Concerning your FSA/HRA

To our Valued Clients:

We have a very important update to announce to you! On Friday, March 27th  the President signed The CARES Act into law.

This law has many important components, one of which permanently reinstates coverage of Over the Counter (OTC) drugs and medicines as items eligible for reimbursement under Code 213(d) expenses in FSA, HRA, and HSA plans. With this law, the drugs and medicines will no longer require participants to have a prescription to prove eligibility.

  • A high-deductible health plan (HDHP) with a health
    savings account (HSA) will be allowed to cover telehealth and other remote care
    services prior to an individual reaching the deductible.
    This allows HDHP
    participants to receive first-dollar coverage for these services without
    disqualifying them from being eligible to contribute to a health savings
    account (HSA). This provision is temporarily in effect beginning January 1,
    2020 through December 31, 2021.
  • Non-prescribed, over-the-counter medicine and medical
    supplies are now covered as qualified medical expenses for HSA, HRA, and health
    FSA purposes.
    This includes over-the-counter menstrual care
    products. The changes take place retroactive to January 1, 2020 with no
    expiration date. This provision reverses laws put in place as part of the
    Affordable Care Act in 2011, which stated that over-the-counter expenses were
    only eligible for reimbursement with a prescription.

IMPORTANT NOTE:  Regarding the OTC medicine and medical supplies, this will occur gradually over the next 4-6 weeks as SIGIS (Special Interest Group for IIAS Standards) will make available the list to be implemented by participating merchants.