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The CARES Act and its impact on account-based plans


The (CARES) Act, signed into law on Friday, March 27, 2020, includes numerous provisions that will impact U.S. employers. Additional detail can be found in Alight’s Coronavirus Aid, Relief, and Economic Security (CARES) Act update. This posting summarizes the provisions that impact account-based plans.

The passing of the CARES Act allows:

  • High deductible health plans (HDHPs) to temporarily cover telehealth services “pre-deductible” without disqualifying the participant from contributing to a Health Savings Account (HSA).

  • Account-based plans (HSAs, healthcare FSAs, HRAs and MSAs) to cover over-the-counter medical products without a prescription. This reverses a previous Affordable Care Act (ACA) exclusion.

  • Account-based plans (HSAs, healthcare FSAs, HRAs and MSAs) to cover menstrual care products.

  • Reimbursement of student loan payments under Qualified Educational Assistance Programs, as long as the payment is made before January 1, 2021.

In addition to the CARES ACT, Treasury Department/IRS also provided additional COVID-19 related guidance for account-based plans. Specifically:

  • Because the deadline for filing 2019 federal income tax returns is now July 15, 2020, individuals are permitted to make contributions to their HSA for 2019 until that same date (July 15, 2020).

  • HDHPs can cover COVID-19 testing and treatment “pre-deductible” without disqualifying the participant from contributing to an HSA.

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