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Great news for your Flexible Spending Plans!

The CARES ACT reinstates coverage for expenses incurred for non-prescribed over-the-counter (OTC) medicine and medical supplies that are eligible for reimbursement under health savings accounts, health flexible spending accounts, and health reimbursement arrangements. This change repeals the Affordable Care Act's prohibition on reimbursement of such expenses under those arrangements. In addition, menstrual products are included as covered expenses that can be reimbursed under those arrangements. This change applies to those expenses incurred after December 31, 2019.

We anticipate that the merchant’s implementation of the new OTC eligible item list will occur gradually within 4-6 weeks of the President signing the bill into law. It is important to emphasize that each merchant will adhere to their own timeline for completion of this process. Debit cards for these newly reinstated expenses may not work at point of service and claims may need to be manually submitted for reimbursement.

Challenges arising as a result of the COVID pandemic provide several possible reasons to allow an election change for Dependent Care plans mid-year. For example, the IRS allows an election change for:

  • Reductions in hours
  • Change in employment status
  • FMLA leave
  • Substantial change in employer benefits/cost
  • Change of cost from the provider
  • Change of provider resulting in change of cost (the curtailment of Day Care due to COVID)

Transit Plans - Please ensure to have employees suspend their transit contributions if they are not currently traveling to work.

PBA will be working on amending all FSA SPDs and provide you the latest version when available. If you have any questions, please reach out to your PBA Flex/Enrollment representative.