The purpose of this Brief is to remind plan sponsors that, if the sponsor has an IRC Section 125 (Cafeteria Plan) with a health care spending account component, the sponsor must amend the plan no later than June 30, 2011 eliminating coverage for over-the-counter non-prescribed drugs and medicines (OTC) as of January 1, 2011 regardless of the plan year of the cafeteria plan. For those plans which were first implemented on or after January 1, 2011, we assume it did not contain this OTC benefit.

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