Updates to FSA Grace Period and Mid-Year Change Requests

March 9, 2021

Dear Colleagues:

The Consolidated Appropriations Act, 2021 (CAA) (new window) allows employers to adopt temporary provisions for health care and dependent care Flexible Spending Account (FSA) plans in order to provide relief to employees during the COVID-19 pandemic. 

Effective March 15, Georgetown University will be implementing an extended grace period for Flexible Spending Account participants to incur and submit expenses for reimbursement. The extended grace period will apply to 2020 and 2021 FSAs. If you currently still have money in your 2020 Health Care or Dependent Care FSA, you now have until December 31, 2021 to use those dollars for eligible expenses (previously, all expenses would need to have been submitted by March 15, 2020). If you are participating in a 2021 FSA, you’ll have until December 31, 2022 to exhaust your balance.

The CAA also provides flexibility for employees to change their Health or Dependent Care FSA contribution amount during 2021 for any reason. This means that eligible faculty and staff may increase, decrease or stop their FSA contributions without experiencing a qualifying life event such as a birth, marriage or change in child care provider. These changes can be requested in GMS starting Monday, March 15.

It is important to note that only prospective changes to FSAs are allowed. Any pre-tax contributions applied to an FSA cannot be refunded. Also, any increased contributions to an FSA can only be used for reimbursement of expenses incurred on or after the date of the requested change. For example, if Joe Hoya requests to increase his Health FSA from $0 to $500 on March 15, he cannot use those dollars to reimburse himself for the eye glasses he purchased on March 1. 

One final change for those with unused balances in their 2020 Dependent Care FSA is that you may claim eligible expenses for dependents up to age 14 during the 2020 plan year or the extended grace period. 

COVID-19 FSA change requests can be submitted through GMS starting Monday, March 15. You’ll find step-by-step instructions on the HR website (new window). The deadline to submit applicable FSA contribution change requests is December 1, 2021. Although the change to your FSA election will take effect on the date it is requested, it’s important to note that the change may take up to three (3) weeks to be reflected in your ConnectYourCare account. 

Georgetown University will adopt the above provisions effective Monday, March 15. You can learn more about these provisions, view Frequently Asked Questions and instructions for requesting FSA changes on our website (new window).

Be well,

Charles DeSantis
Associate Vice President, Benefits, Payroll & Wellness
Chief Benefits Officer