Medicare Reimbursement of Pharmacy-Based COVID-19 Testing
On May 8, 2020, CMS issued guidance clarifying how pharmacies and other suppliers can obtain waivers to allow them to temporarily enroll as independent clinical diagnostic laboratories for the purpose of providing COVID-19 diagnostic testing. This move is seen as a critical step in expanding the public’s access to convenient testing locations. Prior to this guidance, reimbursement was a significant impediment to the implementation of testing in this setting because pharmacies were not designated as Medicare providers, and, therefore, could generally only offer the tests as a cash service. In order to be eligible for reimbursement, eligible pharmacies and their suppliers must be enrolled in the Medicare program and obtain a certificate of waiver from the laboratory standards established under the Clinical Laboratory Improvement Act (CLIA). The expansion of Medicare-reimbursed testing in a pharmacy setting is just one more example of the extraordinary changes that COVID-19 has produced within the health care system over the past few weeks.
We will continue to monitor the expansion of testing into other “non-traditional” settings and provide updates as they become available. Please contact Doug Griswold or your relationship attorney if you have any questions.
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The material in this publication was created as of the date set forth above and is based on laws, court decisions, administrative rulings, and congressional materials that existed at that time, and should not be construed as legal advice or legal opinions on specific facts. In some cases, the underlying legal information is changing quickly in light of the COVID-19 pandemic. The information in this publication is not intended to create, and the transmission and receipt of it does not constitute, a lawyer-client relationship. Please contact your legal counsel for advice regarding specific situations.