In light of the COVID-19 National Emergency relief rules issued by the Internal Revenue Service (IRS) and 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. This web page will be updated with new guidance as it becomes available, so please check back regularly. If you have any questions on how these extensions may apply to your specific situation, please contact HR Shared Services at email@example.com or 315.443.4042.
A number of extensions below reference an Outbreak Period. The Outbreak Period is the period from March 1, 2020 through 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, 2021, the Outbreak Period ends 60 days later on Nov. 29, 2021.
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 National Emergency, 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. However, guidance issued earlier this year clarifies that the deadline relief cannot last more than one year for any individual; therefore, the deadline relief ends on the earlier of (a) one year from the date the relief began for a particular individual or, (b) the end of the Outbreak Period (as defined above).
- The following example illustrates how the 31-day deadline would be disregarded or tolled for events that occur during the Outbreak Period:
- Participant Smith has a baby on July 31, 2020. Under the University’s medical plan enrollment rules, Smith would have had through Aug. 30, 2020 to enroll the new child. However, under the COVID-19 relief rules, the deadline for Smith to enroll the new child is Aug. 31, 2021 (31 days after the one-year period that began on Aug. 1, 2020 and ends July 31, 2021).
The following changes apply to the University’s Health Care and Dependent Care Flexible Spending Accounts ("FSAs").
If you wish to make a change to your FSA election, or have any questions, contact HR Shared Services at firstname.lastname@example.org or 315.443.4042.
In 2021, the maximum amount you can contribute is $2,750 to a Health Care FSA and $10,500 per household ($5,250 for individuals filing separately) to a Dependent Care FSA.
Health Care FSA Extended Claim Deadlines
The deadline to submit claims for expenses incurred during the plan year, which runs from Jan. 1 (or your enrollment date, if later) through Dec. 31, is normally Apr. 30 of the following plan year.
However, due to the COVID-19 National Emergency, certain regulations regarding plan administration deadlines have been suspended to give participants more time to file claims for benefits under a Health Care FSA. The Dependent Care FSA is still subject to the Apr. 30 claim filing deadline.
When you log into your HealthEquity/WageWorks account, you will see a “claim by” date which identifies when you need to submit your FSA claims for reimbursement. If you have questions about the deadline for submitting your FSA claims, please contact HealthEquity/WageWorks at 877.924.3967 (TTY: 866.353.8058).
For 2020 and 2021, if you end your participation in a Health Care FSA mid-year, reimbursements will be allowed for eligible health care expenses incurred through the end of the calendar year in which your participation ended, and reimbursements will be limited to only unused contributions. As a reminder, this is already allowed for Dependent Care FSAs.
Temporary Mid-Year Election Changes and Carryover Amounts
Expectations about your health care and dependent care expenses may have changed significantly due to COVID-19. As a result, you may want to change your FSA elections for 2020 or 2021.
Eligible faculty and staff are allowed to change their Health Care and Dependent Care FSA elections during 2020 and 2021 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.
All unused funds from both 2020 and 2021 will carry over and be available for use in the next year. This opportunity is provided under temporary COVID relief legislation that the University has adopted.
Temporary Increase in Dependent Care FSA Maximum Qualifying Child Age
The Dependent Care FSA reimburses the cost of eligible care for your qualifying child (typically age 12 and under) or other qualifying dependent, while you work or which enables you to work.
Due to recent COVID-19 relief legislation, the maximum qualifying child age for use of unused 2020 Dependent Care FSA funds increased from age 12 to 13. The extension only applies to 2020 Dependent Care FSA funds that are either used to pay 2020 claims for a dependent who turned age 13 in 2020, or carried over into 2021 for claims for dependents age 13 and under in 2021. The extension does not apply to new elections for the 2021 plan year. New 2021 Dependent Care FSA elections can only be used for claims for dependents age 12 and under.
Expanded List of Eligible Health Care FSA Reimbursable Expenses
The following health care expenses incurred as of Jan. 1, 2020, qualify for reimbursement from a Health Care FSA with proper documentation:
- 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 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
- Personal protective equipment such as face masks and hand sanitizer (containing at least 60% alcohol) purchased to prevent the spread of COVID-19.
Consult the HealthEquity/WageWorks searchable database of eligible health care expenses for more information and a complete list of eligible reimbursable expenses. This list will help you appropriately budget your Health Care FSA each year.
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. Keep in mind, however, that under the new guidance, the deadline relief ends on the earlier of (a) one year from the date the relief began for a particular individual or, (b) the end of the Outbreak Period (as defined above).
- The following example illustrates how the 180-day deadline would be disregarded or tolled for events that occur during the Outbreak Period:
- Participant Smith’s claim under the University’s medical plan was denied on June 30, 2020. The pre-pandemic deadline for Smith’s appeal would be 180 days from the denial date (Dec. 27, 2020). However, under the recent deadline relief rules, the 180-day deadline for the appeal does not begin to run until July 1, 2021 (assuming the Outbreak Period does not end before then); therefore, Smith has through Dec. 27, 2021, 180 days from the end of the one-year extended deadline line, to file an appeal.
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.
Under rules issued by the IRS and U.S. Department of Labor, the Outbreak Period (or one year, if earlier) is disregarded in determining whether the following COBRA deadlines have been met:
- The 60-day period to elect COBRA coverage.
- The deadline to make COBRA premium payments.
- 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 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 or, if earlier, one year after the loss of coverage as a result of a qualifying event.
The following example illustrates how the 60-day COBRA election deadline would be disregarded or tolled for events that occur during the Outbreak Period:
- Mr. Smith is no longer employed as of April 1, 2020. Under the pre-pandemic rules, Smith’s health plan coverage would have ended at midnight on March 31, 2020, if Smith did not timely elect COBRA coverage by May 31, 2020. Under the 1-year pandemic rule, Smith’s extension relief began on April 1, 2020; therefore, Smith had through March 31, 2021 to elect coverage retroactive to April 1, 2020.
Extension of the COBRA Premium Payment Deadline
If COBRA is elected, a qualified beneficiary has 45 days after the COBRA election is made 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, and who elect COBRA within the original 60-day COBRA election period, the deadline to make the initial COBRA premium payment is extended until the earlier of (i) the date that is 45 days after the last day of the Outbreak Period or (ii) the date that is one year and 45 days after the date the individual elected COBRA.
For qualified beneficiaries whose initial COBRA premium payment becomes due during the Outbreak Period, but who elected COBRA after the original 60-day COBRA election period, the deadline to make the initial COBRA premium payment is extended until the earlier of (i) the date that is 45 days after the last day of the Outbreak Period or (ii) the date that is one year and 105 days after the date the COBRA notice was provided.
Notwithstanding the above rules, in no event will a qualified beneficiary whose initial COBRA premium payment becomes due during the Outbreak Period be required to pay the initial payment prior to November 1, 2021, as long as the initial payment is made no later than 1 year and 45 days after the date the individual elected COBRA.
For qualified beneficiaries already enrolled in COBRA coverage, the deadlines to make required monthly premium contributions are extended until the earlier of (i) the date that is 30 days after the end of the Outbreak Period or (ii) the date that is one year and 30 days after the original payment due date.
Coverage cannot be terminated and claims cannot be rejected for nonpayment of initial or monthly COBRA premiums during the extension periods described above. Coverage termination will only occur if the individual fails to make all the required monthly premium contributions due by the applicable deadline described above.
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. Under the National Emergency relief, the 60-day notice period is paused until the end of the Outbreak Period (or, if earlier, one year after the date of the qualifying event). Once the notice period restarts, notice needs to be given within 60 days.
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.