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CARES Act Prescription Requirement Reversed

Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) reverses prescription requirement for Over-the-Counter (OTC) products


COVID-19 is an unprecedented global event that is changing our personal, business and economic environment daily. Recently the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) was signed into law. Among other provisions, this legislation reverses the prescription requirement for Over-the-Counter (OTC) drugs for HSA, HRA, and FSA reimbursement and includes eligibility for many products not eligible in the past. The acceptance of OTC products as eligible medical expenses is retroactive to January 1, 2020.  

The following Questions and Answers are provided to assist FSA, HRA and H S A participants in better understanding how changes will occur that will allow acceptance of OTC products as eligible medical expenses at point of sale, as well as filing manual claims and changing elections.

Can I use my debit card for OTC purchases now?

The first step in allowing reimbursement of OTC items, will require merchants who sell OTC products, to update their POS (point of sale) systems to read the OTC items as an eligible medical expense. These system changes may take several months and most likely will occur first at the big national stores and slower for smaller stores and chains. Until merchants make these system changes, debit cards will not accept OTC purchases as being eligible medical expenses and will require another means of payment.

Where can I find a list of eligible OTC products?

SIGIS (Special Interest Group for IIAS Standards) is working to identify changes to the eligibility criteria and OTC Eligible Product List. We expect it will take some time for all the products to be identified and updated in every merchant’s system, but will keep participants informed of changes and additions as they are made available to us. Online resources such as FSAstore.com and Drugs.com, are industry leaders that respond quickly to consumer needs and should provide a list of eligible OTC products promptly.

How can I be reimbursed for OTC products I have paid for out of pocket or with a card other than my debit card?

Participants who pay for eligible OTC products during this transition period (retroactive to January 1, 2020), may file a manual claim for reimbursement. A manual claim form may be downloaded from this website. 

Your manual claim submission must include specific information to verify the eligibility of the purchase.  IRS Rules require a detailed receipt from a merchant, pharmacy, doctor, or other healthcare provider, should include: 1) the date of the service or purchase; 2) the name of the provider or merchant where purchase was made; 3) the service performed or item purchased; and 4) the amount the employee paid f\or is responsible for paying. You may also provide an Explanation of Benefits (EOB) your health plan if a portion of the purchase was covered by your medical plan.

How do I change my original election for my pretax account since my employment status has changed?

If you wish to change your DCA and/or FSA election, you should complete a Qualified Status Change Form and email, fax or mail the form to our office.  We will make the change as requested. You may download a Qualified Status Change Form from this website.  If you have an HSA, you can change your contribution for this year at any time, up to the IRS limit. 

You may email the Qualified Status Change Form, Manual Claim Form and Documentation to flex@usadmin.com or febco@febco.com or fax to 423-634-0625 or 502-695-9292.  Mailing Address:  P. O. Box 11045, Chattanooga, TN  37401.

We expect more changes to occur rapidly as we go through day to day challenges in our lives due to this virus.  As we look to an end to this crisis, we encourage you to continue to adhere to all mandated requirements for maintaining health and safety for you and your family.  Please contact our office should you need assistance or have other questions.


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$500.00 FSA Rollover Option Information

If your FSA plan includes the $500.00 Rollover option then those funds will be rolled into the new plan year once the Run Out period has ended. The Run Out period generally runs about 90 days, but varies per employer. The purpose of the Run Out period is to give participants time to submit claims for expenses incurred during the previous plan year.

DO NOT run your benefits card for last "year" claims. You MUST submit prior plan year claims to us during your Run Out period.