TPApril Posted January 25, 2022 Share Posted January 25, 2022 A 'friend' was traveling with her family last week, after the effective date of reimbursements for home covid tests, and found her family in need of purchasing multiple covid tests. In the process of taking these tests, the test materials and packaging themselves were discarded. Upon arriving home, this 'friend' contacted her insurance who has informed her that they will need both receipts and the UPC symbols in order to get reimbursement. Is this excessive and even allowed? Link to comment Share on other sites More sharing options...
Peter Gulia Posted January 26, 2022 Share Posted January 26, 2022 While I say nothing about whether any guidance is an appropriate interpretation or explanation of any law, consider these FAQs. January 10, 2022 https://www.dol.gov/sites/dolgov/files/EBSA/about-ebsa/our-activities/resource-center/faqs/aca-part-51.pdf Q1 states: “[A] plan or issuer may . . . require a participant, beneficiary, or enrollee who purchases an OTC COVID-19 test to submit a claim for reimbursement to the plan or issuer (in accordance with the plan’s or issuer’s reasonable internal claims procedures, consistent with applicable federal and [not superseded] state law).” Consider whether a claims administrator might look to a Universal Product Code as some evidence about whether the thing someone bought is a test that meets the conditions specified in the statute. Further, Q4 states: “A plan or issuer may require reasonable documentation of proof of purchase with a claim for reimbursement for the cost of an OTC COVID-19 test. Examples of such documentation could include the UPC code for the OTC COVID-19 test to verify that the item is one for which coverage is required under section 6001 of FFCRA, and/or a receipt from the seller of the test, documenting the date of purchase and the price of the OTC COVID-19 test.” For more background, see these FAQs. October 4, 2021 https://www.dol.gov/sites/dolgov/files/EBSA/about-ebsa/our-activities/resource-center/faqs/aca-part-50.pdf February 26, 2021 https://www.dol.gov/sites/dolgov/files/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-44.pdf February 26, 2021 https://www.cms.gov/files/document/faqs-part-44.pdf June 23, 2020 https://www.dol.gov/sites/dolgov/files/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-43.pdf April 11, 2020 https://www.dol.gov/sites/dolgov/files/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-42.pdf April 11, 2020 https://www.cms.gov/files/document/FFCRA-Part-42-FAQs.pdf leevena and bito'money 2 Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com Link to comment Share on other sites More sharing options...
TPApril Posted January 26, 2022 Author Share Posted January 26, 2022 Peter - thank you for your time putting that response together. Link to comment Share on other sites More sharing options...
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