On March 27, 2020, the president signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law. Under the CARES Act, over-the-counter (OTC) drugs and feminine care products are newly eligible expenses for certain Health Reimbursement Arrangements (HRAs) and Health Care Flexible Spending Accounts (FSAs), and no longer require prescriptions for reimbursement, assuming an employer’s plan documents allow as such.
The CARES Act reverses Affordable Care Act (ACA) restrictions on tax-favored reimbursement for OTC drugs and products. Now, items like ibuprofen, acetaminophen, cold & flu medications, allergy medication, and sleep aids can be reimbursed through an HRA and FSA.
Feminine Care Products
Additionally, feminine care products are new on the list of items eligible for reimbursement through an HRA and FSA. According to text in the CARES Act, feminine products include “tampons, pads, liners, cups, sponges, or similar products used by individuals.”
These provisions are retroactive to January 1, 2020, so any of the newly qualified expenses incurred in 2020 may be eligible for reimbursement. It’s important to note that HRA plan documents must allow for reimbursement of all IRS Code Section 213(d) medical expenses for OTC and feminine care products to be reimbursable.
For a comprehensive list of health care items and services that are considered eligible under IRS Code Section 213(d) rules, we encourage you to visit the Special Interest Groups for IIAS* Standards website at https://sig-is.org/eligible-product-list2/eligible-product-list-criteria.
If you have any questions regarding the impact of the CARES Act on your MidAmerica benefits, we’re here to help:
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Contact Information by Plan Type
Health Reimbursement Arrangements/Flexible Spending Accounts
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Employers and Alliance Partners
Please reach out to your dedicated account representative, account manager or our Account Management team by emailing [email protected]
*What is IIAS?
Many major pharmacies are registered as Inventory Information Approval System (IIAS) certified. The pharmacy’s IIAS system allows them to differentiate between eligible and ineligible expenses, making it possible for eligible HRA and FSA products to be automatically approved at the point of purchase.