FSA / HSA / HRA

As we explained in 2020, funding for the Patient-Centered Outcomes Research Institute (PCORI) was supposed to end with filings and fees for plan years that began before October 1, 2019. In the words of the great philosopher Emily Litella, “Never mind.”

The COVID-19 Outbreak Period has had numerous impacts upon benefit plans, extending timelines with which plans had to perform certain activities.

President Biden declared the end of the National Emergency effective May 11, 2023. Employers must plan now for the end of the Outbreak Period.

It must be the holiday season. The IRS recently finalized new regulations providing that ALEs must furnish the Forms 1095-C to employees no later than 30 days after January 31st of each year. In the past, forms were due by January 31st unless an employer asked for an extension. It's now automatic.

The IRS has now released all of the 2023 benefit limits on October 21, 2022. Earlier this year, they also released the High Deductible Health Plan (HDHP) and Health Savings Account (HSA) limits.

The PCORI annual filing and fees were reinstated through 2029. That means that all employers (or their insurers in fully insured group health plans) must file the annual IRS Form 720 by July 31st of each year, regardless of their plan year.

The IRS has now released all of the 2022 benefit limits. Earlier this year, they also released the High Deductible Health Plan (HDHP) and Health Savings Account (HSA) limits.

In a recent news release, the IRS reminds employers and employees that the cost of COVID-19 home testing is an eligible expense under a health care flexible spending account (FSA), health reimbursement arrangement (HRA), and health savings account (HSA).

In IRS Information Letter 2021-13, the agency reiterates that Flexible Spending Account claims paid on an FSA debit card must have the required substantiation containing all of the information normally required for a claim submitted for reimbursement through other means such as mail, e-mail, or fax.

As we explained last year, funding for the Patient-Centered Outcomes Research Institute (PCORI) was supposed to end with filings and fees for plan years that began before October 1, 2018. Nope.

Last year's Consolidated Appropriations Act and this year's American Rescue Plan provided employers optional flexibility for their Dependent Care FSAs. But they also created a potential tax hurdle. The IRS fixed (most all of) it.

Starting in 2007, the Tax Relief and Health Care Act of 2006 (TRHCA) requires that the IRS release the upcoming year’s new HSA limits prior to June 1st. Thus, we now have the 2022 HSA limits.