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CARES Act - Eligible Product List Changes

by SIGIS | March 31, 2020

On Friday March 27th the Coronavirus Aid, Relief, and Economic Security Act or the CARES Act was signed into law.  The bill included a change impacting the use of funds from HSA, HRA and FSA health benefit accounts. The bill reverses the prescription requirement for Over the Counter Drugs for reimbursement and also includes eligibility for menstrual care products.  The bill had a retroactive start date of 1/1/20. While SIGIS cannot affect past transactions, we are making changes as quick as possible for future transactions.


SIGIS initiated this as a top priority early last week even before the signing of the bill.  Our teams and business partners are working to identify changes to the eligibility criteria and the Eligible Product List.  Under a normal monthly review cycle we process an average review of 1,700 items per month.  This month’s submission was on the high end including 3,395 items.  In addition, we are including 19,111 OTC Drugs and Medicines items in our database and doing a full review on 913 items in our Feminine Care categories which include Menstrual Care.  Our goal is to have all of this reviewed and published by our next Eligible Product List date scheduled on 4/15/20.


Upon merchants downloading the updated list with revised statuses, and processing those changes into their point of sale systems, consumers will be able to proceed through normal checkout lanes and use their healthcare benefit debit cards for the purchase of these products.  In addition to processing the list, merchants that have private label items will need to update their internal eligibility flagging of products based on the revised list criteria document.


While the 4/15 list publication will be a significant start, we expect large changes to be published in the following months as merchants and manufacturers submit items not currently in our database for eligibility review.  There will also be merchant responsibility to ensure their systems get updated with the item revisions.


SIGIS and our business partners have the highest priority on this change.  Our work locations are impacted by shelter in place orders, as are many of you.  We expect it will take some time for all the products to be identified and updated in every merchant’s system.  The current pandemic will create additional challenges in making that happen.  Consumer experience will be inconsistent across items and products in the near future but should improve quickly.  It will be important, that consumers, plan administrators, manufacturers, point of sale vendors and merchants work together and provide mutual understanding while this change gets rolled out.


Future communication will be provided as needed.