The U.S. Department of Health and Human Services’ Office of Inspector General (HHS OIG) continues to conduct audits and assessments examining whether health centers received duplicate reimbursements from the Health Resources and Services Administration (HRSA) for COVID-19 testing services.

In a December 18, 2025, press release, the HHS OIG reported that a recent review determined that 12 of 106 sampled health centers charged $313,270 in laboratory costs to process COVID-19 tests to their COVID supplemental grants, while also submitting claims for the same services to HRSA’s COVID-19 Uninsured Program (UIP). The report recommended that HRSA require the affected 12 health centers to refund the improperly charged amounts to the federal government. HRSA has concurred with this recommendation and indicated it will work with the identified health centers to determine the precise amount of unallowable costs that require repayment.

The UIP was intended to reimburse health care providers for COVID-19 testing, treatment and vaccine administration provided to individuals without health insurance during the pandemic. Through the UIP, HRSA reimbursed providers more than $24.5 billion for offering COVID-19 testing and treatment services to uninsured individuals. During the same period, HRSA awarded approximately $8.1 billion in COVID-19 supplemental grant funding to 1,387 health centers nationwide in fiscal years 2020 through 2022 to support pandemic response efforts.

According to HRSA, health centers were required to accept UIP payments as payment in full and were prohibited from charging any of these costs to their COVID-19 supplemental grant funding, including the difference between the amount claimed to the UIP and the amount they were reimbursed by the UIP.

Health care providers that submitted pandemic-era reimbursement claims to the UIP have been on notice that both HRSA and the HHS OIG consider recovery of improper UIP payments and enforcement priority. As we reported in February 2024, HRSA and the HHS OIG have used their audit authority to assess whether providers received UIP reimbursements for services provided to patients who had third-party health insurance coverage. A July 2023 OIG report estimated that providers may have received as much as $784 million in overpayments for services rendered to individuals with third-party insurance coverage.

Although many health centers may view pandemic-era funding as a closed chapter, the recent HHS OIG report underscores that UIP reimbursements remain an active area of federal scrutiny. Health centers that received UIP funds for COVID-19 testing or treatment services should consider reviewing the UIP terms and conditions; confirming compliance with uninsured-status determination requirements; assessing how UIP payments were used; and documenting the allocation of UIP reimbursements in relation to COVID-19 supplemental grant funds received during the same period.

If you have received an audit notice or if you have questions concerning your expenditures of UIP funds, please contact Feldesman Managing Partner Edward T. Waters at ewaters@feldesman.com or Feldesman Partner Mindy B. Pava at mpava@feldesman.com.