Plan Design Change-Consolidated Appropriations Act, 2021



Plan Design Change-Consolidated Appropriations Act, 2021InstructionsThis form contains two service options. Clients will need to choose one or the other, not both. For example, if you complete Option One, you do not need to complete any of the questions under Option Two and vice versa: Option One: Igoe’s Recommended Relief PackageOption Two: Pick and Choose Relief OptionsSend the completed form to compliance@ Basic Client Information Company Name (Client):Click or tap here to enter text. OverviewThe Consolidated Appropriations Act, 2021 allows clients to electively adopt any combination of the following changes:Allow Unlimited Carryover of funds (or a specified dollar limit) from plan years with a 2020 and/or 2021 plan year end date for the following account types:Health FSANew!! Dependent Care Assistance Plans (DCA)Extend a Grace Period for a standard 12-month plan with a plan year end date in 2020 and/or 2021 up to a 12-month period following the plan year end date for the following account types:Health FSADCAExtend or adopt relaxed change in status rules for the plan year ending in 2021. Such changes are prospective.Allow employees who terminated in the calendar year of 2020 or 2021 to Spend Down balances in their Health FSA.Allow reimbursement of daycare expenses for children up to the age of 14 if the dependent aged out (turned 14 during the previous plan year) provided that enrollment in the DCA took place on or prior to January 31, 2020.There is no current guidance that allows relief for plan years ending in 2022.Please note that Igoe will automatically update claim management to allow qualified account holders to claim dependent care reimbursement for children up to the age of 14. No action is needed on your part.To make these changes, a Plan Amendment is required but does not need to be completed until December 31, 2021 at the earlier. As a result, employers have time to consider what changes they wish to apply to their plan even when those changes are retroactive to plan years ending in 2020. Employers may wish to review their final run out activity reporting before making any retroactive plan design changes and are advised to seek benefit counsel opinion.To ease the review and adoption process, Igoe has put together a plan design option for your review within this Statement of Work (SOW). Igoe is offering a researched position but is not benefit counsel and must disclose the importance of working with benefit counsel prior to relief adoption.Option One: Igoe’s Recommended Relief PackageOnly complete this section if you want Igoe’s Recommended Relief Package in full. To qualify for this discounted package, you must choose Carryover relief.Fee: $100 Services include Plan Amendments, Summary Plan Descriptions, System Updates, and participant communication options. This fee is billed one time.What is the Plan Design for Igoe’s Recommended Package?Carryover for the Health FSA (Full and Limited, if applicable) both during relief and ongoing. If Carryover limits return to the indexed value for plan years ending in 2022, Igoe will automatically recalibrate the plan.Carryover will be designed to be HSA compatible, meaning Carryover funds can be voluntarily waived by the accountholder or moved into a Limited Purpose FSA (LPFSA) if one is offered. If adding an LPFSA at this time, the LPFSA will be designed to be convertible, meaning that it will convert to a full purpose FSA if the accountholder reaches their HDHP deductible. Carryover for DCA plans during the selected relief period. As Carryover is not available for plan years ending in 2022, Igoe will replace the Carryover with the 2.5-month Grace Period unless otherwise directed. Option to elect the Spend Down for terminated health FSAs (additional fees will apply at the account level)Option to add DCA Spend DownOption to add/extend mid-year election changes for spending accounts for plan years ending in 2021 If you do not want Igoe’s Recommended Relief Package as outlined above, please proceed to page 5 (Option Two: Pick and Choose Relief Options)Option One: Igoe’s Recommended Relief PackageAdd Carryover to my Health FSA/s (full and limited, if offered) for the plan year whose end date falls in the calendar year/s noted below:? 2020? 2021Apply the following Carryover Maximum:? Unlimited? Click here to enter custom amount.Enforce a Carryover Minimum:? Yes Click here to enter minimum balance amount.? NoClient agrees to automatically recalibrate the Carryover amount to the maximum allowed each applicable plan year starting in the plan year ending in 2022. Starting with plan years ending in 2023, a $50 annual charge applies if future adjustments are made as a result of newly indexed amounts. Client agrees to allow Carryover funds to be voluntarily waived or moved into a Limited Purpose FSA (LPFSA) if an employee wishes to accept and/or begin making HSA contributions in the future. Client understands that it is the Client’s responsibility to inform Igoe as part of open enrollment, or upon a change in election, if any accountholder chooses to waive Carryover or move funds into an LPFSA. If Client does not have an LPFSA and wishes to add one, check here. The LPFSA will be designed to be convertible (meaning the LPFSA converts into a standard FSA once the HDHP deductible has been met): ? Client agrees to add Carryover to its DCA plan using the same requirements selected in #1 above.:? Yes? NoPlease also select how you would like the DCA be to handled for plan years ending in 2022? Revert/Add to the 2.5-month Grace Period if Carryover is not available before our 2022 plan year end date.? Revert to a traditional 12-month plan design.Optional: Client would like to offer spend down for terminated FSAs. ? Yes. Client must complete the terminated FSA Spend Down options listed on page 9.? NoOptional: Add Spend Down to my DCA for the plan year currently in operation and ongoing. If you are not sure if you have this provision already but want to make sure you add it, select yes below. If you select No but already have this provision, Igoe will not amend the provision out of your plan design:? Yes? NoOptional: Allow Mid-Year Election Changes without requiring a qualifying event for the plan year ending in 2021 as listed below. NOTE: if you use a data feed to send eligibility to Igoe, please consult with your EDI vendor to ensure that they can support the selected election change rules: ? Health Plans. (NOTE: this could affect HSA eligibility. Consult with your broker and your carrier before electing this option).? Health FSA: revoke an election. Please designate how claims should be handled:? Allow accountholder to incur claims for the remainder of the plan year. (NOTE: this can cause HSA eligibility issues.)? Allow claims to be covered for services on or prior to the date of revocation by following the standard FSA termination rules associated with our plan? Health FSA: make a new election ? Allow accountholders to be covered for claims retroactively to the beginning of the plan year. ? Health FSA: increase/decrease an election NOTE: If an employee makes a new Health FSA election, they will not be able to contribute to an HSA (if applicable)? DCA: revoke an election ? DCA: make a new election ? DCA: increase/decrease an election Option Two: Pick and Choose Relief OptionsOnly complete this section if you do not want Igoe’s Recommended Relief Package. If you completed Option One, please proceed to the end of this SOW for signature.Fee: starts at $120Services include Plan Amendments, Summary Plan Descriptions, system updates, and customized participant communication options. This fee is billed one time. Additional fees may apply as listed herein.Add or Change Existing Carryover Provisions: Health FSA (Full and Limited)? Add or Change Carryover for my Health FSA/s (full and limited, if offered) for the plan year ending in the calendar year/s noted below:? 2020? 2021Apply the following Carryover Maximum:? Unlimited? Click here to enter custom amount.Enforce a Minimum Carryover Balance in order to qualify for Carryover:? Yes Click here to enter custom amount.? No? Automatically adjust the Carryover amount to the published maximum each year should the maximum revert to the annually indexed amount. ($50 annual fee applies if adjustments are made as a result of newly indexed amounts)Choose ONE:? Allow Carryover funds to be waived or moved into an LPFSA if an employee wishes to accept and/or begin making HSA contributions in the future. Client understands that it is the Client’s responsibility to inform Igoe as part of open enrollment, or upon a change in election, if any accountholder chooses to waive Carryover or move funds into an LPFSA. If Client does not have an LPFSA and wishes to add one, check here. The LPFSA will be designed to be convertible (meaning the LPFSA converts into a standard FSA once the HDHP deductible has been met): ? ? Require that all employees with an HSA have their account converted to a Limited Purpose FSA during the if Carryover funds are available. Client understands that it is the Client’s responsibility to inform Igoe as part of open enrollment, or upon a change in election, if any accountholder elects and HSA and needs funds moved into an LPFSA. If Client does not have an LPFSA and wishes to add one, check here. The LPFSA will be designed to be convertible (meaning the LPFSA converts into a standard FSA once the HDHP deductible has been met): ?? N/A. Client does not have and will not be offering an HDHP/HSA during the relief period.Add Carryover Provisions: DCA? Add Carryover to my DCA for plan years with an end date in the year/s selected below:Apply the following Carryover Maximum:? Unlimited? Click here to enter custom amount.Enforce a Minimum Carryover Balance in order to qualify for Carryover:? Yes Click here to enter custom amount.? NoAdd or Change an Existing Grace Period up to 12 months following the Plan Year endThe extension of a Grace Period up to 12 months following the end of the year is an elective option for Health FSA and DCA accounts. This extension is only available for plans whose traditional 12-month plan year (or short plan year) ended in 2020 or will end in 2021. Additional fees apply: $25 per month for the duration of the extended Grace Period NOTE: per participant fees and other Grace Period related surcharges as listed in your Fee Exhibit will be prospectively waived. Health FSA (Full and Limited, if applicable)? Yes, please extend the Grace Period for plans with a plan year end date in the calendar year/s listed below.? 2020? 2021Choose ONE:? Apply the full 12-month extension? Apply a custom extension. Please enter the custom duration here: Click or tap here to enter your desired Grace Period duration.Choose ONE:? Allow employees to waive the Grace Period or change their account to a Limited Purpose FSA? Require that all employees with an HSA have their account converted to a Limited Purpose FSA during the Grace Period? N/A. We do not have and will not be offering an HDHP/HSA during the relief period.DCA? Yes, please extend the Grace Period to 12 months following the end of the plan year for plans with a plan year end date in the calendar year/s listed below.? 2020? 2021Choose ONE:? Apply the full 12-month extension? Apply a custom extension. Please enter the custom duration here: Click or tap here to enter your desired Grace Period duration.Add or Extend Mid-Year Election Changes Without Requiring a Qualifying EventThese provisions are prospective for new adopters or will be extended if already adopted for plan years that have a plan year end date in 2021. NOTE: if you use a data feed to send eligibility to Igoe, please consult with your EDI vendor to ensure that they can support the selected election change rules:? Health Plans. (NOTE: this could affect HSA eligibility. Consult with your broker and your carrier before electing this option).? Health FSA: revoke an election. Please designate how claims should be handled:? Allow accountholder to incur claims for the remainder of the plan year. (NOTE: this can cause HSA eligibility issues.? Allow claims to be covered for services on or prior to the date of revocation by following the standard FSA termination rules associated with our plan? Health FSA: make a new election ? Allow accountholders to be covered for claims retroactively to the beginning of the plan year. ? Health FSA: increase/decrease an election NOTE: If an employee makes a new Health FSA election, they will not be able to contribute to an HSA (if applicable)? DCA: revoke an election ? DCA: make a new election ? DCA: increase/decrease an election Spend Down Provisions: Health FSAAdditional Fees Apply: $25 per account revision This fee is billed each time an account has to be manually re-opened to allow Spend Down claim submission once adopted or a result of receiving incorrect eligibility data once adopted. Accounts should only need to be re-opened one time to allow ongoing claim access. However, if you use a data feed, there is a potential that data feed eligibility will cause an account to close which would result in additional revision fees. Active participation fees will also apply.? Add Spend Down to my Health FSA/s for events that took place in the calendar year/s listed below. I understand that COBRA obligations are still required and that Client is responsible to notify accountholders of this spend down opportunity:? 2020? 2021Client understands that the accountholder to have access to spend down funds through the end of the plan year in which their loss of coverage occurredChoose ONE:? Allow the accountholder to have access only to funds contributed prior to their loss of coverage. ? Allow the accountholder to have access to their full benefit/election amount.Spend Down Provisions: DCA? Add Spend Down to my DCA for the plan year currently in operation and ongoing. If you are not sure if you have this provision already but want to make sure you add it, select yes below. If you select No but already have this provision, Igoe will not amend the provision out of your plan design:? Yes? NoSignatureI attest that I am authorized to make decisions and indebt Client. I further attest that the information in this document is truthful, accurate and can be used to begin system re-configuration and updates to any existing Plan Document. The executed SOW can be submitted to compliance@. Print Name: Type in Name.Signature:___________________________________________________Title: Enter Title.Date: Click or tap to enter a date. ................
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