Changes to Health Care and Dependent Day Care Flexible Spending Accounts Effective 4/15
Questions and Answers
Q1. Will my 2020 health care and/or dependent day care FSA balances automatically be rolled over to 2021 or do I need to do something to make this occur? Will my 2021 health care and/or dependent day care FSA balances, if any, automatically be rolled over to 2022?
A1. Your 2020 health care and/or dependent day care FSA balances will automatically be rolled over to 2021, and your 2021 health care and/or dependent day care FSA balances, if any, will automatically be rolled over to 2022. You do not need to do anything.
Q2: If I'm not enrolled in the healthcare and/or dependent day care FSA for 2021, will my 2020 FSA balance still roll over to 2021?
A2. Yes.
Q3. Will the FSA balance on my PayFlex debit card automatically be adjusted for the rollover of FSA funds from 2020 to 2021?
A3. Yes.
Q4. If I terminate employment during 2021, will my health care and/or dependent day care FSA balances, if any, be rolled over to 2022?
A4. No, and only eligible expenses up to your date of termination of employment are eligible for reimbursement from your 2021 health care and/or dependent day care FSA. Some exceptions regarding participants on COBRA may apply. For additional information refer to the Flexible Spending Accounts Plan Summary Plan Description at https://www.bnl.gov/hr/benefits/docs/reimbursement/fsa-spd.pdf.
Q5. What if I'm enrolled in the Aetna Plan 4 for medical coverage in 2021? That's the high deductible plan with the health savings account (HSA). Can I have an HSA and health care FSA at the same time? If not, can I change my medical plan election for 2021?
A5. You cannot have an HSA and health care FSA at the same time. If you were in the health care FSA in 2020 and you're enrolled in the Aetna Plan 4 with HSA in 2021, then any unused balance in your 2020 health care FSA will be forfeited. It will not be rolled over to 2021. Also, you cannot make a change to your 2021 medical plan election without a qualifying event. You do, however, have until March 31, 2021, to submit any eligible 2020 heath care expenses to PayFlex for reimbursement.
Q6. How do I determine my 2020 health care and/or dependent day care FSA balances?
A6. Go to www.payflex.com and login. Your User Name is your BNL Life Number and the zip code is your home zip code. You will be able to see your account balance, including your 2020 rollover amount, if any.
Q7. I understand that the health care FSA contribution limit for 2021 is $2,750 and the dependent day care contribution limit for 2021 is $5,000 (or $2,500 if you are married and file separate tax returns). When my 2020 health care and/or dependent day care FSA balance rolls over to 2021, my FSA balance will be above the Internal Revenue Service (IRS) maximum allowed annual contribution for 2021. Is that a problem?
A7. Based on the terms of the Consolidated Appropriations Act, 2021, this rollover of your 2020 unused balance(s) does not affect the 2021 IRS maximum(s) for contributions.
Q8. Will distributions from these FSAs be taxable if they exceed the 2021 IRS maximum(s) for contributions?
A8. Distributions from the health care FSA that exceed $2,750 in 2021 are not taxable. Normally distributions from the dependent day care FSA that exceed $5,000 (or $2,500 if you are married and file separate tax returns) are taxable, however, under the current special rule for 2021, distributions up to $10,500 are tax free. Such taxability is subject to change. Please contact your tax advisor for more information.
Q9. What types of changes can I make to my 2021 health care and/or dependent day care FSA contribution elections? Will I also be able to make these changes during 2022?
A9. You can increase, decrease, or drop your 2021 health care and/or dependent day care FSA contributions. You cannot do this during 2022 without a qualifying event.
Q10. Can I reduce my 2021 contribution to $0 if I've already received reimbursements from the FSA in 2021?
A10. No. You cannot reduce your 2021 health care and/or dependent day care FSA contribution elections to a point below the amount they have already been reimbursed by the FSA in 2021. Also not allowed is a reduction of your 2021 health care and/or dependent day care FSA contribution elections that would result in a refund of your unused 2021 contributions to the FSA.
Q11: If you have lost or discarded your PayFlex card, how do I obtain a new one?
A11. Contact PayFlex at 844-729-3539.
Q12. Can I make more than one change during 2021 to my 2021 health care and/or dependent day care FSA?
A12. Yes.
Q13. What's the difference between making a change in my 2021 FSA contribution based on the Consolidated Appropriations Act, 2021, and making a change due to a qualifying event?
A13. Changes in your 2021 FSA contributions based on the Consolidated Appropriations Act, 2021, are prospective changes. You do not need to provide supporting documentation of the reason for such change.
Changes due to a qualifying event must meet certain criteria and supporting documentation of the reason for such change must be provided. In some cases, a retroactive change may be feasible. Additional information is available at https://www.bnl.gov/hr/benefits/qualifying-events.php
Q14. Can I use my 2020 health care and/or dependent day care FSA contributions that are being rolled over to pay for 2021 for eligible 2021 expenses?
A14. Yes.
Q15. Can I use my 2021 health care and/or dependent day care FSA contributions to pay for eligible 2020 expenses?
A15. No.
Q16. Is there an order in which my FSA funds will be used to pay my eligible expenses?
A16. Yes. When you submit your expenses, FSA reimbursements will come from your 2020 contributions before your 2021 contributions.
Q17. What is the deadline for submitting FSA expenses?
A17. The deadline for submitting claims incurred in 2019 has been extended and is based on the end of the COVID-19 Outbreak Period, which is defined as the period from March 1, 2020 until 60 days after the announced end of the COVID-19 National Emergency. The end is unknown at this time.
