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What you need to know before buying Health Insurance  

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Spending Account Claims Require Substantiation Before They Can Be Reimbursed

Health care flexible spending accounts (HCFSAs) reimburse employees for qualified health care expenses that are not covered under a health insurance plan. Such expenses can include, for example, the copayments and deductibles required by your health plan, your coinsurance amounts, and any dental or vision care expenses not covered by insurance.

HCFSAs typically are funded entirely by employee contributions, made on a pretax basis, so they offer you a cost-effective way of paying for your out-of-pocket health care expenses. This tax advantage, however, is lost if the HCFSA reimburses expenses that are not qualified health care expenses. Thus, if an improper reimbursement is made, the amount will be considered taxable income to you, the employee. In extreme cases, the HCFSA plan itself could be disqualified.

To preserve the integrity of the HCFSA, employees who participate in these plans are required to substantiate any expenses for which they seek reimbursement. Internal Revenue Service rules detail these substantiation requirements. In general, substantiation means that the employee seeking reimbursement must provide a written statement from an independent third party stating that the medical expense has been incurred along with the amount of the expense. Also, the employee must provide a written statement that the expense has not been reimbursed or is not reimbursable under any other health care coverage.

However, if the statement from the independent third party indicates the date of the service and the employee's responsibility for payment for that service, the claim for reimbursement from the HCFSA is considered fully substantiated under IRS Notice 2006-69. An example of this situation would be when the substantiation provided is an explanation of benefits (EOB) from a health insurance company. An EOB would show that a medical expense has been incurred, the date of the expense, the amount of the expense, and the employee's responsibility for payment of the expense. If you submit an EOB when claiming a reimbursement, the IRS does not require that you also submit a receipt or statement from a physician.

The IRS does not consider employee self-substantiation or self-certification of health care expenses to be adequate. So, if instead of an EOB an employee submits a description of the health care expenses being claimed, along with the amount and date of the expenses, information from an independent third party also must be submitted (such as a receipt or invoice from the doctor).

Many HCFSAs now provide participating employees with debit cards that they can use to make certain health care expense payments at the time of service, rather than paying for these services out-of-pocket and later submitting a claim for reimbursement. The IRS has established approved methods for how debit card transactions can meet the basic substantiation requirements without the need for the employee using the card to submit further paperwork on the claim. If your employer has issued debit cards to be used in conjunction with your HCFSA, pay careful attention to the rules for using your card, as there may be situations where you will be required to fax or mail a receipt from the health care provider after you have used your debit card.

HCFSAs provide an easy way to save money on your health care expenses. By following the rules your employer has established for these plans, you will be able to enjoy their full, tax-advantaged benefits.

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