New FSA-eligible items available under the recently passed CARES Act

March 30, 2020

On March 27, the President signed into law The Coronavirus Aid, Relief and Economic Security (CARES) Act. The bill contains two changes to eligible expenses for FSAs, HSAs and all IRS eligible HRAs.

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Two categories of eligible expenses for tax-free accounts have been added effective as of January 1, 2020:

1. A prescription is no longer required for over-the-counter medicines.

2. Menstrual products are now eligible expenses under FSAs, HSAs & HRAs.

The CARES Act removes the restriction on the use of FSA funds for the purchase of over-the-counter (OTC) drugs and medicines. Effective for expenses incurred on or after January 1, 2020, consumers may use FSA funds to pay for OTC drugs without the need for a prescription. The same provision also adds menstrual care products to the list of OTC items for which healthcare spending account consumers may use their funds tax-free.

Q. Can members swipe their Difference Cards for these new eligible expenses?

A. Yes, you will be able to, but not yet. Updates will need to be made to the inventory information approval system (IIAS) that allows pharmacy point-of-sale (POS) systems to discern whether transactions are FSA-eligible via the product SKU.

In the meantime, members can submit their receipts for purchases of the newly qualified items (going back to 1/1/2020) for reimbursement. Going forward, we encourage our members to submit their receipts by taking a picture and uploading them via the mobile app or portal for reimbursement. We will not automatically re-process any claims for these items that were previously denied.

To learn more about submitting a claim via the mobile app, visit our DC Mobile App page.

To submit a claim via the portal, login to your Difference Card account and click SUBMIT CLAIM.


You can view a copy of the bill in it’s entirety HERE.

We will continue to keep you updated as we learn more about the CARES Act and what it means for our members.

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