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COVID-19: Changes to HRA, HSA and FSA rules

The Coronavirus Aid, Relief, and Economic Security (CARES) Act signed into law as of March 27, 2020, contains important provisions that will affect Health Reimbursement Accounts (HRAs), Health Savings Accounts (HSAs) and Flexible Spending Accounts (FSAs).

New reimbursable expenses

Under the CARES Act, you can now pay for or receive reimbursement for:

  • Over-the-counter drugs and medicines without a doctor’s prescription.
  • Menstrual care products (now considered a qualified medical expense) through an FSA, HRA or HSA. All expenses incurred after December 31, 2019, qualify, and the provision has no expiration date.

UC’s HSA and FSA administrators are working to update their plan documents and websites to reflect these changes. Please note that you may not be able to use your HSA or FSA debit card to purchase these newly-qualified items until retailers have updated their systems. Remember to keep your receipts so you can submit claims for reimbursement.

Eligible FSA enrollment and contribution changes

Under the CARE Act, you can enroll, disenroll or change contribution amounts to Health and Dependent Care FSAs if your status changes because of the COVID-19 epidemic. Note: You must request a change to your FSA within 30 days of your change in status (for example, the date your spouse became unemployed or your child stopped attending daycare).

Health FSAs

If your spouse loses a job and eligibility for their employer’s Health FSA plan due to the pandemic, you may enroll in UC’s Health FSA plan or update your contribution amount.

Dependent care FSAs

If your child’s school closes and you need to purchase daycare so that you can work, you can enroll in the Dependent Care FSA or increase your election.

If your child’s daycare closes and you don’t need daycare while you’re working from home, you can decrease or cancel your FSA election. If you reduce your annual contribution to the amount you’ve already contributed this year, you will have through the end of the year to use any remaining funds in your account. If you disenroll from your FSA, you may only be reimbursed for expenses from Jan. 1 (or your start date) through the date you stop participating – unless you enroll again promptly once your situation returns to normal.

Once your work schedule and childcare expenses return to normal, you will once again be eligible to make changes to your FSA elections — reducing or increasing your expenses, or enrolling or disenrolling in the plan.

Review the Dependent Care FSA Summary Plan DescriptionPDF or Health FSA Summary Plan DescriptionPDF for details about the FSA plans.

How to request FSA changes

Log in to UCPath Online and complete the Health Benefits Enrollment Form for Life Event (PDF) to change your FSA enrollment or contribution. In section 2, for your qualifying life event, select “Other – Explain.” Write in “COVID-19.” Once your form is complete, submit it as a secure message on UCPath.

Your Health FSA

If you have an HSA, you can change your contribution at any time, and you have until April 15 to make contributions for the previous year. To make the change, contact UCPath via secure message, or your Benefits Office if you are not at a UCPath location.

Important note about 2019 plan year expenses

Though the April 15 tax filing date has been extended until July 15, 2020, the Health and Dependent Care FSA filing deadlines have not been extended. Remember to file claims for your eligible 2019 expenses by April 15, 2020.

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Comments ( 14 )

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  1. Nancy Chamberlain March 31, 2020 Reply

    Could you please outline the steps to modify DEPCARE FSA deductions?

    • Michelle Simone March 31, 2020 Reply

      Hi Nancy, you’ll want to make the change at UCPath. We’re in the process of determining exact instructions and they will be posted here as soon as they’re available.

    • Michelle Simone April 2, 2020 Reply

      Hi Nancy! These instructions have been added.

  2. Kristin Adkins April 17, 2020 Reply

    Hi, can someone please help, I would like to make changes to my FSA enrollments due to COVID-19 and I work at UCSF and UCPath is not live until 6/1. Where can I submit my form? Thank you in advance!

    • Michelle Simone April 17, 2020 Reply

      Hi Kristin: Since you’re at a UC location that uses At Your Service Online to manage benefits, you’ll want to complete the UPAY 850 form (PDF) and submit it to your local benefits office.

  3. Rich July 2, 2020 Reply

    Is there any plan to extend the carry over limit since dentists have been closed and won’t be able to get all work I had planned on doing this year.

    • Michelle Simone July 3, 2020 Reply

      Hi Rich, the health FSA carryover option from 2020 to 2021 has been increased a little bit — from $500 to $550 (HSA funds always carry over). If you’re contributing more than you think you can use this year, you also have the option to reduce your contribution to whatever you’ve already contributed for the year. These updates are detailed on UCnet.

  4. Bridget Parr July 14, 2020 Reply

    How do I change my depcare FSA contribution? I can’t fill out the form listed above to change the depcare FSA amount because the form won’t let me enter an amount. I can’t find a phone number to call either. I find UC Path very confusing to actually talk to a person, The only phone number I called says nobody is working in the the office and so the number isn’t working. What is the phone number to contact a person to direct me in navigating the necessary changes? Address or fax machine numbers to send forms? I don’t have all day to explore this site to find a person!!!! It’s very frustrating.

    • Michelle Simone July 14, 2020 Reply

      Hi Bridget — Unfortunately our colleagues at the UCPath Center are also unable to work from the office due to COVID-19; however, live representatives are available via chat during business hours on several pages and you can also connect with them by logging in to UCPath online and selecting “Ask UCPath Center” to submit an inquiry. I have personally used this tool to connect with a representative and they are very responsive and helpful.

  5. Janyce September 1, 2020 Reply

    I have a FSA for transportation to/from work. We have been working from home since March. I have money still in my account. If I don’t use this by end of 2020 will I loose it?

    • Michelle Simone September 2, 2020 Reply

      Hi Janyce — As far as we know, the transportation account funds do not expire at the end of the calendar year. We are researching this further and will update you when we have more info.

  6. Tula Gourdin March 9, 2021 Reply

    I have $1200 in my HSA account for 2020. This amount was reserved for planned dental work that did not occur until 2021 due to the COVID restrictions. Now I understand I will lose the excess over $550–$650. My dental work was done in February 2021 and it wiped out my HSA for 2021. Is there a way I can retrieve the full amount of $1200 from my 2020 HSA to pay for the medical payments I will need to make this year.

    • Michelle Simone March 9, 2021 Reply

      Hi Tula — The Link editorial team isn’t able to provide advice regarding benefits. Please contact the UCPath Center for assistance.

  7. Tula Gourdin March 10, 2021 Reply

    Today we received a UCnetwork newsletter with welcome news on FSA/HSA accounts that responds to the concern I expressed in yesterday’s post. Hallelujah!
    “UC has approved some important temporary changes, giving you more time to use the money in your accounts — and the option to change your 2021 elections.” See the link:

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