MMC Benefits Handbook
Reimbursements
In general, the Plan will reimburse:
For examples of IRC Section 213 qualified medical expenses, see IRS Publication 502, which is available at www.irs.gov or by calling the IRS at +1 800 829 3676. Note that certain items listed in Publication 502 may not qualify for Limited Purpose Health Care Flexible Spending Account reimbursement, such as premiums for dental or vision insurance. In addition, Publication 502 does not specifically address all of the requirements of Limited Purpose Health Care Flexible Spending Accounts, including post-deductible qualified medical expenses (see "Examples of Eligible Expenses" and "Examples of Ineligible Expenses" for more information). You may also contact the Claims Administrator for information about reimbursable qualified medical expenses.
Who are the qualifying family members whose expenses may be reimbursed?
According to the IRS, a qualifying family member includes any person who qualifies for tax-free health plan benefits, including any of the following individuals:
  • your spouse
  • a person for whom you can claim an exemption on your federal taxes
  • a person who meets all of the following criteria:
    • is your child (by birth or adoption), stepchild or foster child; your sibling or, step-sibling; or the descendant of your child, stepchild, foster child or sibling
    • lives with you for more than half the year
    • doesn't provide more than half his or her own support for the year
    • has not reached or will not reach the age of 27 at the end of the Plan Year
    • is either a US citizen, national, or resident; a resident of Canada or Mexico; or a child being adopted by a US citizen or national who shares that individual's home as a member of the household
  • another person (e.g., relative, domestic partner, same-sex spouse) who meets all of the following criteria:
    • receives more than half of his or her support from you during the calendar year
    • can't be claimed as anyone's "qualifying child" dependent
    • is your relative or, if the person is not your relative, he or she must live with you for the entire calendar year as a member of your household (except for temporary reasons such as vacation, military service or education) and the relationship cannot be in violation of local law
    • is either a US citizen, national, or resident; a resident of Canada or Mexico; or a child being adopted by a US citizen or national who shares that individual's home as a member of the household
You can be reimbursed for eligible expenses for you, your spouse or your qualifying family members.
Unless your domestic partner or his or her children qualify for tax-free health plan benefits (as described above), the federal government does not permit you to use health care flexible spending accounts for eligible expenses incurred by your domestic partner or his or her children.
How do I get Limited Purpose Health Care Flexible Spending Account reimbursements?
There are several ways for you to be reimbursed for eligible Limited Purpose Health Care Flexible Spending Account expenses:
  • You can use the Prepaid MasterCard® at point of service to pay for eligible dental and vision expenses without needing to submit claims. When you use the Prepaid MasterCard® at a qualifying provider, the funds are automatically deducted from your Limited Purpose Health Care Flexible Spending Account for payment. Using the Prepaid MasterCard® reduces out-of-pocket payments and paperwork, as well as the need to wait for reimbursement checks.
    • If you participate in the Health Savings Account and the Plan and use the Prepaid MasterCard® to pay for eligible dental or vision expenses at a provider who is not a qualifying provider, the cost of the expense will be deducted from your Health Savings Account. If you prefer to use your Limited Purpose Health Care Flexible Spending Account to pay for eligible dental or vision expenses at a provider who is not a qualifying provider, you can pay out-of-pocket and submit a claim for reimbursement.
    • You cannot use the Prepaid MasterCard® to pay for eligible preventive medical care expenses or post-deductible qualified medical expenses. Instead, you must submit a claim for reimbursement.
  • You can submit a claim for reimbursement either online at the Spending Account Service Center, mobile app (Spending Account Mobile Center for your Android or iPhone (also compatible with iPad® and iPod touch®)), by fax at +1 888 788 1928 or by mail.
  • In order to be reimbursed for post-deductible qualified medical expenses, you must submit a claim form along with an Explanation of Benefits. You cannot use the Prepaid MasterCard® for these expenses.
Claims Submission by Mail:
Spending Account Service Center
FSA Claims Processing
2300 Renaissance Boulevard
King of Prussia, PA 19406
Note: Medical expenses (other than eligible preventive medical care expenses) incurred before you have satisfied the deductible applicable to you (that is, the individual or family deductible, depending on your level of coverage) under the Marsh & McLennan Companies $1,500 Deductible Plan or $2,850 Deductible Plan cannot be reimbursed from the Limited Purpose Health Care Flexible Spending Account, even if the expense is not covered by the Marsh & McLennan Companies $1,500 Deductible Plan or $2,850 Deductible Plan. If you are requesting reimbursement post-deductible qualified medical expenses, you will have to provide an Explanation of Benefits to confirm that your deductible has been met.
You should keep copies for your records.
What is the Prepaid MasterCard®?
The Prepaid MasterCard® is a special-purpose MasterCard® that gives you a way to pay for eligible dental and vision expenses without needing to submit claims. The Prepaid MasterCard® lets you electronically access the amount you elected to contribute to your Limited Purpose Health Care Flexible Spending Account at qualifying providers.
Trion will provide two (2) Prepaid MasterCards®, which will be loaded with your Limited Purpose Health Care Flexible Spending Account election. Additional or replacement cards are available for a $10.00 fee (come in packages of 2 cards) charged directly to your account. If you participate in more than one account, the fee would be charged first to your Limited Purpose Health Care Flexible Spending Account, then your Dependent Care Flexible Spending Account before being charged to your Health Savings Account
How does the Prepaid MasterCard® work?
The Prepaid MasterCard® works like a debit card, with your account balance stored on it. When you use the Prepaid MasterCard®, the amount of the eligible dental and vision expenses will be deducted automatically from your Limited Purpose Health Care Flexible Spending Account and will be electronically transferred to the provider/merchant. There are no monthly bills and no interest. The total amount you elected for the plan year is available for reimbursement at the start of the year, regardless of your contributions at the time of reimbursement.
Who issues the reimbursements?
Reimbursements are issued by the Claims Administrator. You can submit your eligible expenses for reimbursement at any time after you incur the expense, provided that you submit your claim for reimbursement before the claims submission deadline of March 31 of the following plan year.
Where can I get a Limited Purpose Health Care Flexible Spending Account Claim Form?
Forms can be found on Colleague Connect. You can download the Limited Purpose Health Care Flexible Spending Account Claim Form by going to Colleague Connect (https://colleagueconnect.mmc.com). Click Career & Rewards and select Find a Document.
Forms can also be found on the Claims Administrator's website or requested from the Claims Administrator by calling +1 866 324 4087.
How is the reimbursement paid from my account?
For eligible expenses that are not reimbursed by using the Prepaid MasterCard®, such as preventive medical care expenses and Post-Deductible Qualified Medical Expenses, you must submit a claim for reimbursement. The Claims Administrator will reimburse eligible expenses directly to you from your Limited Purpose Health Care Flexible Spending Account. The Claims Administrator will do one of the following:
  • deposit your reimbursement amount directly into your checking or savings account. To establish direct deposit of your reimbursement, you will need to provide your direct deposit information to the Claims Administrator by completing a Direct Deposit Authorization Form, accessible online through the Trion Spending Account Service Center.
  • send your check to your home address if you do not have direct deposit on file with the Claims Administrator.
Your first reimbursement may be paid by check while the Claims Administrator authenticates your bank information for direct deposit.
How long does it take for claims to be processed?
Reimbursements are processed within three to four business days of the Claims Administrator's receipt of the completed claim form and required documentation.
Do I need a minimum amount of expenses before I can be reimbursed?
No. There is no minimum amount of expenses when submitting a claim for reimbursement.
How much can I be reimbursed?
The total amount elected for the plan year is available for reimbursement at the start of the year, regardless of your contributions at the time of reimbursement. You can be reimbursed up to your account balance, which is the total amount you elected for the plan year minus the amount you have already been reimbursed.
What if the amount of my expense is more than I currently have in my account?
Eligible expenses are reimbursed from your account balance, which is the total amount you elected for the plan year minus the amount you have already been reimbursed.
Can I be reimbursed before I pay my provider?
Yes, but you must submit documentation confirming that services were rendered including dates of service, services rendered and your cost for these services (such as an itemized statement from your provider or an Explanation of Benefits from the insurer) before you can be reimbursed for eligible expenses.
Keep in mind that qualified medical expenses are only reimbursable if they are preventive or post-deductible qualified medical expenses.
Can I be reimbursed for expenses incurred before I meet my Marsh & McLennan Companies $1,500 Deductible Plan or $2,850 Deductible Plan deductible?
You can be reimbursed for eligible dental, vision and preventive medical care expenses incurred before you have satisfied the deductible applicable to you (that is, the individual or family deductible, depending on your level of coverage) under the Marsh & McLennan Companies $1,500 Deductible Plan or $2,850 Deductible Plan. Other qualified medical expenses can only be reimbursed if they are post-deductible qualified medical expenses. The Prepaid MasterCard® cannot be used for preventive medical care expenses or post-deductible qualified medical expenses. If you prefer to use your Limited Purpose Health Care Flexible Spending Account to pay for preventive medical care expenses and post-deductible qualified medical expenses, you can pay out-of-pocket and submit a claim for reimbursement.
Are there different deductibles depending on the level of medical coverage I elect?
Yes, your deductible is different depending on whether you elect Employee-Only, Employee + Spouse/Domestic Partner, Employee + Child(ren), or Employee + Family coverage under the Marsh & McLennan Companies $1,500 Deductible Plan or $2,850 Deductible Plan. The individual deductibles apply to Employee-Only coverage, and the family deductibles apply to all coverage levels except Employee-Only. Please see the applicable section of the Benefits Handbook for the $1,500 Deductible Plan or $2,850 Deductible Plan for more information about deductibles and how each plan determines whether you or a family member has satisfied the applicable deductible.
Do post-deductible qualified medical expenses have to be incurred after I meet my deductible or submitted after I meet my deductible?
Yes. Post-deductible qualified medical expenses must be incurred after you have satisfied the deductible applicable to you (that is, the individual or family deductible, depending on your level of coverage) under the Marsh & McLennan Companies $1,500 Deductible Plan or $2,850 Deductible Plan. For example, let's say you meet your Marsh & McLennan Companies $1,500 Deductible Plan or $2,850 Deductible Plan deductible on October 1. You went to the doctor on September 15 for a non-preventive care visit and, on October 15 you submit a claim to your Limited Purpose Health Care Flexible Spending Account for your expenses related to that office visit. That claim would not be reimbursable from your Limited Purpose Health Care Flexible Spending Account since the expense for the office visit was incurred on September 15, before you met your deductible.
Note: Expenses are treated as having been "incurred" when the care or service is provided, not when you are billed or pay for it.
Can I be reimbursed for expenses incurred before participation in the Plan?
No, expenses incurred before your participation begins cannot be reimbursed.
How often can I request reimbursement?
You can submit your expenses for reimbursement as often as you would like, provided that you submit your claim for reimbursement before the claims submission deadline of March 31 of the following plan year.
If I use the Prepaid MasterCard® for a health care expense(s), am I required to prove that my expenses qualify as eligible health care expenses?
Yes, all purchases with the Prepaid MasterCard® are required to be "substantiated," or verified as an eligible health care expense. There are some ways in which your eligible health care expense(s) are automatically substantiated in compliance with IRS regulations. These include co-pay matching substantiation, claims auto-substantiation, and IIAS-Certified Merchant pharmacies.
If a Prepaid MasterCard® purchase cannot be verified by one of the automatic substantiation methods, the IRS requires that you submit itemized receipts to verify that the purchase was eligible for reimbursement under the Health FSA.
What happens if my Prepaid MasterCard® expense is not automatically substantiated?
You will receive a Receipt Request letter from the Claims Administrator, Trion, requesting you to submit an itemized receipt or Explanation of Benefits (EOB) for each unsubstantiated expense. Documentation must include the merchant or provider name, service received or item purchased, date of service or date of purchase, description of the expense and the amount of the expense.
You will have 30 days from the date of the letter to submit your documentation to Trion. If you fail to submit documentation within the 30 day period, you will be sent a second Receipt Request letter from Trion. You will then have 60 days to submit your documentation to Trion.
What happens if I submit documentation to substantiate my Prepaid MasterCard® expense(s) and more information is requested?
If you submit documentation to substantiate the expense(s) and Trion requires more information to make an eligibility determination, you will be sent a Request for More Information (RMI) letter from Trion. You will then have an additional 30 days to submit your additional documentation to Trion.
What happens if I submit documentation to substantiate my Prepaid MasterCard® expense(s) and the expense is determined to be ineligible?
If you submit documentation to substantiate the expense(s) and Trion determines the expense(s) is ineligible, you will be sent an Ineligible Notice letter from Trion. You will then have 30 days to submit a repayment check to Trion. If you fail to repay the expense to the Plan, the expense will be reported to the Internal Revenue Service as taxable income to you.
What happens if I do not have documentation to submit for my Prepaid MasterCard® expense?
If documentation is not available, you may send a check payable to Trion for the expense amount. These monies will be applied to your Health FSA for future reimbursement of eligible expenses. Alternatively, if you have a different eligible expense that was paid out of pocket, you may submit an itemized receipt for it to offset the payment for the expense for which you do not have the necessary documentation.
What happens if I am not able to substantiate or repay my Prepaid MasterCard® expense(s) within the specified timeframe?
Your Prepaid MasterCard® will be temporarily suspended (i.e., cannot be used for further purchases) until the required documentation or repayment check is received and the claim(s) have been verified by Trion.
Once your Prepaid MasterCard® has been suspended, you won't be able to use your Prepaid MasterCard® for purchases. However, if you need to purchase items during this suspension period, you can still submit a claim reimbursement request form, either online at the Spending Account Service Center, on the mobile app, by fax or by mail.
If you fail to substantiate an expense or otherwise repay the expense to the Plan, the expense will be reported to the Internal Revenue Service as taxable income to you.
What happens if my Prepaid MasterCard® is suspended and then I submit documentation to substantiate my Prepaid MasterCard® expense(s)?
If your Prepaid MasterCard® has been suspended, and you then send in the necessary documentation to prove the expense's eligibility and it is deemed to be an eligible expense, your Prepaid MasterCard® will be reactivated and available for use.
What happens if my Prepaid MasterCard® is suspended and then I submit a check to repay the Prepaid MasterCard® expense(s)?
If your Prepaid MasterCard® has been suspended, and you then send in a repayment check for the ineligible expense(s), your Prepaid MasterCard® will be reactivated and available for use.
Can I carryover any 2019 plan year Limited Purpose Health Care Flexible Spending Account balance?
Yes, the carryover feature for the 2019 plan year will allow a maximum balance of $500 to be carried over from your Limited Purpose Health Care Flexible Spending Account for use in the 2020 plan year.
How does the carryover work?
Any claims for eligible expenses incurred in 2019 that are submitted between January 1, 2020 and March 31, 2020 will be reimbursed from your 2019 balance. After March 31, 2020, any 2019 balance over $500 will be forfeited. Up to $500 of your 2019 account balance will be available on January 1, 2020 for eligible expenses incurred in 2020.
For example:
  • In November 2019, you elect to contribute $2,500 to a 2020 Health FSA.
  • On December 31, 2019, you have a balance of $800 in your Health FSA.
  • In March 2020, during the run-out period, you submit a claim for $350 for eligible expenses incurred in 2019.
    • Your 2019 Health FSA balance is reduced to $450 ($800 minus $350).
  • If no other 2019 claims are submitted by March 31, 2020, the $450 balance will be carried over to your 2020 Health FSA.
  • You have $2,950 available for reimbursement in 2020 ($2,500 plus $450).
  • You incur $2,700 in eligible expenses on July 15, 2020 and submit a claim for reimbursement.
  • You are reimbursed for the $2,700 claim ($2,500 from your 2020 Health FSA plus $200 from your 2019 balance that was carried over).
    • Your 2020 balance is now reduced to $250 ($2,950 minus $2,700).
  • If no other 2020 claims are submitted by March 31, 2021, your $250 Health FSA balance will be carried over to 2021.
Does the carryover impact the amount I may contribute to the Limited Purpose Health Care Flexible Spending Account in subsequent years?
No. The carryover of up to $500 does not affect the maximum amount of contributions that you may contribute to your Health FSA. You may contribute up to the maximum amount each year, regardless of whether any amount is carried over from the prior year. The maximum contribution amount for 2019 is $2,650.
Which plan terms apply to my carryover funds if I elect to contribute to a Health FSA for 2019 and have a 2018 balance that is carried over?
The 2018 carryover funds are subject to the plan terms of the Health FSA applicable to you as a result of your medical plan and Trion Health Savings Account elections for 2019, as shown in the chart below:
2019 Medical Coverage and HSA Elections
Applicable Plan Terms
$400 Deductible Plan
Health Care Flexible Spending Account
$900 Deductible Plan
Health Care Flexible Spending Account
$1,500 Deductible Plan with Health Savings Account
Limited Purpose Health Care Flexible Spending Account
$1,500 Deductible Plan without Health Savings Account
Health Care Flexible Spending Account
$2,850 Deductible Plan with Health Savings Account
Limited Purpose Health Care Flexible Spending Account
$2,850 Deductible Plan without Health Savings Account
Health Care Flexible Spending Account
MMC Medical Coverage Waived
Health Care Flexible Spending Account
Do I have to elect to contribute to a Health FSA in the following year for the carryover funds?
No. If you do not elect a Health FSA in the following year, a Health FSA will be established for you for the carryover funds.
What type of Health FSA will be established for me if I don't elect to contribute to a Health FSA in 2019 and have a 2018 balance?
The type of Health FSA established for you depends solely on your 2019 medical coverage election, as shown in the chart below:
If you DO NOT elect a Health FSA for 2019 and have a 2018 balance
2019 Medical Coverage Election
Health FSA Established for 2019
$400 Deductible Plan
Health Care Flexible Spending Account
$900 Deductible Plan
Health Care Flexible Spending Account
$1,500 Deductible Plan
Limited Purpose Health Care Flexible Spending Account
$2,850 Deductible Plan
Limited Purpose Health Care Flexible Spending Account
MMC Medical Coverage Waived
Limited Purpose Health Care Flexible Spending Account
What is the deadline for using the carryover funds?
You have until December 31 of the plan year into which funds are carried over to incur eligible expenses. The deadline to submit claims is March 31 of the following year.
For example, $500 is carried over from 2018 to your 2019 Health FSA. You have all of 2019 to incur expenses and submit claims against any 2019 election amount plus the 2018 carryover funds. You then have until March 31, 2020 to submit claims for reimbursement for claims incurred in 2019.
Does the carryover affect my eligibility to contribute to a Health Savings Account?
No. Your eligibility to contribute to a Health Savings Account is not impacted by the carryover feature, and you can contribute to a Health Savings Account starting on January 1, as long as you meet the eligibility requirements. Please note that if you are covered by a Health Care Flexible Spending Account, you are not eligible to contribute to a Health Savings Account.
If my participation ends during the year, can I be reimbursed for expenses incurred after my participation ends?
If your participation ends during the year, you will not be reimbursed for expenses incurred after the date your participation ends (for example, after your employment ends, unless you continue participation through COBRA). You will, however, have until March 31 of the following plan year to submit for reimbursement eligible expenses you incurred during the plan year while you were participating.
If you were participating in the Health FSA solely from the prior plan year's carryover funds, you are not eligible to continue participation through COBRA. You will, however, have until March 31 of the following plan year to submit reimbursement for eligible expenses you incurred during the plan year while you were participating.
What happens to my Limited Purpose Health Care Flexible Spending Account when I am on an authorized unpaid leave of absence?
Your before-tax contributions cease. (In some circumstances, COBRA participation may be available.)
Upon return to work, your before-tax contributions will resume. The amount of your before-tax contributions will be recalculated for the remainder of the year to "catch-up" for your missed contributions while on leave. The balance of your annual election will be divided by your remaining pay dates, spreading the balance over the remaining pay periods through the end of the year. This will increase your per pay period contribution upon return from unpaid leave.
For example, suppose your annual election to the Limited Purpose Health Care Flexible Spending Account is $1,200 and you are on an authorized unpaid leave from July 1 through November 1. You will have contributed $600 before you began leave and your contributions will stop while you are on leave. When you return to work, the remaining $600 of your annual election will be spread out over the paychecks you receive in the November and December pay periods. You can submit claims for reimbursement for any eligible expenses you incur while on unpaid leave.
How do I appeal a benefit determination or denied claim?
There are special rules, procedures and deadlines that apply to appeals of benefit determinations and denied claims and you have special legal rights under ERISA. Please refer to the Administrative Information section for a description of the appeal process.
How can I get a copy of IRS Publication 502?
Go to www.irs.gov and enter "502" in the "Search" box for more information about IRC Section 213 qualified medical expenses. Note that certain items listed in Publication 502 may not qualify for Limited Purpose Health Care Flexible Spending Account reimbursement, such as premiums for dental or vision insurance. In addition, Publication 502 does not specifically address all of the requirements of Limited Purpose Health Care Flexible Spending Accounts, including post-deductible Qualified medical expenses (see "Examples of Eligible Expenses" and "Examples of Ineligible Expenses" for more information).
You may also contact the Claims Administrator for information about reimbursable qualified medical expenses.