• Taxpayers now have until July 15 to file their taxes. Can members contribute to their 2019 HSA funds up until the July deadline?

  Yes, contributions may be made to an HSA or Archer MSA, for a particular year, at any time during the year or by the due date for filing your return for that year. Because the due date for filing Federal income tax returns is now July 15, 2020, under this relief, you may make contributions to your HSA or Archer MSA for 2019 at any time up to July 15, 2020. See https://www.irs.gov/newsroom/filing-and-payment-deadlines-questions-and-answers for more details.

• Can employers provide telemedicine, testing and treatment below the deductible and with reduced or no copays without jeopardizing employees’ eligibility to make contributions for an HSA?

  Yes, the CARES Act provides for reimbursement for services for "telehealth and other remote care services" below the deductible and will be permitted in an HSA-qualified health plan. This provision is temporary and effective for plan years beginning on or before December 31, 2021. Expenses are eligible under FSA, HRA and HSA plans.

• How does the CARES Act change over-the-counter (OTC) and menstrual care products?

  The CARES Act has removed the requirement for prescriptions (Rx) in order to reimburse over-the-counter (OTC) drugs and medicines, effective January 1, 2020 with no expiration date. In addition, it newly allows for the reimbursement of menstrual care products.

Note: The FAQs above are provided to assist employers and plan sponsors with their research into the potential impacts of the recent IRS guidance. This is not legal advice, and the relief actions are complex and dynamic. As always, we strongly encourage employers and plan sponsors to consult their legal or benefits counsel for conclusive guidance on how the actions apply in their circumstances.