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MCS administers flexible
compensation accounts (FSAs) for employers with 15 or more
employees. In addition to "Premium Only Plans", MCS also
administers Health Care
and Dependent Care Spending Accounts.
Health
Care and Dependent Care Spending Accounts
MCS
administers IRS qualified Section 125 Plans (sometimes known as Flexible
Compensation) for employers. These plans enable employees to take a salary reduction option, whereby
certain eligible expenses may be paid for with pre-tax dollars rather than
after-tax dollars. Generally
these eligible expenses include unreimbursed medical expenses or dependent
care expenses incurred for care of the employee, his or her spouse and
dependent(s). For example, a
Flexible Compensation Plan might be used to reimburse an employee medical
expenses including deductibles, and co-payment as well as qualified day
care expenses. Expenses
for annual physicals and preventive care as well as dental, vision, and
qualified over-the-counter medications also can be included.
For
Section 125 Plans our services include:
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Web
access for 24/7 account updates.
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A
Powerpoint presentation for employees describing the benefits of
Section 125.
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A
suggested plan document for review by employer counsel.
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Enrollment,
claim, and change of status forms to be utilized for the
administration of the plan. All
forms are available electronically and can be tailored to employers
specifications.
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Co-ordination
of Section 125 benefits with your present employee benefit
program.
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Suggested
Summary Plan Description literature for employees.
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Personalized
claims service including a toll free telephone number for direct
contact with
claims specialists.
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Interactive
Voice Response system and Web access for 24 hours, 7 days per week
account access.
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Participant
claim direct deposit option.
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A
quarterly status report mailed to the employer for distribution to
employees.
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Management
reports (also available through the MCS Web Site).
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Multiple
account funding options are available as well as electronic payroll
downloads.
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Continuing
advice and assistance to the employer and employees to ensure the
successful ongoing operation of
The Plan.
Overview
of the Flex Debit Card Option
The
Flex Debit Card is designed to charge an employee’s FSA coverage
directly while providing oversight capability by MCS. An account is
established for the employer, and a subaccount, indicating the amount of
available coverage, is established for each plan participant.
Each participant is then issued a debit card (the “Card”).
The Card looks like a typical credit or debit card, and in fact is
issued under the Visa or MasterCard system, but is only accepted at 23
types of merchant or provider locations as defined by merchant category
codes (“MCCs”). Visa, for
example, has over 550 MCCs (e.g., one for restaurants, one for department
stores, one for gas stations, one for dentists, etc.).
The Card is programmed to be accepted only at the 23 qualified
merchant types relating directly to healthcare where eligible purchases
can be made, such as hospitals, doctors, pharmacies, opticians, etc.
This limitation in and of itself substantially ensures that the
Card will not be used for non-qualifying expenses.
The likelihood is that the overwhelming majority of expenses
incurred from one of the 23 categories of merchants will be qualifying
expenses under the FSA. As is
true elsewhere in our tax system, use of the Card involves voluntary
compliance that is encouraged by a system of tax and employer-imposed
penalties. Plus, the plan
administrators have the option to turn cards on or off from their
location, when they deem appropriate.
Once
a cardholder swipes the Card at an eligible merchant location, the system
preliminarily screens the transaction.
It determines whether there are sufficient funds credited to the
account, then the employer account, and finally the employee coverage
amount. Only if there is
enough money credited to each of these accounts is the transaction
approved. It is at this point
that the merchant will be paid from the employer’s “advance
account.” There is no
direct payment or reimbursement to the participant.
To
ensure that a particular transaction qualifies for pre-tax reimbursement,
a hold is placed on the employee’s coverage amount until MCS deems the
expense to be a permissible expense under Section 213 of the Code.
MCS will review the transaction amount, merchant type, merchant
name and the date of the charge. The
plan benefit is treated as conditional (or, “paid but pending”) until
MCS confirms that the services qualify for pre-tax payment by the
employer. MCS can either
approve or deny the transaction. In
the event an eligibility determination is not possible, MCS has the option
of “pending” the transaction and requesting more detail from the
cardholder.
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