Covid-19 | Member Resource

FSA/HRA Update

For group health plans subject to Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code, the relief allows additional deadline time through the “Outbreak Period.”

The “Outbreak Period” began March 1, 2020 and will end 60 days after the date the federal government declares the COVID-19 national emergency has ended (date yet to be determined) or another date announced by the DOL and Treasury in a future notice. The rule provides that, in regard to ERISA, the Outbreak Period may not be longer than one year.

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”) recently released guidance to provide relief for certain COBRA deadlines during the COVID-19 Outbreak Period. These deadlines are disregarded from March 1, 2020 until the end of the Outbreak Period. Once an end date to this National Emergency Period is announced, the Outbreak Period will end 60 days following that date, unless the agencies announce a different end date for purposes of these extensions, but no longer than one year, which is March 1, 2021.

  • 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.