The recently passed Consolidated Appropriations Act (CAA) allows Duke employees greater flexibility in using remaining 2020 balances and making changes to 2021 elections for Duke’s healthcare reimbursement account and dependent care reimbursement account. The CAA permits employers to temporarily adopt provisions that allow employees to carry over the full amount of their unused 2020 balances in both their health and dependent care reimbursement accounts for payment of 2021 expenses. Additional provisions of the Act give employees greater flexibility in making prospective, mid-year changes to both of these accounts.
Below are additional details regarding these changes.
- Unlimited Carryover for Reimbursement Accounts
- Prospective Changes in Election Without a Qualifying Life Event
- Special Carry Forward Rule for Dependent Care Reimbursement Accounts
- Spend-Down for Health Care Reimbursement Accounts After an Employee Ceases Participation
- Frequently Asked Questions
- All unused funds from 2020 reimbursement accounts (both health care and dependent care) will carry over to the following plan year.
- Even if you did not enroll in a 2021 health care or dependent care reimbursement account this year, you may still be able to use the funds remaining in your account from the prior year.
- For Health Care Reimbursement Accounts (HCRA) – Health care cards will contain up to $550 carryover balance until March 28, 2021. On March 29, 2021, unlimited carryover balances will be available on the health care cards to spend once the 2021 plan year balance has been depleted. Full unlimited carryover will be visible in your online account approximately two weeks after the claim it by date. The 2020 HCRA claims filing deadline (claim it by date) has been extended to no later than April 15, 2022 or 60 days from the end of the national emergency, whichever date is earlier.
- You will have until April 15, 2022, at the latest, or 60 days from the end of the national emergency , whichever date is earlier, to submit claims for services provided/expenses incurred in calendar year 2020. After that, any unused funds from your 2020 account will be visible in your 2021 account.
- For Dependent Care Reimbursement Accounts (DCRA) – Full unlimited carryover will occur approximately two weeks after the April 15, 2021 claim it by date – May 1, 2021.
- For the 2021 plan year, election changes to your health care and dependent care reimbursement account can be made without a qualifying life event (QLE). This means you are able to make a change in your election at any time for any reason. Please note, your election cannot be reduced to an amount less than your year-to-date contributions or reimbursements/claims paid. You will need to make your election change no later than September 15, 2021. Please also note, Duke reserves the right to collect any overpayments made in error. Additionally, refunds remain impermissible. How to make a prospective change in election.
- Employees who were enrolled in a 2020 DCRA prior to January 31, 2020 and who have unused funds and a dependent that aged out during the pandemic may submit claims related to that dependent now. This means if you had a qualifying dependent who turned (or will turn) 13 during the 2020 or 2021 plan years, you may be able to use any unused funds from those plan years for qualifying expenses for that child until they turn 14.
- The funds you have contributed to your 2021 health care reimbursement account will remain available for spending through December 31, 2021, even if you leave Duke during the plan year or lose your eligibility to participate in the plan.
- Please contact the HRIC at 919-684-5600 to determine the amount of funds you have upon termination/loss of eligibility. Your election amount will be calculated based on year-to-date (YTD) contributions minus YTD reimbursements.
What is the Consolidated Appropriations Act?
The CAA is federal legislation recently passed that provides COVID-19 related relief in a number of areas. One of these areas is for reimbursement accounts that permit employers to adopt temporary rules to address the use-it-or-lose-it rules ordinarily required under the Internal Revenue Code.
When will I be able to submit 2021 claims for reimbursement against my 2020 balances?
Health Equity, the claims administrator, will have their claims system updated to reflect the unlimited access to your remaining 2020 healthcare and dependent care reimbursement account balance on March 29, 2021.
What is my deadline to submit 2020 healthcare or dependent care reimbursement claims?
April 15, 2021.
Do I still have access to the usual $550 carry over limit from last year’s balance in my healthcare reimbursement account before March 29?
How might these changes help me?
We have heard from many faculty and staff who have higher than usual remaining balances in their 2020 reimbursement accounts because of the impact of COVID-19 on their ability to use the funds. Some employees needed to defer care or did not use daycare as expected.
These changes enable you to use your full remaining 2020 balance for 2021 expenses and provide you flexibility to prospectively adjust your 2021 elections if needed.
Do I have access to the funds I was unable to spend in my 2020 health care reimbursement account?
Yes, active staff will have access to their full remaining 2020 balance on March 29. Prior to that date, you have access to up to $550 of your remaining 2020 balance if you have exhausted your 2021 funds. You will keep access to this balance through April 15, 2022, for eligible expenses incurred any time during 2021.
Do I have access to the funds I was unable to spend in my 2020 dependent care reimbursement account?
Yes, active staff will have access to their full remaining balance in their 2020 dependent care reimbursement account on March 29, 2021, for expenses incurred anytime in 2021. You will keep access to this balance through April 15, 2022, for eligible expenses incurred any time during 2021.
My child turned age 13 in 2020, and I have a remaining balance in my 2020 dependent care account. I have eligible expenses for my child in 2020, but I was unable to have them reimbursed as my child aged out. Can I submit these for reimbursement?
Yes. You are able to file claims for dependent children up to age 14 if you were enrolled in the dependent care reimbursement account prior to January 31, 2020. You will need to submit your claim for reimbursement of 2020 expenses by April 15, 2021.
Do I have to wait until March 29 to submit claims less than $550 for reimbursement of 2021 expenses from my 2020 balance?
No. As before, you have access to up to $550 of your 2020 health care reimbursement carryover now.
I went part-time in 2021, and my participation in the reimbursement account ended. I still have a remaining balance. Can I submit a claim for an expense incurred after the date I went part-time?
Yes, if your participation in the plan ends in 2021, you can submit expenses incurred through December 31, 2021, for reimbursement. The maximum that can be reimbursed is the amount contributed less the amount previously reimbursed.
I would like to change (increase/decrease or start/stop) my healthcare reimbursement account or dependent care reimbursement account election for 2021. I haven’t had one of the usual qualifying events (ex. marriage, birth, divorce, change in status). Can I make a change?
Yes. You are able to make prospective changes only, and the dollar amount will be impacted by any amounts you have already received in reimbursement for 2021. Making a prospective change means that you cannot reduce the amount to be withheld during 2021 to an amount less than the amount you have already contributed. Also, you cannot reduce the amount to be greater than the amount you have already received in reimbursement for 2021 expenses. Duke reserves the right to require reimbursement of the overpayment. Lastly, the window to make a mid-year change ends on September 15, 2021.
To update your 2021 election amount, please follow these steps, then contact the HRIC at 919-684-5600.
Can I move dollars between my dependent care account and healthcare reimbursement account?
No, you cannot move funds between dependent care and healthcare reimbursement accounts. Unfortunately, this was not one of the temporary provisions in the CAA and this remains impermissible.