COVID-19 impact on Flexible Spending Accounts

The “Consolidated Appropriations Act, 2021” was signed on December 27, 2020 . Since December, the 5600 pages of the Act have been further clarified and defined, and at this time we would like to share the provisions of the Act being offered to Cornell faculty and staff – and the impact of those provisions on Flexible Spending Accounts.

 

FLEXIBLE SPENDING ACCOUNT - MEDICAL CARE (FSAMC) IMPACTS

2019 Accounts and Balances

  • There are no additional changes to 2019 FSAMC accounts under this Act, but earlier Acts have impacted 2019 accounts.
  • Dates of Service: Claims against 2019 accounts are allowed for dates of service: 1/1/2019 – 12/31/2019.
  • Deadline to Submit Claims: Claims for 2019 dates of service must be submitted no later than 4/30/2021

 

2020 Accounts and Balances

  • Unused Balance Carryover: In early 2021, if you had unused 2020 FSAMC balances, up to $550 of your balance was automatically ‘carried-over’ to a 2021 account. Under the new provisions of this Act, your ENTIRE unused balance from 2020 will be ‘carried-over’ to a 2021 account. Before the end of March, you will see your PayFlex account adjusted to reflect any additional unused 2020 amounts (above the $550 already processed), then available for 2021 claims.
  • Dates of Service: Claims against 2020 balances are allowed for dates of service: 1/1/2020 – 12/31/2020; Once your 2020 balances have carried-over, they will be available for dates of service in 2021.
  • Deadline to Submit Claims: Claims for 2020 dates of service must be filed no later than 4/30/2022 (unless the pandemic officially ends earlier and the date is moved earlier).

 

2021 Accounts and Balances – NOW with the Ability to change your 2021 Elections!

  • You may now make changes to your 2021 Election, without experiencing a life status change! Under this Act, Cornell will allow you to make additional changes to your 2021 FSAMC, from March 15, 2021 to December 15, 2021. We will allow all benefits-eligible faculty and staff to ADD, CHANGE (move election higher or lower) OR TERMINATE a 2021 FSAMC in Workday (see instructions below). NOTE: you will not be able to reduce your 2021 election to an amount lower than contributions you have already made or reimbursements already received/submitted to PayFlex. There can be no refunds of contributions currently in the account.
  • Unused Balance Carryover: Before the end of March 2021, any unused 2020 FSAMC balance will become available in your 2021 account for dates of service in 2021. Before the end of 2021, we will announce the carryover provision from 2021 to 2022.
  • Dates of Service: Claims against 2020 balances are allowed for dates of service: 1/1/2020 – 12/31/2020; Once your 2020 balances have carried-over into a 2021 account, they will be available for dates of service: 1/1/2021 – 12/31/2021.
  • Deadline to Submit Claims:  Claims for 2020 dates of service must be filed no later than 4/30/2022. Claims for 2021 dates of service must be filed no later than 4/30/2022.

 

 

FLEXIBLE SPENDING ACCOUNT – DEPENDENT CARE (FSADC) IMPACTS

 

2019 FSADC Accounts and Balances

 

  • There are no additional changes to 2019 FSADC accounts under this Act, and earlier Acts also did not impact 2019 accounts.
  • Dates of Service:  Claims against 2019 accounts were allowed for dates of service: 1/1/2019 – 3/15/2020.
  • Deadline to Submit Claims: Claims for 2019 accounts were due to be submitted no later than 4/30/2020. (there was no extension based on any of the 2020 or 2021 Acts).

 

2020 FSADC Accounts and Balances

  • Unused Balance Grace Period: 2020 FSADC accounts were allowed a ‘grace period’, extending 2020 balances to be used for dates of service from 1/1/2020 – 3/15/2021. Under this new Act, the grace period for 2020 balances is now extended to 12/31/2021. (i.e. your 2020 balance can be used for 2020 claims and 2021 claims, for dates of service through 12/31/2021).
  • Dates of Service: Claims against 2020 unused balances are allowed for dates of service: 1/1/2020 – 12/31/2021; 2020 balances remaining as of 12/31/2021, will be forfeited. Only 2021 unused contributions will have the grace period from 1/1/2021 to 3/15/2022.
  • Deadline to Submit Claims: Claims for 2020 accounts (with dates of service 1/1/2020 – 12/31/2021) must be filed no later than 1/31/2022.

 

2021 FSADC Accounts and Balances – NOW with the Ability to change your 2021 Elections!

  • You may now make changes to your 2021 Election, without experiencing a life status change! Under this Act, Cornell will allow you to make additional changes to your 2021 FSADC, from March 15, 2021 to December 15, 2021. We will allow all benefits-eligible faculty and staff to ADD, CHANGE (move election higher or lower) OR TERMINATE a 2021 FSADC in Workday (see instructions below). NOTE: you will not be able to reduce your 2021 election to an amount lower than contributions you have already made or reimbursements already received/submitted to PayFlex. There can be no refunds of contributions currently in the account.
  • Unused Balance Grace Period: 2021 FSADC accounts are allowed a ‘grace period’, for dates of service from 1/1/2021 – 3/15/2022. Before the end of 2021, we will announce if the grace period will be adjusted further in 2022.
  • Dates of Service: Claims against 2021 balances are allowed for dates of service: 1/1/2021 – 3/15/2022; Once any remaining 2020 balances have been applied to your 2021 account, they will be available for dates of service: 1/1/2021 – 12/31/2021.
  • Deadline to Submit Claims: Claims against 2020 unused amounts (with dates of service 1/1/2020 – 12/31/2021) must be filed no later than 1/31/2022. Claims for 2021 contributions (for dates of service 1/1/2021 – 3/15/2022) must be filed no later than 4/30/2022.

 

CHILD CARE GRANTS – POSSIBLE IMPACTS due to changes you make above

  • If you received a 2020 Child Care Grant, it will follow the same process/procedures/deadlines as the 2020 FSADC above.
  • If you received a 2021 Child Care Grant, it will follow the same process/procedures/deadlines as the 2021 FSADC above.

You may want to reconsider your expenses and needs for child care in 2021, to determine if you need your full election for 2020 and 2021 to use against 2021 expenses.

When you submit a claim for reimbursement for dependent care expenses, please also remember that your Child Care Grant award is used first, then your own election is used.

Should you wish to make a change (increasing or decreasing) to your FSADC in 2021, ONLY your voluntary contribution is in Workday. YOU WILL NOT enter or make changes to your Child Care Grant in Workday. For any questions on the Child Care Grant, please send an email to childcare@cornell.edu.

 

WANT TO MAKE A CHANGE TO YOUR 2021 FSA ACCOUNT (either FSAMC or FSADC)?

You’ll enter your new election in Workday – to either ADD a new Account, CHANGE an existing Election, or STOP future contributions.

First, access your Benefits icon via Workday:

  1. In the top left menu, under “Change”, select “Benefits”.
  2. On the Change Benefits page, under “Change Reason”, select “FSA Special Enrollment COVID-19”.
    1. Enter a benefit event date, which must be the current date or later. Using a retroactive date will result in an error. See the “Please Be Aware of Timing Impacts” message below.
  3. Click the “Submit” button at the bottom of the page.
  4. Click "Open" and then the "Let's Get Started" button to go to the enrollment event.
  5. Pick the FSA plan you wish to change. If you wish to change both FSA – Medical Care and FSA – Dependent Care, you must process each plan separately. Within either plan, you will need to complete two pages in Workday and then submit. Click “Manage’ for the first plan you wish to change.
  6. You’ll see the same instructions on each of the two screens you’ll need to complete. Follow the instructions carefully.
  7. When you’ve completed your enrollments, click “Review and Sign” at the bottom of the Accounts page, and confirm that your elections are correct.
  8. Once you’ve confirmed that your elections are correct, remember to click “Submit.”
    1. Until you see the “Submitted” message, your enrollments/changes have not actually been submitted to benefits for processing.
    2. We encourage you to print a copy of your submitted change.

 

PLEASE BE AWARE OF TIMING IMPACTS: Changes you enter into Workday (whether additions, changes or terminations) will need to be validated and approved BEFORE they will be effective. Due to the volume of submissions and the need for Benefits to validate your new election, your year-to-date contributions, and your claims submitted/reimbursed at PayFlex, it may require a full pay-cycle or more to be effective. We encourage you to submit your elections more than one-week before your next paycheck, and allow for up to two paychecks for it to be effective.

 

We hope that this information has been helpful in clarifying the complicated options under the “Consolidated Appropriations Act, 2021”.

After reviewing your current accounts and needs, if you still have additional questions, please contact us at the HR Services and Transitions Center (HRSTC), at (607) 255-3936 or via email: hrservices@cornell.edu.

 

Thank you,

 

Gordon L. Barger

Sr. Director, Benefit Services and Administration