The Internal Revenue Service issued guidance Tuesday to make temporary changes to section 125 cafeteria plans, with the goal of providing tax relief and flexibility in the midst of the novel coronavirus pandemic. The IRS is extending the claims period for health care flexible spending arrangements and dependent care assistance programs and enabling taxpayers to make mid-year changes to their accounts.
The guidance released Tuesday by the IRS deals with the unanticipated changes in expenses faced by many taxpayers as a result of the COVID-19 pandemic. The IRS is now allowing its previously provided temporary relief for high deductible health plans to be applied retroactively to Jan. 1, 2020, and also increases for inflation the $500 permitted carryover amount for health FSAs to $550.
Karen Monks is a Principal Analyst in Celent's North American insurance practice. She brings a broad range of insurance and consulting experience to her work; she has worked as a management consultant to and within insurance carriers and other financial services companies for over 25 years.
Karen's focus is life insurance technology and trends. Her research concentrates on life, all aspects of life insurance processing including illustrations, eApplications and eSignature, new business and underwriting systems, policy administration systems, claims systems, and digital enablement technologies. Her consulting experience at Celent includes new business and underwriting system selections, policy administration system selections, distribution management system selections, vendor product strategy reviews, a life claims system benchmarking project, eApplication and automated underwriting cost analyses, plus several small life insurance technology analyses. Karen led Celent's Knowledge Management team for seven years. The KMC supports Celent's vendor assessments across all practices and helps manage vendor data on Celent's online platform, VendorMatch. She helped build out Celent's VendorMatch Digital Services Platform.
Mary Mulcare, MD, FACEP, is the Chief Medical Officer at Summus and oversees all clinical aspects of operations. Mary also serves as a Clinical Assistant Professor of Emergency Medicine at NewYork-Presbyterian/Weill Cornell Medicine, and has held several leadership roles at Weill Cornell, including Director of Undergraduate Medical Education in the Department of Emergency Medicine and Assistant Director of the Margaret and Ian Smith Clinical Skills Center.
Sam Raus studies public relations and political science at the University of Miami. Follow him on Twitter: @SamRaus1.
In Notice 2020-29, the IRS is offering extra flexibility to taxpayers by:
- extending the claims periods for taxpayers to apply unused amounts remaining in a health FSA or dependent care assistance program for expenses incurred for those same qualified benefits through Dec. 31, 2020;
- expanding the ability of taxpayers to make mid-year elections for health coverage, health FSAs and dependent care assistance programs, allowing them to respond to changes in needs as a result of the COVID-19 pandemic; and
- applying earlier relief for high-deductible health plans to cover expenses related to COVID-19, and a temporary exemption for telehealth services retroactively to Jan. 1, 2020.
In conjunction with that notice, the IRS also issued Notice 2020-33, in response to the Trump administration’s Executive Order 13877, which directs the Treasury secretary to “issue guidance to increase the amount of funds that can carry over without penalty at the end of the year for flexible spending arrangements.” The notice ups the limit for unused health FSA carryover amounts from $500, to a maximum of $550, adjusted each year for inflation.



