Feds Keeping Plan Sponsors On Their Toes

By GDI Client Services

We are over halfway through 2020 and sponsors of group health plans, IRS Code Section 125 plans and Health Reimbursement Arrangements may be reeling from the inordinate amount of new regulations coming forth from Washington, DC. See below for a list (and brief description) of 2020 regulatory items that impact the services we provide:

March 2020: The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) removed the requirement to obtain a prescription for over-the-counter drugs and medicines for participants in an FSA, HSA and certain types of HRAs. The Act also declared that menstrual care products are eligible for tax-free reimbursement from the same types of accounts. For more information, please read our Compliance Alert.

April 2020: The IRS & DOL issued joint guidance directing group health plans and insurers to disregard the period between March 1, 2020 and 60 days after the end of the COVID-19 National Emergency when calculating specific plan related time periods. More information can be found here.

May 2020: The Department of Labor got May started off by adding some new FAQs (relating to the interaction of COBRA and Medicare) to their sample COBRA notices. The IRS announced COVID-19 related temporary relief for Code Section 125 plan participants and High Deductible Health Plans on May 12th (additional information is available here) and on May 21st, the IRS announced the 2021 HSA annual contribution limits: $3,600 self-only coverage/$7,200 family coverage; HDHP minimum deductibles: $1,400 self-only coverage/$2,800 family coverage; and HDHP out of pocket limits: $7,000 self-only coverage/$14,000 family coverage.

At the time of publication, Congress is working through their differences on additional COVID-19 relief. We will keep you posted on any final legislation resulting from their negotiations.