Novitas, the CMS MAC for IHS and tribal providers, is currently only allowing IHS and Tribal hospitals performing COVID-19 laboratory tests to be reimbursed a nominal dispensing fee, even though they are often the entities who are analyzing the test themselves. This is in error, and CMS should instead clarify that they should be eligible for reimbursement at the encounter rate (OMB rate) since the facility continues to bear the same costs for collection, processing, analyzing, handling and follow-up on the results.