With many employees furloughed or on reduced hours due to the COVID-19 pandemic, the
Why
The assumptions that employees made during their 2020 benefit elections may have substantially changed since those elections were made at the end of 2019. Rather than waiting until the end of 2020 to make revised elections for 2021, the
If an employee had initially declined employer health coverage for 2020, the employee may enroll in coverage on a prospective basis
If an employee had initially made an employer health plan election, the employee may make a different election on a prospective basis
An employee may revoke an existing election of employer health coverage on a prospective basis without making a new election if the employee attests in writing that he or she has other health coverage
An employee may revoke an election, make a new election or revise an election with respect to a health flexible spending account or a dependent care flexible spending account, including limited purpose health FSAs
Flexible spending accounts may be allowed to extend a carryover period or a grace period ending in 2020 to the end of 2020, as well as reimburse expenses incurred through the end of 2020
An employer may allow an employee to make multiple mid-year election changes in 2020
Employers have flexibility to adopt all, some or none of these changes, so long as it is done on a nondiscriminatory basis
Employers adopting all or some of these changes are required to make plan amendments by
A change in an employee's health flexible spending account election could still affect the ability of an employee to make health savings account contributions during that period
A health plan is permitted to reimburse premiums paid for coverage commencing in the plan year even if the covered individual actually paid the premium for the coverage in the prior year
The
Who
Tax expert
Contact
To arrange interviews with
+1-847-267-2225
Bart.Lipinski@wolterskluwer.com
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