Understanding DCAP Reimbursements: Application Fees, Deposits, and Indirect Expenses

Understanding DCAP Reimbursements: Application Fees, Deposits, and Indirect Expenses

Navigating the intricacies of Dependent Care Assistance Programs (DCAP) can be challenging, especially when it comes to understanding what expenses qualify for reimbursement. One common question that arises is whether application fees, deposits, and similar expenses can be reimbursed. Here, we break down the IRS regulations and provide clarity on this topic.

What Are Indirect Expenses?

Indirect expenses are costs that are not directly for care but are necessary to obtain care. Examples include application fees and deposits paid to day-care centers or preschools. According to IRS regulations, these expenses may qualify for reimbursement under a DCAP if they meet specific criteria.

Criteria for Reimbursement

To be eligible for reimbursement, indirect expenses must:

  1. Be Required for Care: The employee must be required to pay these expenses to obtain related care.
  2. Meet DCAP Rules: The expenses must comply with DCAP rules and the plan document.
  3. Relate to Provided Care: The care to which these expenses relate must actually be provided.

Examples of Reimbursable and Non-Reimbursable Expenses

  • Reimbursable: If a DCAP participant pays a $100 application fee to secure a spot at a new day-care provider, this fee can be reimbursed once the care is provided.
  • Non-Reimbursable: If a participant pays a $100 deposit to a preschool but later decides not to enroll the child, the deposit is not reimbursable since the care was not provided.

Timing of Reimbursement

The IRS does not specify whether indirect expenses can be reimbursed in full once care commences or if they must be reimbursed proportionately over the duration of the care agreement. To err on the side of caution, it is advisable to prorate the reimbursement over the agreement’s duration. For instance, if the agreement is month-to-month, the entire fee might be reimbursed after the first month of care. For longer agreements, the fee should be prorated accordingly.

Conclusion

Understanding the nuances of DCAP reimbursements for indirect expenses like application fees and deposits is crucial for both employers and employees. By ensuring these expenses meet the necessary criteria and timing the reimbursements appropriately, you can navigate the DCAP rules effectively and make the most of your benefits.

Source: Thomson Reuters

Understanding DCAP Reimbursements: Application Fees, Deposits, and Indirect Expenses

Top 5 FSA and HSA Eligible Items for Stress-Free Back-to-School Shopping

As the back-to-school season approaches, parents and students are preparing for the new academic year. Beyond the usual school supplies, there are many health-related items eligible for purchase using your Flexible Spending Account (FSA) or Health Savings Account (HSA). These tax-advantaged accounts can help you save money on essential health products that support your child’s well-being throughout the school year.

1. First Aid Supplies

Accidents happen, especially on the playground or during sports activities. Stock up on first aid essentials like bandages, antiseptic wipes, and cold packs. These items are crucial for handling minor injuries promptly.

2.  Contact Solution

If your child uses contact lenses, ensuring they have the right contact solution is essential for maintaining eye health and comfort. Both prescription glasses and contact lenses are eligible expenses, so make sure they have a clear view of the blackboard and their textbooks.

3. Over-the-Counter Medicines

Having a stock of over-the-counter (OTC) medicines can be a lifesaver for managing common ailments like colds, allergies, and headaches.

4. Acne Treatment

Managing acne is crucial for your child’s confidence and skin health. Various acne treatments, including creams, gels, and cleansers, are eligible for purchase with your FSA or HSA.

5. Sunscreen

Protecting your child’s skin from harmful UV rays is important year-round. Ensure you have an adequate supply of sunscreen, particularly if your child spends a lot of time outdoors.

Leveraging your FSA or HSA for back-to-school shopping not only ensures your child is well-prepared but also helps you save on essential health-related products. By planning ahead and purchasing these eligible items, you can take advantage of the tax benefits these accounts offer.

For a complete list of eligible FSA and HSA back-to-school items click here.

For more information on all FSA and HSA eligible items, visit the FSA Store.

Can employees be reimbursed for their entire health FSA election early in the year?

Can employees be reimbursed for their entire health FSA election early in the year?

QUESTION: For 2023, an employee elected $2,400 of health FSA coverage under our calendar-year cafeteria plan, which is funded solely through employee salary reductions and does not provide for carryovers or include a grace period. The employee has already incurred medical expenses equal to this amount in 2023 and wants to be reimbursed for the expenses now, even though she has only made health FSA salary reductions of $400 to date. Do we have to reimburse all of these expenses right away, or can we limit reimbursements to the amount our employee has already contributed and ask her to resubmit the remaining expenses as additional contributions are made? 

ANSWER: Your employee must be reimbursed for all of her expenses now, assuming that the expenses are otherwise eligible for reimbursement (e.g., they are for medical care incurred during the current period of coverage, and appropriate substantiation has been provided). That’s because IRS requirements for health FSAs include a “uniform coverage” rule under which the maximum amount of reimbursement must be available at all times during the plan year (or other period of coverage), reduced only for any prior reimbursements for the same period. Reimbursement is deemed “available” under the uniform coverage rule if claims are paid at least monthly, or when an employee’s submitted claims reach a reasonable plan minimum (e.g., $50). Thus, reimbursements cannot be restricted to the amount of the employee’s contributions. 

The uniform coverage rule also prohibits accelerating an employee’s salary reductions based on health FSA claims submitted or paid. Note that the uniform coverage rule does not apply to DCAPs, so reimbursements under a DCAP can be limited to the amount that has been contributed, less expenses already reimbursed. 

Source: Thomson Reuters