Coronavirus Aid, Relief & Economic Security (CARES) Act

March 30, 2020

On Friday, March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief and Economic Security (CARES) Act to aid businesses, workers, and the U.S. healthcare system in dealing with the coronavirus pandemic.

The CARES Act contains the following key provisions that affect health savings accounts (HSAs), health reimbursement arrangements (HRAs), and health flexible spending arrangements (FSAs):

• A high-deductible health plan (HDHP) with a health savings account (HSA) will be allowed to cover telehealth and other remote care services prior to an individual reaching the deductible. This allows HDHP participants to receive first-dollar coverage for these services without disqualifying them from being eligible to contribute to a health savings account (HSA). This provision is temporarily in effect beginning January 1, 2020 through December 31, 2021.

• Non-prescribed, over-the-counter medicine and medical supplies are now covered as qualified medical expenses for healthcare FSA, HSA, and HRA (if applicable). This includes over-the-counter menstrual care products. The changes take place retroactive to January 1, 2020 with no expiration date. This provision reverses laws put in place as part of the Affordable Care Act in 2011, which stated that over-the-counter expenses were only eligible for reimbursement with a prescription.

IMPORTANT NOTE: Full implementation of the second provision listed above requires SIGIS (Special Interest Group for IIAS Standards) and merchants to take action. 

The key driver behind the change will be the availability of any updated list of eligible products from SIGIS and the implementation of that list by participating merchants.

Our benefit card provider anticipates that SIGIS and merchant implementation of the new eligible item list will occur gradually within 4-6 weeks. The first step is for SIGIS to update its eligible product list and publish it to merchants for download. Current SIGIS rules require merchants to update their point of sale (POS) systems on at least a monthly basis, and we anticipate many will likely do this as soon as the new list is available.  However, it is important to emphasize that each merchant will adhere to their own timeline for completion of this process based on their own internal considerations, and card processors have no ability to influence this. 

Plan participants will be able to submit claims online or via the Chard Snyder mobile app to get reimbursed until the technology is available on the Chard Snyder Benefit Card. The mobile app also has an eligible expense scanner available, so participants can use that to verify that the product is eligible while they are at the point of sale.

How The Federal CARES Act Impacts Your Health FSA/HSA - This quick guide for health FSA and HSA participants explains how the Coronavirus Aid, Relief, and Economic Security (CARES) Act impacts their plans.