States must ensure that Medicaid beneficiaries have access to OTC products, including at-home Covid tests

States must ensure that Medicaid beneficiaries have access to OTC products, including at-home Covid tests

Over the last few days, millions of people have begun to receive four at-home Covid tests in the mail, as a result of the Biden Administration’s push to make Covid testing more readily available. In addition, the Administration has clarified that most private insurance plans must cover at least eight at-home tests per person per month, starting January 15, 2022. But access to at-home Covid tests for people enrolled in Medicaid and CHIP remains a patchwork.

Several at-home Covid antigen tests and PCR tests have been authorized for sale in the U.S. by the FDA since November 2020. While some FDA-authorized at-home tests require a prescription, most are available over-the-counter (OTC) from pharmacies, retail stores, and online. A test kit typically costs between $20 and $40 for a set of two tests.

The CDC has proclaimed, “Testing is very important to help reduce the spread of COVID-19.” This is especially true for people who are more likely to be exposed to the virus, such as essential workers and young people attending in-person school. Still, even almost three years into the pandemic, access to Covid testing has been challenging, especially during infection surges. While Medicaid beneficiaries, like all U.S. households, are eligible to have four tests mailed to them for free, accessing additional tests may pose a challenge. For low-income people on Medicaid, who cannot easily afford to pay for testing out-of-pocket, these challenges are exacerbated.

The federal Medicaid agency released guidance in summer 2021 making clear that state Medicaid programs must cover no-cost Covid testing for beneficiaries and provide access to all FDA-approved tests, including at-home tests. The guidance provides states significant flexibility, however, in terms of how they implement access to tests. While CMS noted that states could require a prescription for OTC at-home Covid tests, it also encouraged states to avoid “arbitrary barriers” to access and encouraged states to implement access in a way that linked particular tests to particular beneficiaries. In our view, requiring an individual prescription for OTC products, such as at-home Covid tests, is an arbitrary barrier to access, and states should not require them.

Instead, states should implement the Covid testing requirement in a way that maximizes beneficiary access to this important tool to limit the spread of the virus. For example, North Carolina issued a state standing order for OTC at-home Covid tests, and Medicaid beneficiaries can obtain up to eight tests per 30 days from Medicaid-participating pharmacies at no cost. Minnesota covers eight tests per month, and while tests must be dispensed on a provider’s prescription, pharmacists are authorized to prescribe tests.

Lessons learned from implementing access to OTC at-home Covid tests should be applied to ensure that Medicaid beneficiaries have access to other OTC products, such as OTC vitamins, medications, and contraceptives, when they need them. Too often, OTC products are out-of-reach for Medicaid beneficiaries. The Medicaid Act does not require programs to cover most OTC products, and when they are covered, beneficiaries often must obtain a prescription first. The pandemic has given states the incentive to expand access to OTC Covid tests. Now states should ensure these tests are readily available and explore using these same tools to expand access to other OTC products for Medicaid beneficiaries.

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