Regulatory Updates

The CAA offers employers several options to provide temporary relief to Health FSA and DCFSA holders. The provisions of the Act include the ability to expand carryover amounts or extend grace period dates for qualifying members, as well as increased flexibility in election changes for both the Health FSA and DCFSA.

The CAA also allows employers to temporarily increase the age limit for DCFSA eligible dependents from 13 to 14 in some circumstances, and employers may allow spend-down of Health FSA and DCFSA even if you leave your job.

All provisions of the Act are at your employer’s discretion, so please check your plan details for more information.

If your employer decides to adopt any or all of the relief provided in the CAA, you should receive detailed information about effective dates and other relevant information to help you take advantage of the relief offered.

Your employer may communicate any changes it adopts as a result of the CAA, as well as any action you may need to take to benefit from the relief.

Masks, surgical gloves and hand sanitizer are not considered qualified medical expenses. Some masks may be eligible with a letter of medical necessity.

All major health plans have waived copays, coinsurance and deductibles for approved COVID-19 treatment and testing through May 31, 2020.* This waiver does not affect HSA eligibility. In addition, office visits, lab tests, medications, urgent care visits, emergency room visits, hospitalization or isolation facility charges can be paid directly by insurance below the deductible without fear of HSA consequences, if directly related to COVID-19. Of course, all qualified medical expenses may be paid from your HSA.

*Plans vary by employer, and these changes do not necessarily change the benefits available under your employer's plan. Please review plan documents carefully or consult your employer for information about your company's benefits.

We do not anticipate disruptions to services, including our ability to respond to claims and disperse funds. Our member services team is still available 24/7 to serve you.

IRS Notice 2020-29 provides flexibility for employers to temporarily adopt a more expansive list of allowable election changes. The CAA further extends this flexibility at your employer’s discretion. Please check your plan for more details.

Generally, a furlough or other change in employment status can affect Health FSA eligibility and allow for making changes to Health FSA elections. However, if your plan provides continued eligibility during a furlough or a temporary layoff, there would be no change in status. IRS Notice 2020-29 provides flexibility for employers to temporarily adopt a more expansive list of allowable election changes. Please check your plan for more details.