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Regulatory Updates: FSA and HRA Extensions due to COVID-19

On April 28, 2020, the Departments of Labor and Treasury jointly announced regulatory changes due to the impact of the COVID-19 (Coronavirus) pandemic. These regulations are meant to provide relief for members and plan administrators and are effective retroactive to March 1, 2020.

Below is additional detail regarding these changes and LBS’s response.

What are the regulatory changes?
Reimbursement Account deadlines to file reimbursement claims for Flexible Spending Accounts and Health Reimbursement Accounts will be extended to 60 days after the COVID-19 National Emergency has been lifted. The changes apply to any plan that had a final filing date on or after 3/1/2020.

Who do the extensions apply to?
The extensions apply to members and plan administrators of Flexible Spending Accounts and Health Reimbursement Accounts.

Are the extensions retroactive and when do they end?
The extensions are retroactive to March 1, 2020 and ends 60 days after the COVID-19 National Emergency has been lifted. The federal government will decide when the National Emergency has ended.

How will LBS be handling the regulatory changes identified above?
LBS will extend the number of runout days to allow for the extension. At this time, our system will extend the runout until 8/31/2020 and will be adjusted as the expiration of the National Emergency is determined. This change will apply to the following plans:

  • Flexible Spending Accounts
  • Health Reimbursement Accounts
  • Limited Purpose Flexible Spending Accounts

LBS will extend the appeals period for claims with appeals deadlines as of 3/1/2020.

These changes include any active or terminated participant enrollment. For example, a participant who was enrolled in a plan from 12/1/2019 through 11/30/2020 but terminated as of 2/15/2020 where the plan offers a 90-day runout, LBS will extend the final filing date until 8/31/2020.

If your plan was recently terminated with LBS, the runout days will NOT be extended for that plan unless instructed otherwise. Please contact your administrator directly for more details on these plans.

If any claims were previously denied for timely filing, but now fall into the extended runout, the claims need to be refiled, or the member can contact our customer service team to request their claim be reprocessed.

We encourage you to share these important updates with your clients and/or employees.  

As we work through our amended processes, we will post additional information on our website at