On Tuesday, May 12, 2020, the IRS issued Notice 2020-29 and Notice 2020-33. These Notices included major changes to Section 125 and FSA benefits that may be financially beneficial to plan participants. Some provisions, however, require adoption by the plan. Here is a summary of the provisions included in each Notice:
IRS Notice 2020-29
IRS Notice 2020-33
As we communicated in our Sentinel Alert on May 4, 2020, the Final Rule announced by the Agencies provided extensions to deadlines tied to benefit plans. These extensions cover HIPAA Special Enrollment, COBRA, and claims filing. As a follow up to that Alert, the Agencies have made it clear that the claim filing extensions do apply to any Health FSA, Limited Purpose FSA, and HRA (but not Dependent Care and Commuter Accounts). This means that any plan year which was in its run-out period on or after March 1, 2020 will have an extended period of time to submit expenses incurred during the plan year, though the end date to submit claims will not be defined until the National Emergency is declared to be over.
Sentinel’s Health & Welfare Team will be hosting a webinar within the next week to review the legislative changes introduced in the IRS Notices referenced above, as well as what was introduced as part of the Final Rule. Additionally, for all clients for whom Sentinel administers an FSA Plan, Sentinel will be reaching out via email in an effort to capture which changes, if any, your plan wishes to adopt in response to the release of IRS Notices 2020-29 and 2020-33. Lastly, if you have questions about these changes, please contact your Sentinel FSA/HSA/HRA Account Manager directly to discuss the specifics as it relates to your plan.