The Cares Act & Flexible Benefits

4/13/2020 - By Judy Fryer


Participants may be interested in updating their flexible benefits due to changes in their health and lifestyle experiences. Here are the guidelines on what is allowable under current guidelines:

  • MEDFSAs - Participants cannot make election changes without a qualifying life event. Having more or less medical expenses does not qualify. The MEDFSA grace period cannot be extended beyond the 2 month and 15-day extension for incurring expenses, but employers could extend the runout period to file eligible claims if needed. The carryover limit remains at $500 for unused MEDFSA funds.
  • DEPCARE - Participants can update their dependent daycare expense election if there is a change in the childcare provider or cost of coverage as long as the update is consistent with the change. For example, if a daycare provider stopped service due to COVID-19, the election can be reduced or eliminated. Annual Limits still apply.


The Cares Act extended the list of eligible expenses for Health Saving Account (HSA), Health Reimbursement Arrangement (HRA), and Flexible Spending Account (FSA) to include menstrual care products and then mandated that over-the-counter (OTC) medications are covered without a doctor’s prescription. We are making updates to extend these benefits to the participants.

  • Debit Card Purchases (TakeCare card) - To pay for OTC medications and menstrual products is dependent on the timing of the updates of the eligible products provided by SIGIS (Special Interest Group for IIAS Standards) out to the merchants to update their systems as well as add their own brand products. (I.E. - Equate at Wal-Mart). Until these updates have occurred, participants will need to submit the receipts on a manual claim or all via the Mobile App for reimbursement. This change is effective for any eligible expenses purchased after 12.31.2019.
  • Claims Reimbursement - Participants can submit claims for menstrual care products and OTC medications without a doctor’s prescription. The date of purchase must be after 12.31.2019. Claims can be submitted online at


  • Tax deadline and HSA contributions - IRS tax filings have been extended to July 15, 2020. This includes the 2019 contribution deadlines to health savings accounts (HSAs) and Archer medical savings accounts (MSAs). The deadline to make those eligible to contribute to a 2019 account has until July 15, 2020, to make those 2019 contributions. The maximum annual contribution has not changed. For 2019, $3,500 for individual policies and $7,000 for Employee plus 1 or more. The catch-up contribution remains $1,000 for those 55 years of age and older.
  • Telemedicine – The Coronavirus Aid, Relief and Economic Security Act (CARES Act) provides for reimbursement for services for “telemedicine and other remote care services” below the deductible and will be permitted in an HSAqualified plan (HDHP). This provision is effective March 27, 2020, through December 31, 2021.


If you have specific questions, please reach out to our Flexible Spending Plan Administration team.

Visit our COVID-19 RESOURCE HUB for ongoing updates and information. Due to the ever-changing nature of this event, you should always consult a professional.

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