In light of COVID-19 relief rules recently issued by the Internal Revenue Service (IRS) and the U.S. Department of Labor, and guidance issued by the University’s insurance carriers, certain employee and retiree benefit notice, election and claims deadlines have been extended. The University-sponsored benefit programs impacted by these changes are described more fully below.
This information is for your reference only. You are not required to take any action. However, if you have any questions on how these notifications may apply to your specific situation, please contact HR Shared Services at firstname.lastname@example.org or 315.443.4042.
A number of extensions below reference an Outbreak Period. The Outbreak Period, as defined under federal guidance, is the period from March 1, 2020, until 60 days after the announced end of the COVID-19 national emergency. For example, if the last day of the national emergency is Sept. 30, 2020, the Outbreak Period began on March 1, 2020, and ends on Nov. 29, 2020.
You generally have one opportunity each year to make changes to benefits during the University’s Open Enrollment period. However, if you experience a special enrollment event (including, but not limited to, gaining a new dependent by birth, marriage or adoption), you may make changes outside of this enrollment period, within 31* days of the event, provided all necessary forms and required documentation are submitted to the Syracuse University Office of Human Resources within this time period.
*You may make changes to your benefits coverage within 60 days if the event is due to eligibility for or loss of Medicaid or CHIP coverage.
Under recent government agency rules designed to provide relief during the COVID-19 pandemic, the University’s group health (i.e., active and retiree medical, dental/vision) plan deadlines for requesting special enrollment are extended as follows:
- For special enrollment events that occur on or after March 1, 2020, and before the last day of the Outbreak Period, the 31-day or 60-day deadline is extended to the date that is 31 or 60 days following the end of the Outbreak Period, as applicable.
- For special enrollment events that occurred before March 1, 2020, for which the usual deadline did not expire before March 1, 2020, eligible employees will have a specific number of days following the end of the Outbreak Period to submit an election. The applicable deadline is extended by the number of days that did not expire as of March 1, 2020.
These temporary special enrollment extensions do not apply if the usual 31 (or 60-day) deadline expired before March 1, 2020.
The following changes apply to the University’s health and dependent care flexible spending accounts (FSAs):
Extended 2019 Claim Deadline
Under the usual plan rules, an FSA claim incurred during 2019 must be submitted by April 30, 2020 to be eligible for reimbursement.
In light of the COVID-19 pandemic, participants will have additional time to submit health and dependent care FSA reimbursement requests. Under this temporary extension, a claim for expenses incurred during 2019 will be considered timely if filed on or before the date that is 60 days following the last day of the Outbreak Period.
Once the national health emergency is declared over and the 60 days have expired, up to $500 of any unused health care FSA funds from 2019 will be rolled over to the employee’s health care FSA for use in 2020. Please note there is no rollover permitted for the dependent care FSA.
Important Note: When employees log into their HealthEquity/WageWorks account, they will see a “claim by” date of Dec. 31, 2020 for their 2019 FSA. The claim by date is subject to change depending on when the Outbreak Period has been declared over. Therefore, employees are encouraged to submit claims for expenses incurred during 2019 as soon as possible.
Should you have any questions on the reimbursement process, contact the HealthEquity/WageWorks customer care team at 877.924.3967 (TTY: 866.353.8058).
2020 Mid-Year Election Changes and Increase in Carryover Amounts
Original expectations about your health and dependent care expenses for 2020 may have significantly changed due to the coronavirus (COVID-19) global pandemic. As a result, you may want to change your FSA elections for 2020.
Effective immediately, eligible faculty and staff are allowed to change health and dependent care FSA elections for 2020 without having a qualifying family status change.
Allowable changes must be made on a prospective basis, and include new elections as well as increases or decreases to existing FSA elections. If an election is made to reduce your health care FSA contribution, the reduced contribution must be no less than claims that have already been reimbursed or approved for reimbursement.
Additionally, beginning Jan. 1, 2020, the maximum amount of unused health care FSA contributions that can carry over to the next year has increased from $500 to $550, and will be adjusted annually for inflation.
If you wish to make a change to your 2020 FSA election, or have any questions, contact HR Shared Services at email@example.com or 315.443.4042.
Reimbursement of Over-the-Counter Medicines and Drugs and Menstrual Care Products
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) has expanded the list of health care items that are eligible for reimbursement from health care FSAs. The following health care expenses incurred after Dec. 31, 2019, qualify for reimbursement:
- Over-the-counter drugs and medicines such as antacids, allergy medicines, pain relievers and cold medicines (to the extent permitted by Code Section 213) can now be reimbursed even though they are purchased without a prescription. Dietary supplements (e.g., vitamins) which are merely beneficial to good health are not eligible for reimbursement, except for prenatal vitamins taken during pregnancy.
- Menstrual care products
Each of the University-sponsored benefit plans maintain a claims procedure that governs the filing of claims, the initial disposition of filed claims by the applicable claims administrator, and the appeal of adverse determinations on a claim.
The deadlines for filing benefit claims are summarized in each of the plans. Under applicable law, claimants have at least 180 days to appeal an adverse determination on a claim under the University’s group health (i.e., active and retiree medical, dental/vision) and disability plans. Under the 403(b) retirement plans and life and accidental death and dismemberment plans, appeals generally must be filed within 60 days following receipt of the adverse benefit determination.
The claim and appeal deadlines for University-sponsored group health, disability, 403(b) retirement, and life and accidental death and dismemberment plans have been temporarily extended. Participants are permitted additional time to submit claims (and request appeals of denied claims) if the usual deadline ends on or after March 1, 2020, and before the end of the Outbreak Period. If the usual deadline ends on or after March 1, 2020, and before the end of the Outbreak Period, the entire Outbreak Period shall be disregarded and the applicable deadline will resume once the Outbreak Period ends. If you are a participant who is eligible for extended time to submit a claim or file an appeal, the applicable benefit vendor or insurance carrier will automatically apply the extension for you.
Deadlines that expired before March 1, 2020 are not extended under these temporary extensions.
Premium Payment Relief
The following premium payment relief applies to current and former employees who have a responsibility to pay their own life insurance and accidental death and dismemberment premiums (e.g., via check or bank account debit). Employees for whom the University remits payments via payroll deduction on a regular basis are not impacted.
If you are facing financial hardship as a result of the COVID-19 pandemic, the grace period for the payment of your premiums will be extended to 90 days. If you are facing financial hardship as a result of the COVID-19 pandemic and are unable to make a timely premium payment, you will be able to arrange to pay this premium over a 12-month period. If you are late in making a payment, late fees will not be imposed by the insurance carrier (MetLife) and MetLife will not report you to a credit reporting agency or a debt collection agency regarding late premium payments due to financial hardship as a result of the COVID-19 pandemic. These grace periods and rights are currently in effect but are temporary, though they may be extended further by MetLife. The ability to pay over a 12-month period will also be available to you if you were issued a nonpayment cancellation notice prior to March 29, 2020, and did not make a timely premium payment due to financial hardship as a result of the COVID-19 pandemic.
Extension of Deadlines to Request Rights or Benefits Under the Plan
New York State regulations also provide a 90-day extension of deadlines to exercise any rights or benefits under your certificate as a result of the COVID-19 pandemic. The extended deadlines will apply for the purposes of submitting claims and filing appeals of adverse benefit decisions. If this applies to you, MetLife will automatically apply this extension; you do not need to contact MetLife.
Under rules issued by the IRS and U.S. Department of Labor, the Outbreak Period is disregarded in determining whether any of the following COBRA deadlines have been met:
- the 60-day period to elect COBRA coverage;
- the deadline to make COBRA premium payments; or
- the date by which an individual must notify the plan of a COBRA qualifying event or disability determination.
Extension of the COBRA Election Deadline
COBRA qualified beneficiaries have a period of at least 60 days to elect COBRA coverage after the election period begins. The election period begins on the date the COBRA election notice is received or, if later, the date coverage is lost.
The extension of the COBRA election deadline applies as follows:
- The extension does not apply if the COBRA election period expired before March 1, 2020, the beginning of the Outbreak Period.
- If a qualified beneficiary’s 60-day election period began prior to March 1, 2020, and would expire during the Outbreak Period, the deadline is extended by a specific number of days following the end of the Outbreak Period as follows: 60 days minus the number of days that expired from the start of the election period through March 1, 2020.
- If a qualified beneficiary’s 60-day election period begins on or after March 1, 2020, and before the end of the Outbreak Period, the 60-day election period does not begin until the end of the Outbreak Period.
Extension of the COBRA Premium Payment Deadline
If COBRA is elected, a qualified beneficiary has 45 days to pay the initial COBRA premium.
Future premiums are due in monthly installments (generally as of the first day of the month), subject to a 30-day grace period.
For qualified beneficiaries whose initial COBRA premium payment becomes due during the Outbreak Period, the deadline to make the initial COBRA premium payment is extended until 45 days after the end of the Outbreak Period. For qualified beneficiaries already enrolled in COBRA coverage, the deadlines to make required monthly premium contributions are extended until 30 days after the end of the Outbreak Period.
Coverage cannot be terminated and claims cannot be rejected for nonpayment of initial or monthly COBRA premiums during this period. Coverage termination will only occur if the individual fails to make all the required monthly premium contributions due by the end of the Outbreak Period.
The Extension of the Deadline for Qualifying Event and Disability Notices
The 60-day deadline by which qualified beneficiaries must notify the plan of certain qualifying events (e.g., divorce or legal separation, a dependent child ceasing to be a dependent under the terms of the plan) or disability determination has been temporarily extended.
The extended notice deadline applies as follows:
- If the 60-day notice deadline following a qualifying event expired prior to March 1, 2020, the extension does not apply.
- If a qualifying event occurs on or after March 1, 2020, and before the end of the Outbreak Period, the deadline for submitting the necessary qualifying event notice is extended to the date that is 60 days after the end of the Outbreak Period.
- If the qualifying event occurred prior to March 1, 2020, the deadline for submitting the necessary qualifying event notice is extended beyond the end of the Outbreak Period by the following number of days: 60 days minus the number of days that elapsed between the qualifying event and March 1, 2020.
Every effort has been made to ensure that the information contained within this website is accurate. However, benefits are governed by legal documents (which, in certain circumstances, may include insurance contracts). If there is any difference between the information in this website and the official documents, the official documents will control. As is the case with all of Syracuse University’s employee benefit plans, the University reserves the right to modify or terminate these benefits at any time.