COVID-19 Commercial Payer Policy Updates: Coverage, Testing, and Telehealth

As the number of confirmed COVID-19 cases continues to grow in the US, national commercial payers are enacting policy changes pertaining to coronavirus testing, treatment, and telehealth services.

This month, federal legislation dictated that all COVID-19 testing be covered at zero cost to patients.

Meanwhile, telehealth services are expanding following guidance from the Department of Health and Human Services’ (HHS’s) and changes in Medicare telehealth guidelines to enable greater access during this emergency period (Medicare Advantage plans have increased flexibilities related to telehealth, with payer discretion on service offerings).

Commercial payers appear to be following suit. On March 10, Vice President Pence met with the CEOs of the major national health insurance companies, including Aetna, Anthem Blue Cross, Blue Cross Blue Shield Association (BCBSA), Cigna, Humana, and UnitedHealthcare (UHC), and indicated the insurers “agreed to cover telemedicine to allow people to speak to their doctors remotely about the coronavirus.” While these national payers have agreed to provide reimbursement for telehealth services, the benefits and coverage approach differ by payer.

Payer policies are continually changing in response to the pandemic, with many of these updates currently indicating a time frame of around 90 days. The start and stop dates of the changes vary by payer. ECG is continuing to monitor and track relevant payer policies to provide guidance to providers in this period of uncertainty.

Overview of National Payer Policy Changes in Response to COVID-19

Payer	Policy Changes
Aetna	Through June 4, 2020, Aetna will: Waive member costs associated with diagnostic testing at any approved laboratory location. Waive commercial member cost sharing for inpatient admissions at all in-network and out-of-network facilities for treatment of COVID-19 or health complications associated with COVID-19 (through June 1). Waive member costs associated with covered telemedicine visits. Offer its Medicare Advantage brief virtual check-in and remote evaluation benefits to all Aetna commercial members and waive the copay.
Anthem Blue Cross	Anthem Blue Cross has announced it will: Waive copays, coinsurance, and deductibles for diagnostic testing and in-network visits related to COVID-19 for all members. Waive member cost sharing for COVID-19–related treatment for fully insured individual, Medicaid, and Medicare Advantage members (through May 31). Waive any member cost sharing for telehealth visits.
BCBSA	No national standard documented. However, BCBSA and its network of 36 independent and locally operated BCBSA companies will: Waive prior authorizations for diagnostic tests and covered services that are medically necessary and consistent with the CDC’s guidance for members diagnosed with COVID-19. Cover medically necessary diagnostic tests that are consistent with CDC guidance related to COVID-19 without cost sharing for its members. Expand access to telehealth and nurse/provider hotlines. Many BCBSA companies have decided to waive cost sharing for treatment of COVID-19 through May 31.
Cigna	Through May 31, 2020, Cigna will: Waive customer cost sharing for testing and office visits related to COVID-19. Waive out-of-pocket costs for all COVID-19 treatment. Waive customer cost sharing for telehealth screenings. Make it easier for customers to be treated virtually for routine medical examinations by in-network physicians.
Humana	Humana is implementing the following measures: Testing for COVID-19, including physician office visits, will be fully covered with no out-of-pocket costs for patients who meet CDC guidelines at approved laboratory locations (effective as of March 6). All out-of-pocket medical costs related to treatment for COVID-19 will be waived—including inpatient hospital admissions. Out-of-pocket costs for telemedicine visits for urgent care needs will be waived for the next 90 days (effective as of March 23).
UHC	Through June 18, 2020, UHC will: Waive costs for COVID-19 testing provided at approved locations. Waive copays, coinsurance, and deductibles for visits associated with COVID-19 testing. Waive member cost sharing for the treatment of COVID-19 for fully insured commercial, Medicare Advantage, and Medicaid members (through May 31). Expand telehealth policies to make it easier for patients to connect with their healthcare providers.

COVID-19 Testing Reimbursement

Federal legislation dictated that testing for COVID-19 will be covered at zero cost to patients under both government and commercial plans. Most payers are following the reimbursement rates announced by the Centers for Medicare & Medicaid Services, which are as follows: HCPCS U0001: $35.92 per test; HCPCS U0002: $51.31 per test; CPT 87635: $51.31 per test.

COVID-19 Coverage Guidelines

Recent legislation has also specified that cost sharing for services related to COVID-19 testing are covered for Medicare beneficiaries. While some commercial plans may waive copays, coinsurance, and deductibles for visits associated with COVID-19 testing, federal policy only requires the testing to be covered. The following table outlines national commercial payer policy changes for COVID-19 testing, services related to COVID-19 testing, and COVID-19 treatment.

National Commercial Payer Coverage Policies

UHC will waive costs for COVID-19 testing provided at approved locations in accordance with the CDC’s guidelines. It is also waiving copays, coinsurance, and deductibles for visits associated with COVID-19 testing, whether the care is received in a healthcare provider’s office, an urgent care center, or an ER. This coverage applies to Medicare Advantage, Medicaid, and commercial members.
UHC will waive member cost sharing for the treatment of COVID-19 for fully insured commercial, Medicare Advantage, and Medicaid members. UHC will also work with self-funded customers who want to implement a similar approach.

Payer	Patient Responsibility: COVID-19 Testing and Treatment
Aetna	Aetna will waive the member costs associated with diagnostic testing for all commercial, Medicare, and Medicaid lines of business. This policy will cover the cost of a physician-ordered test and the physician visit that results in a COVID-19 test, which can be done in any approved laboratory location. Aetna will also waive member cost sharing for inpatient admissions at all in-network and out-of-network facilities for treatment of COVID-19 or health complications associated with COVID-19. This policy applies to all Aetna-insured commercial plan and Medicare Advantage plans. Self-insured plan sponsors will be able to opt-out of this program at their discretion.
Anthem Blue Cross	Anthem Blue Cross’s affiliated plans will waive copays, coinsurance, and deductibles for diagnostic tests for COVID-19 and for visits associated with in-network COVID-19 testing, whether the care is received in a physician office, urgent care center, or emergency department. Anthem Blue Cross will waive out-of-pocket costs for COVID-19 treatment received from in-network physicians, hospitals, and other healthcare professionals through May 31, 2020. This benefit is available to Anthem members in fully insured, individual, Medicare Advantage, and Medicaid plans.
BCBSA	Most BCBSA companies are waiving patient cost sharing on screening for COVID-19–related visits in physician offices, urgent care centers, and hospitals/ERs. Many BCBSA companies have decided to waive cost sharing for treatment of COVID-19, including inpatient admissions, through May 31. See individual plans for further guidance.
Cigna	Cigna will waive customers’ out-of-pocket costs for COVID-19 FDA-approved testing and testing-related visits with in-network providers, whether at a physician’s office, urgent care clinic, ER, or by virtual care options, such as talking with a physician or clinician 24/7 by phone, tablet, or computer, for fully insured plans, including employer-provided coverage, Medicare Advantage, Medicaid, and individual market plans available through the Affordable Care Act. Organizations that offer Administrative Services Only plans will also have the option to include coronavirus testing and treatment as a benefit. Cigna will also waive out-of-pocket costs for all COVID-19 treatment covered under Medicare or other applicable state regulations. This policy applies to customers in the US who are covered under Cigna’s employer/union-sponsored insured group health plans, insured plans for US-based globally mobile individuals, Medicare Advantage, and individual and family plans. Cigna will also administer the waiver to self-insured group health plans, which will have the opportunity to opt out.
Humana	Humana will waive out-of-pocket costs associated with testing for COVID-19 for patients who meet CDC guidelines at approved laboratory locations for its Medicare Advantage, Medicaid, and commercial employer-sponsored plans. Self-insured plan sponsors will be able to opt out. Humana will waive out-of-pocket medical costs related to treatment for COVID-19 by participating/in-network and non-participating/out-of-network providers for enrollees of individual and group Medicare Advantage plans, fully insured commercial members, Medicare Supplement, and Medicaid.
UHC

COVID-19 Telehealth Coverage

Many commercial payers have expanded coverage and waived costs associated with telehealth in order to encourage their members to seek care through a virtual platform. The additional measures have been primarily consumer focused and related to cost sharing. However, following recent guidance from HHS, some payers have also relaxed their standards regarding audiovisual connection and are also reimbursing for telephone (audio only) telehealth visits, making it easier for providers to render virtual care.

Aetna has waived cost sharing and expanded coverage for certain telehealth (general medical, behavioral health, and dermatology) visits; all other telehealth visits will be covered according to existing policy. Aetna is allowing some acute E&M visits to be done via telephone with no visual connection.
AnthemBlue Cross has waived cost sharing for telehealth visits and will cover audio-only telephone calls for medical and behavioral health visits when appropriate.
BCBSA has committed to expand access to telehealth. Some plans are achieving this by waiving cost sharing for telehealth visits. Most plans are covering the full cost of virtual care.
Cigna has waived cost sharing for COVID-19–related testing and virtual screenings; all other telehealth visits will be covered according to existing policy. Cigna is allowing telehealth visits to be done via telephone with no visual connection.
Humana has waived cost sharing for all telehealth visits, and all telehealth visits will be covered at the same rate as in-office visits. Humana is allowing audio-only telephone calls for all telehealth visits.
UHC has waived cost sharing for COVID-19–related visits as well as urgent care visits if accessed through a designated telehealth partner. UHC has waived cost sharing for medical, behavioral health, and PT/OT/ST if care is accessed through a local provider. All other telehealth visits will be covered according to existing policy. UHC is allowing virtual check-ins to be done as audio-only telephone calls.

Below are additional details regarding patient responsibility and expanded provider access by payer. The table is meant to provide a summary of information and allow providers to quickly compare guidance across payers.

Additional National Commercial Payer Guidelines

Payer	Patient Responsibility	Expanded Provider Access
Aetna	Aetna will waive member cost sharing for any covered telemedicine visits—regardless of diagnosis—accessed via Aetna-covered Teladoc offering. Teladoc is currently available to some, but not all, Medicare Advantage members. Cost sharing will also be waived for real-time virtual visits offered by in-network providers for all commercial and Medicare Advantage plans.	Aetna reimburses all providers for telemedicine visits at the same rate as in-person visits. Aetna will cover minor acute evaluation and management services rendered via telephone. A visual connection is not required. Aetna will cover additional general medicine and behavioral health visits; a synchronous audiovisual connection is still required. All other telemedicine services will be covered according to Aetna’s current policy.
Anthem Blue Cross	Anthem Blue Cross will waive cost sharing for covered telehealth visits for members using its telemedicine service, LiveHealth Online, as well as care received from other telehealth providers.	Anthem Blue Cross will cover telephone-only medical and behavioral health services from in-network providers and out-of-network providers when appropriate.
BCBSA	Some plans are waiving cost sharing for telehealth visits. See individual plans for further guidance.	Individual plans are promoting use of their respective telehealth platforms such as Teladoc or in-network providers’ platforms. Some states, such as California, are reimbursing care delivered through virtual connections such as Apple FaceTime. Most plans are covering the full cost of virtual care. See individual plans for further guidance.
Cigna	Cigna will waive virtual care and virtual screening for COVID-19–related services with no cost sharing when members see their usual provider through Cigna’s contracted provider network or vendor network (e.g., Amwell, MDLive). All other services will be reimbursed per member policy.	Cigna will allow providers to bill a standard face-to-face visit for all virtual care services, including those not related to COVID-19 for commercial members. Cigna will not make any requirements regarding the type of technology used (i.e., phone, video, FaceTime, Skype, etc., are all appropriate to use at this time) for commercial members.
Humana	Humana will waive member cost sharing for all telehealth services delivered by participating/in-network providers. This includes: All telehealth services delivered by participating/in-network providers, either through audio or video. All telehealth services delivered through MDLive to Medicare Advantage members, and to commercial members in Puerto Rico. All telehealth services delivered through Doctor on Demand to commercial members.	Humana will temporarily reimburse for telehealth visits with participating/in-network providers at the same rate as in-office visits. In order to qualify for reimbursement, telehealth visits must meet medical necessity criteria, as well as all applicable coverage guidelines. For providers or members who don’t have access to secure video systems, Humana will temporarily accept telephone (audio only) visits.
UHC	For COVID-19 testing-related telehealth visits for both in-network and out-of-network providers, cost sharing is waived during this national emergency. For in-network telehealth visits for medical, outpatient behavioral, and PT/OT/ST services, cost sharing is waived for Medicare Advantage, Medicaid, and commercial fully insured members, with an opt-in available for self-funded employers.	All eligible in-network medical providers who are able and willing to connect with their patients through synchronous virtual care (through FaceTime, Skype, Zoom, or dedicated telehealth applications) can do so. Benefits will be processed in accordance with the member’s plan. UHC will reimburse both participating and nonparticipating care providers who submit appropriate telehealth claims.

Typically, telehealth services will be reimbursed, based on national/state policies, payer policies and contracted rates, and are usually outlined in a provider’s participation agreement. It is important to note that the above telehealth expansions may be affected by state regulations. Providers should contact their payer representatives to understand any local limitations. ECG recommends that providers:

Identify their highest-volume commercial payers.
Review commercial payer summary to identify potential impact.
Compare expanded coverage to policies outlined in the provider manual.
Make billing changes.
Continue to check with payers regarding changes to policies.

Additionally, many payers are recommending that providers hold telehealth claims while the carriers reconfigure their claims systems to accommodate the new telehealth guidance.

Looking Forward

ECG can advise you on the impact of these changes and assist in developing strategies to ensure that providers are optimizing their reimbursement under these expansions.

We anticipate that payer policies will continue to evolve and while some may be temporary, the COVID-19 situation has already transformed the delivery system landscape toward more widespread adoption of telehealth in a short period of time. Providers will need to continue to ensure that they are adequately reimbursed for the time and expense associated with providing virtual care, both during and after this crisis has passed.

This post was last updated on April 9, 2020 at 8:45 A.M. PST

Published March 27, 2020