Recent COVID-19 Regulations: Information and Solutions To Help

Extension of Claims and Appeal Filing Deadlines For Certain Reimbursement Plans

This page was last updated May 8, 2020

Changes to claims and appeal filing deadlines have been made per guidance released by the Department of Labor on April 29, 2020.

The two areas impacted by this guidance are the extension of deadlines for claims filing and the extension of time to file claims for adverse benefit decisions. In response we are doing the following:

  • Identifying claims and appeals that were previously denied for late submission and automatically processing them.
  • Processing claims and appeals that we are currently receiving that have been submitted outside of the normal filing deadline.

Key terms and time periods to know:

COBRA Event Graphic about new deadlines

The guidance applies to these plan types that Benefit Strategies administers:

  • Healthcare Reimbursement Flexible Spending Account (Health FSA)
  • Limited Purpose and Post Deductible Flexible Spending Accounts (LP FSA and PD FSA)
  • Health Reimbursement Arrangements (HRAs) and similar plans that reimburse healthcare expenses (deductibles, copays, Section 213d expenses and similar), including HRAs that reimburse retiree medical premiums. This list also includes ICHRA, QSEHRA, and “split funding arrangements”.
  • Wellness Plans that reimburse Section 213d healthcare expenses or have funds contributed to a an HRA or FSA.
  • Retiree Medical Savings Accounts (RMSA)
  1. Deadlines have been extended for claims filing

As of March 1, 2020 and through the Outbreak period, there are no deadlines to file claims or appeals. This means that if your plan’s claim filing deadline falls on or after March 1, 2020, participants in the plan can still submit claims after the date of the plan’s claims filing deadline (also known as the last day of the runout period.)  They can continue to file claims through the 60 day period after the National Emergency ends. Per the current DOL guidance, after that 60 day period ends, claims filing returns to your plan’s normal filing deadline.

Please note that there is no change to the period of time in which expenses are incurred, only an extension of the claims filing period.

Benefit Strategies will process all claims submitted after the runout period ends as if they had been submitted timely under the normal claim filing deadline, and we will pay on any approved claims if funds were available at the time the runout period ended. We will then invoice you for the claims paid through our normal process.


Plan Year is January 1, 2019 – December 31, 2019 (“2019 Plan Year”). Runout period is 90 days, ending on March 30, 2020.

Claim submitted to Benefit Strategies on May 15, 2020 for the 2019 Plan Year. Claim meets all criteria for an eligible expense and documentation is provided:

If claim was incurred during the plan year (and the Grace Period if applicable), we will process the claim.

If there were no fund available as of March 30, 2020, we will deny the claim.

If there were funds available as of March 30, 2020, we will pay on the claim (either in total or in part depending on the amount of the claim and the amount of the available funds.) We will invoice you through our normal invoicing process for the claim. Your invoice will reflect the claim was paid from 2019 Plan Year funds.

Important to note: This may mean that you are invoiced for claims that we process after the plan year closeout has been completed. Plan year closeouts are completed within 90 days of the end of the runout period. We don’t expect a high volume of these claims, but we want you to be aware this could occur.

We have already begun processing claims submitted after the claims filing deadline in order to comply with the guidance. We are also reviewing all applicable claims submitted to us through any claims filing method that were previously denied for late submission. Once identified, we will re-process these claims automatically as if they had been submitted timely.

If you offer a Health FSA or Limited Purpose FSA With the $500 Carryover Provision: If the participant had funds roll to the new plan year, but those funds are needed to pay on a claim, we will “roll back” the needed funds to the prior plan year in order to process the claim. (This is contingent upon the participant having carryover funds still available in the new plan year.)

If you offer an HRA with a carrier claims feed: We are reviewing claims denied that came on the feed after the runout period ended, and will re-process those claims.

Claims Filing Methods For These Claims: Because the plan year’s final filing date in our system will have passed, online and mobile claims filing will not be available. Participants will need to complete a claim form and submit it via fax/secure email/mail. Claim forms can be downloaded from the Resources area of our website.

     2. Extension of time to file appeals for adverse benefit determinations

As of March 1, 2020 and through the 60 day period following the end of the National Emergency, there are no longer deadlines to file appeals.

There is no requirement to notify employees of these extensions.

We are continuously monitoring any changes to regulations and will notify you immediately of any updates.


The EBSA Disaster Relief Notice 2020-01


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967 Elm Street
Manchester, NH 03101
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