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Consociate Health Names Seth Reynolds Regional Vice President of Sales

Latest addition to leadership team continues expansion of Results-driven, value-based healthcare model across the US

DECATUR, IL (July 24, 2023) – Third-Party Administrator (TPA) Consociate Health today announced Seth Reynolds as the new Regional Vice President for the Southeast Region of the United States. Reynolds, to be based in Tampa, Florida, is the latest in a series of top-level executive hires and promotions by Consociate as they aggressively expand their results-driven, value-based healthcare model providing access at the right place, the right time, the right quality and the right price.

Seth has been with Consociate since 2022 as a Business Development Strategist, and has had other industry experience at Pareto Health and Marsh McLennan Agency. He holds a Bachelor’s degree in Finance from the University of Georgia.

Seth will lead the sales team in building and expanding relationships with consultants and business clients throughout the Southeast.

“Consociate’s growth is focused on developing a team that thrives in our culture of innovation and progress. As we grow nationally, Seth’s expertise will advance our strategy of expanding partnerships across the industry,” said Consociate Chief Growth Officer Mike Castleberry.

Existing partnerships with more employers, consultants, captives and healthcare systems have allowed Consociate to perfect its value-based health plan model using data integration strategies and data driven decision support resources. That success, and the need for more patient-centered service from TPAs industry-wide, continues to drive Consociate’s growth.

For more than 40 years, Consociate Health has partnered with consultants and employers of all sizes to deliver employee benefit program administrative services. As a Third-Party Administrator (TPA), Consociate has built a reputation for exceptional accuracy, customer service and a focus on helping employers with innovative cost containment solutions.

Through data analytics, Consociate provides its clients with personalized analysis of their plans to ensure they have quality data and are using that data to make educated decisions.

Essential data analytics allow Consociate Health to integrate claims, eligibility, financial and other healthcare data into a consolidated system database; analyze member health and then identify cost drivers; monitor health plan utilization; and forecast employer healthcare costs – which allows them to develop a strategy to manage and control healthcare costs for employers and members.

Consociate Health names Mike Castleberry as Chief Growth Officer

Castleberry has proven track record of building strategic partnerships to drive results for clients.

Decatur, IL., – Consociate Health, a national Third-Party Administrator of employee benefit plans, announced today that Mike Castleberry has been named Chief Growth Officer (CGO). Castleberry will be responsible for leading the company’s corporate development efforts to grow revenue and expand market channels and market share.

Castleberry brings 30 years of industry experience in leadership, growth, strategy, and product development. His diverse corporate exposure at Prudential, Aetna, WellPoint Anthem, HealthSCOPE Benefits and most recently at Pareto Captive Services, will strengthen Consociate Health’s leadership team and its strategic partnerships with consultants across the nation.

“Over the last several years, Consociate has achieved pivotal growth and success, and the company enjoys excellent relationships with its clients, consultant partners and its employees,” says Castleberry. “I look forward to building on this success and working with the team as we execute new growth initiatives and corporate strategy.”

“Consociate has been fortunate to experience significant growth because of our focus on results for our clients and our culture that supports that mantra. They are an outstanding group of individuals, dedicated to our mission of improving the lives of our customers and those in the communities we serve. We are excited to welcome Mike to our team. He is highly respected across the industry and brings incredible expertise in growth strategy and best-in-class processes to manage this planned growth,” said Consociate Health President Darren Reynolds.

About Consociate Health

For more than 40 years, Consociate Health has partnered with consultants and employers of all sizes to deliver employee benefit program administrative services. As a Third-Party Administrator (TPA), Consociate has built a reputation for delivering results to its clients, leveraging innovation through cost containment, technology and direct-to-employer network development while providing empathic customer service with a focus on helping those we serve.

2023 Open Enrollment Checklist

To prepare for open enrollment, group health plan sponsors should be aware of the legal changes affecting the design and administration of their plans for plan years beginning on or after Jan. 1, 2023. Employers should review their plan documents to confirm that they include these required changes.

In addition, any changes to a health plan’s benefits for the 2023 plan year should be communicated to plan participants through an updated summary plan description (SPD) or a summary of material modifications (SMM).

Health plan sponsors should also confirm that their open enrollment materials contain certain required participant notices, when applicable—for example, the summary of benefits and coverage (SBC). Some participant notices must also be provided annually or upon initial enrollment. To minimize costs and streamline administration, employers should consider including these notices in their open enrollment materials.

Plan Design Issues

Confirm that your plan’s out-of-pocket maximum complies with the ACA’s limits for 2023.
For HDHPs, confirm that the plan’s deductible and out-of-pocket maximum comply with the 2023 limits.
Communicate any plan design changes to employees as part of the open enrollment process.

Notices to Include

Annual CHIP notice
Medicare Part D creditable coverage notice
Notice of grandfathered status (if applicable)
Annual notice regarding coverage requirements for mastectomy-related benefits (WHCRA notice)

Links and Resources

Revenue Procedure 2022-24, which includes the inflation-adjusted limits for HSAs and HDHPs for 2023.
Model notices for group health plans, including the Women’s Health and Cancer Rights Act (WHCRA) Notice.
Model COBRA notices for group health plans.

Plan Design Changes

ACA Affordability Standard

Under the Affordable Care Act’s (ACA) employer shared responsibility rules, applicable large employers (ALEs) are required to offer affordable, minimum value health coverage to their full-time employees (and dependent children) or risk paying a penalty. The employer shared responsibility requirements are also known as the “employer mandate” or “pay or play” rules.

Under the ACA, an ALE’s health coverage is considered affordable if the employee’s required contribution to the plan does not exceed 9.5% of the employee’s household income for the taxable year (as adjusted each year). The adjusted percentage is 9.61% for 2022.

On Aug. 1, 2022, the IRS announced that the affordability percentage for plan years that begin on or after Jan. 1, 2023, will decrease to 9.12%. This is the most substantial decrease since these rules were implemented, and is the lowest that this percentage has ever been set, at 0.38% below the statutory affordability percentage of 9.5%. As a result, many employers may have to significantly lower their employee contributions for 2023 to meet the adjusted percentage.

If you are an ALE, confirm that at least one of the health plans offered to full-time employees (and their dependent children) in 2023 satisfies the ACA’s affordability standard.

Out-of-Pocket Maximum

Non-grandfathered health plans are subject to limits on cost sharing for essential health benefits (EHB). The annual limit on total enrollee cost sharing for EHB for plan years beginning on or after Jan. 1, 2023, is $9,100 for self-only coverage and $18,200 for family coverage.

Review your plan’s out-of-pocket maximum to ensure that it complies with the ACA’s limits for the 2023 plan year ($9,100 for self-only coverage and $18,200 for family coverage).
If you have a high deductible health plan (HDHP) compatible with a health savings account (HSA), keep in mind that your plan’s out-of-pocket maximum must be lower than the ACA’s limit. For 2023 plan years, the out-of-pocket maximum limit for HDHPs is $7,500 for self-only coverage and $15,000 for family coverage.
If your plan uses multiple service providers to administer benefits, confirm that the plan coordinates all claims for EHB across the plan’s service providers or divides the out-of-pocket maximum across the categories of benefits, with a combined limit that does not exceed the maximum for 2023.

Preventive Care Benefits

The ACA requires non-grandfathered health plans to cover certain preventive health services without imposing cost-sharing requirements (that is, deductibles, copayments or coinsurance) for the services. Health plans are required to adjust their first-dollar coverage of preventive care services based on the latest preventive care recommendations. If you have a non-grandfathered plan, you should confirm that your plan covers the latest recommended preventive care services without imposing any cost sharing.

More information on the recommended preventive care services is available through the U.S. Preventive Services Task Force and www.HealthCare.gov.

Health FSA Contributions

The ACA imposes a dollar limit on employees’ salary reduction contributions to a health flexible spending account (FSA) offered under a cafeteria plan. An employer may set its own dollar limit on employees’ salary reduction contributions to a health FSA, as long as the employer’s limit does not exceed the ACA’s maximum limit in effect for the plan year.

The ACA set the health FSA contribution limit at $2,500. For years after 2013, the dollar limit is indexed for cost-of-living adjustments. For 2022 plan years, the health FSA limit is $2,850. For 2023 plan years, the health FSA limit increases to $3,050.

Confirm that your health FSA will not allow employees to make pre-tax contributions in excess of $3,050 for the plan year starting in 2023.
Communicate the health FSA limit to employees as part of the open enrollment process.

HDHP and HSA Limits for 2023

If you offer an HDHP to your employees that is compatible with an HSA, you should confirm that the HDHP’s minimum deductible and out-of-pocket maximum comply with the 2023 limits. The IRS limits for HSA contributions, HDHP minimum deductible and HDHP maximum out-of-pocket expenses increase for 2023. The HSA contribution limits will increase effective Jan. 1, 2023, while the HDHP out-of-pocket limit will increase effective for plan years beginning on or after Jan. 1, 2023.

Check whether your HDHP’s cost-sharing limits need to be adjusted for the 2023 limits.
If you communicate the HSA contribution limits to employees as part of the enrollment process, these enrollment materials should be updated to reflect the increased limits that apply for 2023.

The following table contains the HDHP and HSA limits for 2023 as compared to 2022. It also includes the catch-up contribution limit that applies to HSA-eligible individuals age 55 or older, which is not adjusted for inflation and stays the same from year to year.

Type of Limit		2022	2023	Change
HSA Contribution Limit	Self-only	$3,650	$3,850	Up $200
HSA Contribution Limit	Family	$7,300	$7,750	Up $450
Type of Limit HSA Contribution Limit*	Age 55 or older	$1,000	$1,000	No change
HDHP Minimum Deductible	Self-only	$1,400	$1,500	Up $100
HDHP Minimum Deductible	Family	$2,800	$3,000	Up $200
HDHP Maximum Out-of-pocket Expense Limit**	Self-only	$7,050	$7,500	Up $450
HDHP Maximum Out-of-pocket Expense Limit**	Family	$14,100	$15,000	Up $900

* not subject to adjustment for inflation

** deductibles, copayments and other amounts, but not premiums

ACA Disclosure Requirements

Summary of Benefits and Coverage

The ACA requires health plans and health insurance issuers to provide an SBC to applicants and enrollees to help them understand their coverage and make coverage decisions. Plans and issuers must provide the SBC to participants and beneficiaries who enroll or reenroll during an open enrollment period. The SBC must also be provided to participants and beneficiaries who enroll other than through an open enrollment period (including those newly eligible for coverage and special enrollees).

On Nov. 8, 2019, the Departments of Labor (DOL) and Health and Human Services (HHS) issued an updated template and related materials for the SBC. These materials are required to be used for plan years beginning on or after Jan. 1, 2021. Thus, the updated template must be used for the 2023 plan year’s open enrollment period.

In connection with a plan’s 2023 open enrollment period, use the updated SBC template and related materials. The SBC should be included with the plan’s application materials. If coverage automatically renews for current participants, the SBC must generally be provided no later than 30 days before the beginning of the new plan year.
For self-funded plans, the plan administrator is responsible for providing the SBC. For insured plans, both the plan and the issuer are obligated to provide the SBC; this obligation is satisfied for both parties if either one provides the SBC. Thus, if you have an insured plan, you should confirm that your health insurance issuer will assume responsibility for providing the SBCs.

Grandfathered Plan Notice

If you have a grandfathered plan, make sure to include information about the plan’s grandfathered status in plan materials describing the coverage under the plan, such as SPDs and open enrollment materials. Model language is available from the DOL.

Notice of Patient Protections

Under the ACA, group health plans and issuers that require designation of a participating primary care provider must permit each participant, beneficiary and enrollee to designate any available participating primary care provider (including a pediatrician for children). Additionally, plans and issuers that provide obstetrical/gynecological care and require a designation of a participating primary care provider may not require preauthorization or referral for obstetrical/gynecological care.

If a health plan requires participants to designate a participating primary care provider, the plan or issuer must provide a notice of these patient protections whenever the SPD or similar description of benefits is provided to a participant. If your plan is subject to this notice requirement, you should confirm that it is included in the plan’s open enrollment materials. Model language is available from the DOL.

Other Notices

Group health plan sponsors should consider including the following enrollment and annual notices with the plan’s open enrollment materials.

Initial COBRA Notice

The Consolidated Omnibus Budget Reconciliation Act (COBRA) applies to employers with 20 or more employees that sponsor group health plans. Group health plan administrators must provide an initial COBRA notice to new participants and certain dependents within 90 days after plan coverage begins. The initial COBRA notice may be incorporated into the plan’s SPD. A model initial COBRA notice is available from the DOL.

Notice of HIPAA Special Enrollment Rights

At or before the time of enrollment, a group health plan must provide each eligible employee with a notice of his or her special enrollment rights under HIPAA. This notice may be included in the plan’s SPD.

Summary Plan Description

Plan administrators must provide an SPD to new participants within 90 days after plan coverage begins. Any changes made to the plan should be reflected in an updated SPD booklet or described to participants through an SMM. Also, an updated SPD must be furnished every five years if changes are made to SPD information or if the plan is amended. Otherwise, a new SPD must be provided every 10 years.

HIPAA Privacy Notice

The HIPAA Privacy Rule requires covered entities (including group health plans and issuers) to provide a Notice of Privacy Practices (or Privacy Notice) to each individual who is the subject of protected health information (PHI). Health plans are required to send the Privacy Notice at certain times, including to new enrollees at the time of enrollment. Also, at least once every three years, health plans must either redistribute the Privacy Notice or notify participants that the Privacy Notice is available and explain how to obtain a copy.

Self-insured health plans are required to maintain and provide their own Privacy Notices. However, special rules apply for fully insured plans, where the health insurance issuer, not the plan itself, is primarily responsible for the Privacy Notice.

Special Rules for Fully Insured Plans: The plan sponsor of a fully insured health plan has limited responsibilities with respect to the Privacy Notice.

If the sponsor of a fully insured plan has access to PHI for plan administrative functions, it is required to maintain a Privacy Notice and to provide the notice upon request.
If the sponsor of a fully insured plan does not have access to PHI for plan administrative functions, it is not required to maintain or provide a Privacy Notice.

A plan sponsor’s access to enrollment information, summary health information and PHI that is released pursuant to a HIPAA authorization does not qualify as having access to PHI for plan administration purposes.

Model Privacy Notices are available through HHS.

Annual CHIPRA Notice

Group health plans covering residents in a state that provides a premium subsidy to low-income children and their families to help pay for employer-sponsored coverage must send an annual notice about the available assistance to all employees residing in that state. The DOL has provided a model notice.

WHCRA Notice

Plans and issuers must provide a notice of participants’ rights to mastectomy-related benefits under the Women’s Health and Cancer Rights Act (WHCRA) at the time of enrollment and on an annual basis. Model language for this disclosure is available on the DOL’s website.

Medicare Part D Notices

Group health plan sponsors must provide a notice of creditable or non-creditable prescription drug coverage to Medicare Part D-eligible individuals covered by, or who apply for, prescription drug coverage under the health plan. This creditable coverage notice alerts the individuals about whether or not their prescription drug coverage is at least as good as the Medicare Part D coverage. The notice generally must be provided at various times, including when an individual enrolls in the plan and each year before Oct. 15 (when the Medicare annual open enrollment period begins). Model notices are available on the Centers for Medicare and Medicaid Services’ website.

Summary Annual Report

Plan administrators required to file a Form 5500 must provide participants with a narrative summary of the information in the Form 5500 called a summary annual report (SAR). A model notice is available from the DOL.

Group health plans that are unfunded (that is, benefits are payable from the employer’s general assets and not through an insurance policy or trust) are not subject to the SAR requirement. The plan administrator generally must provide the SAR within nine months of the close of the plan year. If an extension of time to file the Form 5500 is obtained, the plan administrator must furnish the SAR within two months after the close of the extension period.

Michelle’s Law Notice

Group health plans that condition dependent eligibility on a child’s full-time student status must provide a notice of the requirements of Michelle’s Law in any materials describing a requirement for certifying student status for plan coverage. Under Michelle’s Law, a plan cannot terminate a child’s coverage for loss of full-time student status if the change in status is due to a medically necessary leave of absence. Due to the ACA’s age 26 mandate for dependent coverage, most health plans no longer condition dependent eligibility on full-time student status and, thus, are not subject to Michelle’s Law.

HIPAA Opt-out for Self-funded, Nonfederal Governmental Plans

Sponsors of self-funded, nonfederal governmental plans may opt out of certain federal mandates, such as the mental health parity requirements and the WHCRA coverage requirements. Under an opt-out election, the plan must provide a notice to enrollees regarding the election. The notice must be provided annually and at the time of enrollment. Model language for this notice is available for sponsors to use.

Wellness Program Notices

Group health plans that include wellness programs may be required to provide certain notices regarding the program’s design. As a general rule, these notices should be provided when the wellness program is communicated to employees and before employees provide any health-related information or undergo medical examinations.

HIPAA Wellness Program Notice—HIPAA imposes a notice requirement on health-contingent wellness programs that are offered under group health plans. Health-contingent wellness plans require individuals to satisfy standards related to health factors (for example, not smoking) in order to obtain rewards. The notice must disclose the availability of a reasonable alternative standard to qualify for the reward (and, if applicable, the possibility of waiver of the otherwise applicable standard) in all plan materials describing the terms of a health-contingent wellness program. The DOL’s compliance assistance guide includes a model notice that can be used to satisfy this requirement.
Americans with Disabilities Act (ADA) Wellness Program Notice—Employers with 15 or more employees are subject to the ADA. Wellness programs that include health-related questions or medical exams must comply with the ADA’s requirements, including an employee notice requirement. Employers must give participating employees a notice that tells them what information will be collected as part of the wellness program, with whom it will be shared and for what purpose, as well as the limits on disclosure and the way information will be kept confidential. The Equal Employment Opportunity Commission (EEOC) has provided a sample notice to help employers comply with this ADA requirement.

AIMM

We partner with AIMM to create unique medical management strategies, based on our clients’ culture, population, goals, objectives, and budget. We understand that the most effective, most well received, medical management programs are “Patient Centric”, so through AIMM, we offer evaluation by professional nurses to identify how the quality of health care a patient is receiving can be improved, and/or decrease the cost of the care a patient is receiving.

Contact Consociate Health to learn more.

Healthcare as a Performing Asset

Pharmaceutical benefits can be a significant cost driver for business owners, accounting for 30-32% of overall healthcare costs.

Consociate Health now offers pharmacy benefit management to our clients by administrating employer drug benefit programs. Within this new division, we will evaluate pharmacy spend, process and pay prescription drug claims. We will advise on cost containment and incentivize prescribing physicians, pharmacists, and plan members to influence decision-making and save you money. Our expertise goes beyond traditional pharmacy benefit management services. Through our knowledge of underutilization and intensity, supply chains, codes and precertification, along with our process of gathering key data sets, we are able to provide solutions based on your unique situation and employees.

To learn more about our value-based benefits, contact Consociate Health today.

Why Self-Funding Paid Off During Shutdown

The ongoing COVID-19 pandemic has been a notable example of why self-funded health plans make sense for so many employers.

There are numerous advantages to moving from a fully-funded health plan to a self-funded plan – customized plans, control over vendors, fewer taxes, and access to data, to name a few. But one of the most significant benefits is that in a self-funded arrangement, an employer does not pay based an estimated number of claims, but rather pays only on actual claims filed.

Since the beginning of the pandemic and the resulting shutdown, medical claims have dropped across the country. There are a number of reasons for this, including a suspension of elective procedures in many states, hesitation to pursue treatment when hospitals have active COVID patients, and in general people staying home.

Employers with self-funded health plans have experienced considerable cost savings because they are paying only actual claims, which have dropped to substantially from what would be estimated in a ‘normal’ year.

Learn more about why self-funding might be the right arrangement for your business by speaking with your contact at Consociate Health today.

Celebrating Our 25th Anniversary

2020 marks our 25th anniversary! Founded in Decatur in 1995 by Danny R. Reynolds, Consociate Health is a Third Party Administrator (TPA) that administers employee benefit programs, including claims administration, for employers and members in 48 states. As industry innovators, we have been recognized in medical and Flexible Spending Accounts (FSA) administration, health management, wellness program initiatives, and Affordable Care Act (ACA) compliance and consulting.

Consociate Health has grown to 80 employees today with staff in two Illinois locations, along with Indiana, Michigan, Missouri, Tennessee, and Florida. Consociate Health currently serves approximately 75,000 covered lives for 235 employer groups (Medical and FSA). In 2019, nearly $500 million in medical claims were processed with a 99.77% financial dollar accuracy rate, well above the industry average.

Consociate Health has been working diligently to address the extraordinary escalation of healthcare costs by partnering with our clients to develop custom and comprehensive care management programs. Consociate Health works with clients on medical plan design and cost containment opportunities including Wellness Programs, Custom Precertification, Utilization Review, Chronic Disease Management, Cancer and Dialysis Claim Management, Predictive Modeling and Pharmacy Benefit Management. Consociate’s goal is to become a partner in managing an employer’s healthcare budget and improving the health and productivity of their employees. We look forward to the next 25 years!

Read our latest newsletter.

HSA/HDHP Limits Increase for 2021

On May 20, 2020, the IRS released Revenue Procedure 2020-32 to provide the inflation-adjusted limits for health savings accounts (HSAs) and high deductible health plans (HDHPs) for 2021. The IRS is required to publish these limits by June 1 of each year.

These limits include:
• The maximum HSA contribution limit;
• The minimum deductible amount for HDHPs; and
• The maximum out-of-pocket expense limit for HDHPs.
These limits vary based on whether an individual has self-only or family coverage under an HDHP.

Eligible individuals with self-only HDHP coverage will be able to contribute $3,600 to their HSAs for 2021, up from $3,550 for 2020. Eligible individuals with family HDHP coverage will be able to contribute $7,200 to their HSAs for 2021, up from $7,100 for 2020. Individuals who are age 55 or older are permitted to make an additional $1,000 “catch-up” contribution to their HSAs.

The minimum deductible amount for HDHPs remains the same for 2021 plan years ($1,400 for self-only coverage and $2,800 for family coverage). However, the HDHP maximum out-of-pocket expense limit increases to $7,000 for self-only coverage and $14,000 for family coverage.

Highlights

Each year, the IRS announces inflation-adjusted limits for HSAs and HDHPs.
By law, the IRS is required to announce these limits by June 1 of each year.
The adjusted contribution limits for HSAs take effect as of Jan. 1, 2021.
The adjusted HDHP cost-sharing limits take effect for the plan year beginning on or after Jan. 1, 2021.

Important Dates

January 1, 2021

The new contribution limits for HSAs become effective.

2021 Plan Years

The HDHP cost-sharing limits for 2021 apply for plan years beginning on or after Jan. 1, 2021.

Action Steps

Employers that sponsor HDHPs should review their plan’s cost-sharing limits (minimum deductibles and maximum out-of-pocket expense limit) when preparing for the plan year beginning in 2021. Also, employers that allow employees to make pre-tax HSA contributions should update their plan communications for the increased contribution limits.

HSA/HDHP Limits

The following chart shows the HSA and HDHP limits for 2021 as compared to 2020. It also includes the catch-up contribution limit that applies to HSA-eligible individuals who are age 55 or older, which is not adjusted for inflation and stays the same from year to year.

For more information, contact Consociate Health today.

The Families First Coronavirus Response Act (FFCRA)

The Families First Coronavirus Response Act (FFCRA) requires certain employers to provide employees with expanded family and medical leave for specified reasons related to COVID-19. The attached HR Compliance Bulletin includes guidance issued by the DOL regarding employee expanded family and medical leave rights under the law.

Also, attached is a HR Compliance Bulletin that contains questions and answers issued by the DOL to provide compliance assistance to employers and employees on their responsibilities and rights under the FFCRA.

Under the FFCRA, covered employers must post a notice of the FFCRA requirements in a visible place on its premises. The attached HR Compliance Bulletin includes FAQs issued by the DOL on this notice requirement. The required notice poster is, also, attached for your use.

If you have any questions, please contact us at customerservice@consociate.com.

The CARES Act and Health Plan Coverage

On March 27, 2020 President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law to provide $2.2 trillion in federal funding to address the coronavirus crisis. The new law also includes several provisions affecting health plan coverage. The attached Compliance Bulletin summarizes the CARES Act’s changes for health plans.

The attached Know Your Benefits article explains how the CARES Act repeals the Medicine Cabinet Tax provision of the Affordable Care Act, expanding the list of qualifying expenses that can be purchased with Flexible Spending Accounts (FSAs), Health Reimbursement Arrangements (HRAs) and Health Savings Accounts (HSAs).

FSA/HRA/HSA Plan Changes to allow Tax-Free Coverage for OTC Drugs and Menstrual Products

Effective Jan. 1, 2020, the CARES Act provides that OTC medicines are qualifying medical expenses that may be paid for (or reimbursed) on a tax-free basis by a health FSA, HRA or HSA. This change eliminates an ACA provision that required individuals to have a prescription for an OTC medication (except insulin) to pay for it on a tax-free basis with their health FSA, HRA or HSA.

In addition, effective Jan. 1, 2020, menstrual care products are qualifying medical expenses that can be paid for (or reimbursed) on a tax-free basis by a health FSA, HRA or HSA. Menstrual care products include tampons, pads, liners, cups, sponges or similar products used by individuals with respect to menstruation.

These changes are discretionary for employers that sponsor health FSAs and HRAs. However, because HSAs are individual accounts, and not employer plans, employers do not control how HSA funds are used.

What if Consociate Health Administers my FSA/HRA/HSA Benefits?

Consociate Health is ready to process any manual claims submitted (when a Debit Card is not used) for reimbursement on these products. We are also setup behind the scenes with our Debit Card Vendor to make sure your consumers can begin to utilize their benefits debit card for the purchase of these products as soon as possible.

Please Note: Your members can not yet purchase OTC or menstrual care items using their benefits debit card. Consociate Health is ready, but several steps must be taken by merchants before the members will be able to use their benefits debit card at the Mass merchandiser and Pharmacy locations.

The below steps will need to occur before the benefits debit card will be able to be used for the newly eligible items.

IIAS Standards (SIGIS) board must first adopt these new standards and publish the revised Eligible Product List.
Merchants (i.e. Walmart, Walgreens, CVS and smaller drug and grocery stores) must update their systems with the new Eligible Product List.

We expect merchants to start adopting changes for the OTC items around April 15^th. However, merchants may take anywhere from 4-6 weeks to complete the changes that will allow consumers to purchase these items with a card swipe. All of this will undoubtedly result in inconsistencies in shopping experiences for the consumer (i.e. OTCs may be allowable at one merchant, but not another) as the industry makes this important transition. We expect any issues like this to be temporary and resolved in a fairly short timeframe.

If consumers try to purchase these items with their benefits card before the systems have been updated and the transaction is denied, they can submit a claim for reimbursement.