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  • 2016 Flexible Spending Account (FSA) Plan Document Updates

    Language changes have been made throughout the Plan Document in regard to the nature and administration of the FSA Plan and the plan sponsor’s rights, duties, and obligations. These changes will be effective with plans renewing July 1, 2016, and forward.

    Principal Changes:

    Types of plan(s) offered under the FSA are now referred to as components.

    Previous name (plans) New name (components)
    Group Sponsored Insurance Plan Premium Payment component
    Health Related Expense Plan  Health FSA component (General-Purpose Health FSA option)
    Limited Flexible Spending Account Plan  Health FSA component (Limited-Purpose Health FSA option) 
    Dependent Care Assistance Plan DCAP component
    Supplemental Premium Account Plan SPA component 

    • Limited Flexible Spending Account Plan section – this section of the plan document is now incorporated under a Health FSA component, which consists of three account options: 
      • General-Purpose Health FSA option (HRE account)
      • Limited-Scope Health FSA option (LSFSA account), reimbursing vision/dental care, excluding preventive care, added for clients that want to offer the Health FSA component to employees not eligible for that client’s medical insurance plan
      • Limited-Purpose Health FSA option (LFSA account), reimbursing vision/dental/preventive care, for employees enrolled in a Health Savings Account (HSA) 

    • FMLA Leaves of Absence – there are now three methods for continuing coverage while on FMLA. The language for the pay-as-you go and the after-tax self-pay methods were determined to be duplicates and therefore combined into one method, titled pay-as-you-go. 

    • Coverage continuation – additional language has been added regarding coverage continuation (e.g., COBRA and Premium Completion Agreement) and the impact when Grace Period or Carryover Provision are part of the plan design. 
      • COBRA as applicable to Health FSAs (full COBRA vs special limited COBRA)
      • Premium Completion Agreement is voluntary. Eligible terminating employees will be required to complete and forward a new Participant Termination Form [Ed. 6/9/17: form change] to PSA.

    • Carryover Provision in regards to the Health FSA – additional language has been added to clarify the requirements for unused funds to carryover, and the coordination with an HSA. 
      • Any employee with coverage through the last day of a plan year can carryover unused amounts to the next plan year, including participants enrolled in COBRA or the voluntary Premium Completion Agreement.
      • An employer can amend the plan to limit the availability of carryover to employees that make a minimum salary reduction election to the Health FSA for the next plan year. To amend your plan, please complete the Carryover Provision Amendment Request form and forward to PSA.

    • Uncashed benefit checks – additional language has been added to explain benefit payments that are unclaimed.
    • Irrevocability of Elections; Exceptions – additional language has been added to explain that a change in Health FSA election cannot reduce future contributions to a point where the total contributions for the plan year are less than the amount already reimbursed for the plan year.  

    • Appendix A was added; Exclusions – Medical Expenses That Are Not Reimbursable From the Health FSA component