When the CMS and private payers COVID-19 cost-sharing waivers expire in the next weeks and months, it’s imperative that you restart collecting deductibles and copays.

If you fail to update your billing policies, you’ll leave thousands of dollars on the table – and you could even violate claims and kickback laws.

Since Medicare and most private payers have been waiving cost sharing during the coronavirus pandemic, you most likely were not collecting deductibles or copays as usual.

Many waivers are set to expire from October through December along with the ending of the public health emergency (PHE). When each waiver becomes ineffective, you must resume collecting that plan’s outstanding money again or you’ll be inappropriately waiving copays and deductibles – which counts as fraud under the False Claims Act and the Anti-Kickback Statute.

Most of the cost-sharing updates apply to private payers (including Medicare Advantage plans). You’ll want to keep your eyes and ears open, since the PHE is set to expire on October 22, 2020. For your Medicare patients, the provisions tied to the COVID-19 emergency haven’t changed so far.

Here’s a quick rundown on what to expect from some major payers regarding their COVID cost-sharing waivers expirations:

Anthem/BCBS Ends Some COVID Co-Pay Waivers in October

In July, HHS extended the COVID public health emergency (PHE) for an additional 90 days. It is currently scheduled to end around the last week in October. Some Anthem cost sharing waivers are set to expire coinciding with the end of the PHE:

COVID diagnosis testing and related visits, including telehealth and telephone-only visits.

Anthem extended other waivers until the end of the year:

In-network telehealth visits for COVID treatments
Non-COVID telehealth visits for Medicare and Medicaid patients

For BCBS plans, you’ll have to check what’s been updated in your state, since each service area is different.

Aetna Extends COVID Co-Pay Waivers until December 31, 2020

Aetna is reimbursing telemedicine at the same rate as an in-person visit (except for some telephone-only visits in commercial plans). For Medicare Advantage and Commercial plan members, cost-sharing is waived through the end of the year in these situations:

Inpatient admissions for treatment of COVID and/or COVID-associated complications
In-network primary care visits for any reason (in-office or telehealth)
In-network specialist visits, including behavioral and mental health providers

Aetna is also waiving early refill limits on some maintenance prescription drugs for plan members whose pharmacy benefits are administered through CVS Caremark (through December 31, 2020).

Cigna Cost Sharing for Medicare Advantage Extended, Individual Plans Ending

Medicare Advantage plan members will enjoy cost sharing waivers extended until December 31, 2020. These include:

COVID-related telehealth visits
Non-COVID, in-network telehealth visits (including behavioral health)
Expanded virtual care options for non-COVID services

The following COVID co-payment waivers for commercial and individual/family plans will expire on October 31, 2020:

COVID telehealth screenings
COVID diagnostic testing, related visits, and treatment
Non-COVID primary or specialist care office exams

Humana: Keeping COVID Co-Payments Guidelines Simple

Humana is extending cost sharing waivers for all in-network telehealth visits until December 31, 2020. This is regardless of COVID diagnosis, and includes all primary care, specialty care, behavioral and mental health visits. Like Aetna, Humana is reimbursing telehealth visits at the same rate as in-person visits, as long as medical necessity and other coverage guidelines are met and documented.

UnitedHealthcare: Most Out-of-Network Services Cost Sharing Waivers Set to Expire

Expansion of telehealth access for in-network visits—both COVID and non-COVID related—will continue through the end of the year for all Medicare Advantage, Individual, and Group plans. This includes cost sharing waivers.

Out-of-network telehealth visits face some restrictions. Waivers for out-of-network telehealth visits will end on October 22. This is for both COVID and non-COVID visits.