HRA COVID-19 Updates

Impacts on HRA

For group health plans subject to Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code, Department of Labor (DOL) relief initially allowed extension of deadlines for 60 days after the end of the “Outbreak Period.”

The original “Outbreak Period” began March 1, 2020 and was not to exceed one year. The Department of Labor (DOL) recently clarified that employers are to extend deadlines around Flexible Spending Account (FSA) plans on an individual-by-individual basis since the COVID-19 “Outbreak Period” is still ongoing.

Personal Protective Equipment (PPE)

IRS Announcement 2017-07 extended the list of qualified medical expenses for certain accounts to include PPE and we’re making updates to extend these provisions to you.

WHAT DOES THIS MEAN FOR YOU?

When you purchase face masks, hand sanitizer and sanitizing wipes for the primary use in preventing the spread of coronavirus directly with funds from your health accounts, you can save money using pretax dollars.

Qualifying accounts:

  • Healthcare Flexible Spending Accounts (HCFSAs)

  • Archer Medical Savings Account (MSAs)

  • Health Reimbursement Arrangements (HRAs)

  • Health Savings Accounts (HSAs)

Starting March 26, 2021

  • Submit claims for eligible PPE purchased since January 1, 2020.
  • Save money on taxes and use your regular income on other necessities.
  • Purchase hand sanitizer, face masks, and sanitizing wipes with pre-tax funds.
Over-the-counter drugs, medicines and menstrual care products

The CARES Act includes a provision that allows members to use health account funds to pay for over-the-counter (OTC) medications without needing a prescription.

WHAT DOES THIS MEAN FOR YOU?

Effective immediately, FSA-qualified health plans can (but are not required to) cover telemedicine and remote care services before an FSA participant meets their deductible— or at reduced or no cost-sharing. This means FSA-qualified health plans can cover telemedicine services in the same way they cover preventative care services without interrupting a member’s FSA eligibility.

* HSA and HRA plans vary by employer, and these changes do not necessarily change the benefits under your employer’s plan.

Starting January 1, 2020

  • Use your regular income to pay for other necessities.
  • Submit claims for OTC drugs without a doctor’s prescription.
Menstrual care

The CARES Act extended the list of HSA-, HRA- and FSA-qualified expenses to include menstrual care products. We’re making updates to extend these provisions to you.

WHAT DOES THIS MEAN FOR YOU?

Because women can now purchase menstrual care products directly with health account funds, they can save money on taxes and use their regular income on other necessities.

Starting January 1, 2020

  • Submit claims for menstrual care products.
  • Save money on taxes and use your regular income on other necessities.
  • Purchase tampons, pads, liners, cups, sponges or similar products used in respect to menstruation.
FAQs

There have been a lot of changes during this past month as the nation deals with COVID-19. This list will hopefully help you find the answers you need regarding your health accounts and the recent changes.

Have more questions? Contact us.

FSA/HRA
  • What does the Consolidated Appropriations Act 2021 (commonly referred to as the CAA) mean for my Health FSA or HRA?

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

    The CAA also allows spend-down of Health FSA and DCFSA even if you leave your employer.

    HRAs are not included in this relief.

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

  • What is the Outbreak Period?

    The Department of Labor (DOL), the DOL Employee Benefits Security Administration, and the Department of the Treasury (the “Agencies”) released guidance to provide relief for certain Flexible Spending Account (FSA) plans deadlines during the COVID-19 Outbreak Period. These deadlines are disregarded from March 1, 2020 until the end of the Outbreak Period. The original Outbreak Period was not to exceed one year. The Department of Labor (DOL) recently clarified that employers are to extend deadlines around FSA plans on an individual-by-individual basis since the COVID-19 “Outbreak Period” is still ongoing.

  • My Health FSA or HRA claims runout occurred during the Outbreak Period, so what is my claims runout deadline?

    Any days during the "Outbreak Period" (starting March 1, 2020) are disregarded. We will not know the exact date until the federal government declares the COVID-19 national emergency has ended.

  • Will prior denied claims that are now eligible be reprocessed?

    HealthEquity will not go back and proactively re-process claims previously denied. You can:

    • Resubmit claims; or

    • When you call Member Services, a case can be submitted. The claim will then be reprocessed provided all other required documentation is present

  • What is the impact to my claim appeal deadline?

    Any days during the "Outbreak Period" (starting March 1, 2020) are disregarded. We will not know the exact date of your appeal deadline until the federal government declares the COVID-19 national emergency has ended. Any deadlines ending prior to March 1, 2020 are not affected by this guidance. Again, the Outbreak Period would be disregarded when determining the end of your appeal period.