Yes, but not until the grace period is exhausted and coverage is terminated. Qualified health plans are permitted pursuant to 45 CFR §156.270(d)(1) to pend a claim (i.e., withhold payment) during months 2 and 3 of the grace period applicable for enrollees receiving advance payments of the premium tax credit. However, during the grace period, the coverage is still in force, and the plan may be required to pay the claims if the enrollee pays all outstanding amounts before the grace period is exhausted. Until the plan is relieved of the potential obligation to pay the claims (i.e., upon termination retroactive to the end of month 1 of the grace period), the provider may not submit the claim to the HRSA COVID-19 Uninsured Program. Once the grace period is exhausted and coverage is terminated retroactively to the end of month 1 of the grace period, the individual would not have health insurance coverage for months 2 and 3 of the grace period for purposes of the Provider Relief Fund, and the provider could submit claims for reimbursement to the HRSA COVID-19 Uninsured Program. The same approach would apply if the service was administered while an enrollee was in a state grace period but whose coverage was ultimately terminated retroactively for non-payment, leaving the enrollee uninsured at the time of the service.
This program is available to reimburse providers for COVID-19 testing and testing-related visits for uninsured individuals, treatment for uninsured individuals with a COVID-19 diagnosis, and COVID-19 vaccination administration fees. Providers can familiarize themselves with this process at www.hrsa.gov/coviduninsuredclaim, and learn more and file claims at https://coviduninsuredclaim.linkhealth.com. Providers should submit the claim for the uninsured individual to the HRSA COVID-19 Uninsured Program only if and after the grace period is exhausted and coverage has been terminated, or if the issuer coverage for the claim is reversed. Pursuant to 45 CFR 156.270(d)(3), Exchange issuers are required to notify providers of the possibility for denied claims when an enrollee is in the second and third months of the grace period where the enrollee is receiving APTC.