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HCFSA/HRA

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.

Frequently asked questions (FAQ)

Q: My health care FSA or HRA claims runout occurred during the Outbreak Period, so what is my claims runout deadline?
A: 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. The Outbreak Period would be disregarded when determining the end of your claims runout deadline. For example, if your calendar year health FSA has a 90-day run-out period (ending March 30), the period beginning March 1, 2020 and ending (for example, June 29) is disregarded for purposes of the calculation. So, you would have until 31 days after the end of the Outbreak Period (90 – 59 days between January 1 and March 1) to submit claims and still be timely for purposes of the run-out.

Q: What is the impact to grace period and carryover deadlines that occurred during the Outbreak Period?
A: We do not know at this time. We are engaged with outside counsel and with advisory agencies for ambiguities not directly addressed in the relief, such as:

  • Do "claims procedures" include any Healthcare FSA grace periods?
  • How are carryover calculations impacted?

Q: Will prior denied claims that are now eligible be reprocessed?
A: 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.

Q: What is the impact to my claim appeal deadline?
A: 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. Since her 180-day period began before March 1, however, that portion would still be included in the calculation. You would, therefore, be afforded 148 days (subtracting the 32-day period between January 28 and March 1) from the end of the Outbreak Period, which would be November 24, 2020.