the reason), get the test at an in-network provider. This is the best way to ensure your insurer and provider are on the same page.

2. If you’re receiving a Covid test as part of a workplace safety protocol, ask your employer who is responsible for the related costs.

3. If you’re uninsured, get tested at a site operated by the public health department.

4. If you must receive a Covid test at an out-of-network provider, make sure you ask them to direct you to their list cash price for the test. Then when you go in to receive the test, ask the provider to check to make sure the CPT code on your bill is correct.

Navigating the healthcare system in the best of times can feel like a nightmare and when you add a pandemic on top of the byzantine structure, it can be easy to feel defeated. But fear not. The medical community is committed to getting as many people tested and vaccinated for Covid as quickly as possible. So if you’re unsure how to access a Covid test, ask your doctor, look on your local public health department’s website, or your employer (if testing is part of workplace protocol). If you’re trying to get vaccinated against Covid, check this website for help locating a provider near you.