CARES Act: Impact on HSA,FSA, and HRA Benefit Account

Impact on HSA,FSA, and HRA Benefit Accounts


On Friday March 27th the Coronavirus Aid, Relief, and Economic Security Act or the CARES Act was signed into law. The bill included a change impacting the use of funds from HSA, FSA, and in some instances HRA health benefit accounts. The bill reverses the prescription requirement for Over the Counter Drugs (OTC) for reimbursement and also includes eligibility for menstrual care products. The bill had a retroactive start date of 1/1/20. OCA will now be able to manually reimburse OTC drugs when eligible under a member’s HSA, Health FSA and/or HRA benefit account.

Regarding the use of OCA’s debit card and OTC purchases, OCA is working with The Special Interest Group for IIAS Standards (SIGIS), who is responsible for the development and management of an industry standard to meet IRS requirements for operating an inventory information approval system (an “IIAS”). Together, we are making changes as quick as possible for future transactions. We expect it will take some time for all the products to be identified and updated in every merchant’s system. The current pandemic will create additional challenges in making that happen. Consumer experience will be inconsistent across items and products in the near future but should improve quickly.

Today, SIGIS announced its implementation process and timeline to update the eligible expense list to include OTC expenses as well as menstrual care products. OCA has summarized the SIGIS announcement below. To view SIGIS formal press release, please click here.

  • SIGIS is reviewing 19,111 OTC Drugs and Medicines items to include in their database and doing a full review on 913 items in our Feminine Care categories which include Menstrual Care. SIGIS goal is to have all this reviewed and published by 4/15/20.
  • Upon merchants downloading the updated list with revised statuses and processing those changes into their point of sale systems, consumers will be able to proceed through normal checkout lanes and use their OCA healthcare benefit debit cards for the purchase of these products.
  • While the 4/15 list publication will be a significant start, we expect large changes to be published in the following months as merchants and manufacturers submit items not currently in the SIGIS database for eligibility review. There will also be merchant responsibility to ensure their systems get updated with the item revisions.

It will be important, that consumers, plan administrators, manufacturers, point of sale vendors and merchants work together and provide mutual understanding while this change gets rolled out.

To view the OTC employee flyer click here!

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