DOL and IRS issue final rules extending various benefit plan deadlines


On May 4, 2020, the Department of Labor (DOL) and IRS issued final rules regarding the extension of various benefit plan deadlines and run-out periods. Certain deadlines affecting your flexible spending account (FSA) and/or health reimbursement account (HRA) benefit plans have been extended.

What we know to date:

  • Any run-out periods to make claims for 2019 plan year using FSA and/or HRA funds that would have expired March 1, 2020 or later have been extended. The final date to submit claims for 2019 expenses is still being determined and will be shared at a later time.
  • If your plan includes a grace period, there is no impact as a result of this ruling.

We recognize that the guidance may raise questions. We are working diligently to comply with this new ruling and understand the impact to your plan, and will update you accordingly. For more information, please reference the final rule published by the DOL.  

The DOL also posted a set of frequently asked questions to help employee benefit plan participants and beneficiaries, plan sponsors, and employers impacted by the coronavirus outbreak understand their rights and responsibilities. Employers should review their current summary plan descriptions (SPD) and benefit plan documents to determine how these timeframe extensions could impact the terms of the plan as it is currently written and seek the advice of legal counsel if amendments are needed.