Outbreak Start Date:
March 1, 2020
Outbreak End Date:
60 days after the announced end of the COVID-19 national emergency (currently open-ended)
Impact on Deadlines:
The outbreak period is to be disregarded in the calculation of all Health FSA and HRAs deadlines addressed in this notice.
Deadline Extensions This update only effects claims submission deadlines that fall within 2020. Although these deadlines have been suspended for the duration of the outbreak period, they will resume immediately after the outbreak ends. Examples The following example is provided for clarity. These examples assume the following hypothetical scenario facts: • The COVID-19 national emergency is announced to end on May 31, 2020. • The Outbreak Period will end 60 days after May 31, 2020. • The Outbreak Period is, then, March 1, 2020 through July 30, 2020.
Regular Deadline March 31st
New COVID-19 Deadline
July 30 th
2019 Claim Submission Deadline 2019 Claim Submission Deadline for Grace Period Plans
Using this example, employees that previously had until March 31, 2020 to submit their 2019 claims, now have until July 30, 2020. Applied to Which Plans? This extension also applies to submission deadline associated with grace period plans, however, if the claims incurred deadline for these plans is extended through December 31, 2020, it is assumed claims can be submitted through that time as well. This deadline extension applies to Welfare plans that provide health benefits, this includes Health FSAs and HRAs. This extension does not apply to Dependent Care FSAs or Parking plans. Employer Action Considerations This ruling is not optional. FSA/HRA administrators will need to administer claims submission deadlines to disregard the Outbreak Period. Employers should expect that some claims submissions will be processed against outstanding 2019 balances.
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