Order Extending Coverage of COVID-19 Testing for Symptomatic and Asymptomatic Individuals
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This Commissioner's Order requires health carriers offering plans in the District of Columbia to cover COVID-19 testing for individuals meeting District of Columbia Department of Health testing standards (Administrative Orders 2020-07 and 2021-003) during the public health emergency, without a clinician order or cost sharing. It affects carriers and insured individuals in the District of Columbia.
This Order extends coverage of COVID-19 testing for symptomatic and asymptomatic individuals and supersedes Commissioner's Order 04-2020.
Carriers must cover testing for individuals who meet DOH Administrative Orders Nos. 2020-07 and 2021-003 without an order by a physician or other health care provider and without cost sharing.
Coverage Criteria
Covered testing per DOH orders
Covered when ALL of the following are met
When these conditions are met, carriers must cover testing without a physician order and without cost sharing.
Insurers are required to cover COVID-19 testing without a physician or other health care provider order and without cost sharing when the individual meets the standards prescribed in District of Columbia Department of Health Administrative Orders Nos. 2020-07 and 2021-003 and the testing occurs during the duration of the District's public health emergency, including any extensions. Insurers may, but are not required to cover employer-mandated testing (for example, tests required by an employer for return-to-work) except to the extent that such testing is covered under the DOH orders described above.
The Order acknowledges that test results for asymptomatic individuals "may not ultimately be determinative in clinical and public health management policy decisions," but states that the empirical data from asymptomatic testing can "substantially and materially inform" public health decisions. As a result, testing asymptomatic persons who meet DOH Administrative Orders Nos. 2020-07 or 2021-003 is considered medically necessary during the public health emergency for public health management, even if an individual test result alone may have limited interpretive value for individual clinical management.
Coding
| No codes listed |
Provider Actions & Billing
No prior authorization or clinician order required when DOH criteria met
No prior authorization or clinician (physician or other health care provider) order is required for COVID-19 testing when the individual meets the standards prescribed in District of Columbia Department of Health Administrative Orders Nos. 2020-07 or 2021-003; carriers must cover such testing without an order for the duration of the public health emergency.
- Applies only when the individual meets DOH Administrative Orders Nos. 2020-07 or 2021-003.
- Requirement remains in effect for the duration of the District's public health emergency, including any extensions.
No step therapy or sequencing requirements specified
The Order does not impose any step therapy or other utilization management sequence for COVID-19 testing; no step therapy requirements are specified.
Coverage applies when DOH testing standards are met
Coverage under this Order applies when individuals meet the standards prescribed in District of Columbia Department of Health Administrative Orders Nos. 2020-07 and 2021-003 and when testing occurs during the public health emergency (including any extensions).
- Carriers offering health benefit plans in the District per D.C. Official Code § 31-3301.01(20) are subject to this requirement.
- When these conditions are met, testing must be covered without a clinician order and without cost sharing.
Carriers must not deny coverage or impose cost sharing for qualifying individuals
Testing may not be denied and must be covered without cost sharing for individuals who meet the standards in DOH Administrative Orders Nos. 2020-07 and 2021-003 for the duration of the public health emergency.
- Carriers shall cover COVID-19 testing for qualifying individuals without an order from a physician or other health care provider.
- This requirement supersedes Commissioner's Order 04-2020.
Definitions
Background
SARS-CoV-2 can be transmitted by persons without symptoms; therefore, identifying infections among asymptomatic individuals supports broader public health objectives. The Order cites the District of Columbia Department of Health Administrative Orders (2020-07 and 2021-003) as defining which symptomatic and asymptomatic individuals should be tested and explains that, during the public health emergency, "medical necessity encompasses the clinical and public health management" of the population at large. This public health rationale underlies the requirement that carriers cover testing for DOH-specified individuals during the emergency.
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