A Care Spending Account is a notional account. Here’s a quick overview of notional accounts:
The notion of a balance. Notional accounts display a balance for funds deposited elsewhere, giving the “notion” of a balance. Notional accounts track financial activities without funds necessarily moving.
Employer-sponsored. Notional accounts are employer-sponsored plans where employers are responsible for covering employee expenses. For that reason, notional account cash balances are primarily maintained at the employer level.
Employer funding of Care Spending Accounts
Initial required deposit
RMF
A cash reserve balance is maintained in an FBO settlement account held on behalf of the employer to cover program member expenses. Maintaining this reserve is called Required Minimum Funding (RMF).
Each employer is required to maintain a deposit. The amount of this deposit will be determined in accordance with the guidelines below and must be received prior to the start of a new plan year. We'll invoice the employer for the initial deposit, including the calculation used to determine the amount.
Weekly payment for all spend
In addition to the required deposit, employers will send a weekly ACH to cover all employee spend that occurred in the prior seven days—this includes all card transactions and claim reimbursements.
When spend exceeds deposits
If employee spending exceeds the employer’s deposit, employee spend (e.g., card transactions and claim reimbursement) cannot be processed. If this case arises, employers will:
Receive timely notification via email to send funds to cover the unpaid spend balance.
Be required to increase their required deposit amount.
Funding options
Employers have two options for payment: ACH Push or ACH Pull.
ACH Push
Employers will receive an email each week that includes a detailed listing of transactions that occurred the prior week, payment instructions, and the amount owed for the prior week’s transactions. When an email is received, the process for sending funds is initiated by the employer. Funds are due the next day. The employer must send the amount requested for payment for transactions on a weekly basis throughout the plan year.
ACH Pull
The employer will receive an email each week that includes a detailed listing of transactions that occurred the prior week, payment instructions, and the amount owed for the prior week’s transactions. When an email is sent, the funds will automatically be pulled from the funds from the employer’s bank account. This will occur weekly throughout the plan year.
Pull Failure
If an ACH pull fails, the employer will receive an email requesting a wire by the end of the day. The system is programmed to pause paying claims if there are insufficient funds in the employer's RMF account.
Return of required deposit
The required deposit will be held until the filing period for employee spending ends (i.e., the end of a notional’s extension and/or run-out period). After the end of the filing period, the required deposit for the plan year is closed, and the funds are sent back to the employer. A separate required deposit is collected for each plan year, regardless of whether the plan year overlaps with the extension/run-out period.
Required deposit for Care Spending Accounts
10% is the default standard percentage used to calculate the required deposit. However, percentages are subject to change based on plan size and funding method. See the Required Deposit and Frequency of Funding table below for more details.
Notional Benefit | Required Deposit |
Care Spending Account | Required deposit = Total PPT Elections x 10% |
Total PPT elections is the total potential spend for a Care Spending Account in a plan year. Total participant elections account for all enrolled employees and their elected benefit amounts.
Required deposit and frequency of funding
| Daily | Weekly |
Required Deposit | 2% (ACH pull) 4% (ACH push) | 4% (ACH pull) 6% (ACH push) |
Timing of Payment | ACH is generated the morning of the following business day for the prior day’s spend | ACH is generated on Monday morning as a same-day ACH |
Communications | Daily email sent in the morning with the prior day's spend | Weekly email sent on Sunday with prior week’s spend |
Communication with employers
Initial launch email
At launch, the employer will be invoiced for the amount of the initial deposit, including the calculation of the required deposit.
Weekly transaction emails
The employer will receive an email each week that includes a detailed listing of transactions that occurred the prior week, payment instructions, and the amount owed for the prior week’s transactions.