A Dependent Care Flexible Spending Account (DCFSA) is a type of pre-tax benefit account savings account where you can set aside pre-tax dollars to pay for qualifying dependent care expenses. These are expenses that allow the employee to be employed or look for work.
To offer a DCFSA with Gusto, your company must offer health insurance with Gusto. If you already offer a DCFSA and manage it through a third party, admins can set up payroll deductions.
Choose a dropdown below to learn about how a DCFSA works. If your DCFSA is managed by Gusto, head to the Benefits section of your Gusto account to learn about your plan details.
DCFSAs are regulated by IRS Publication 503. They are not subject to Section 125 (ERISA) requirements.
A DCFSA is post-funded, meaning that funds are only available to an employee once deductions are made through payroll. Pre-tax deductions are taken from the employee’s payroll throughout the year and those deductions are available to spend that same day.
DCFSA funds are "use it or lose it." Funds expire if they are not used by the end of the plan year, unless the company offers extension options like a runout or grace period.
Who's eligible
Any employee who's eligible to participate in health benefits with your company is eligible to participate in the Dependent Care FSA. This means:
Who's ineligible
Per the IRS, some individuals are not eligible to contribute to a DCFSA:
Dependent Care FSA funds can be spent on care for qualified dependents that allows an employee (and their spouse, if applicable) to work or look for work.
See IRS Publication 503 for a full list of eligible expenses and what makes a dependent qualified.
Here are a couple examples of qualified dependents:
Check out the "Who Is A Qualifying Person?" section of IRS Publication 503 for more info.
Can I pay a relative for care with my DCFSA?
You can count work-related payments you make to relatives who are not your dependents, even if they live in your home. However, do not count any amounts you pay to:
Does my babysitter need to be licensed?
You do not need to use a licensed babysitter. However, you cannot be reimbursed for the babysitting services of a tax-dependent or someone who is not 18 or older and the babysitting must be work-related.
Eligible employees choose how much they want to contribute during open enrollment. Their contribution is also known as their election.
Filing status | 2023 | 2024 |
Married and filing jointly (the employee and their spouse cannot together exceed this limit) | $5,000 | $5,000 |
Single parent | $5,000 | $5,000 |
Married and filing separately | $2,500 | $2,500 |
If you want to know how much you've contributed to your DCFSA, check your paystub or the Benefits section of your Gusto account.
The annual amount you choose to contribute during your enrollment is locked in for the company’s policy year. Your total election amount is divided by the number of regular payrolls your company will run during the policy year and deducted evenly from your paychecks. DCFSA elections cannot be changed unless you experience a qualifying life event.
If you experience a qualifying life event and think you're eligible to change your DCFSA contribution, reach out to [email protected]. Include the qualifying life event you experienced, documentation of the event, and the new contribution amount you'd like.
Keep in mind that if you want to lower your contribution amount, it can only be lowered up to the amount that has already been used or contributed, whichever is larger.
DCFSAs are post-funded, meaning that you can only use funds once they've been deducted from payroll and deposited into your account on the check date.
Employee contributions are deducted pre-tax from payroll. For paychecks with DCFSA deductions, your funds are available to use on the check date.
If a deduction is missed, the remaining amount owed is redistributed over the remaining payrolls in the policy year.
When an employee sets aside pre-tax money for a Dependent Care FSA, their gross taxable income is lowered. Since employers are taxed for FICA on the amount an employee earns, employer taxes are also reduced.
Here's what benefits admins need to know to set up DCFSA for your company.
Here are the company fees to offer a DCFSA with Gusto:
An enrolling employee is someone with an active benefit in that month or someone in a runout period.
To offer a DCFSA through Gusto, your company must have Gusto-brokered medical insurance or use the broker integration. If you already have benefits with Gusto, you can only add a DCFSA during your next renewal.
To set up medical coverage and a DCFSA, check out this article.
If you offer a DCFSA through a third party, you can set up pre-tax payroll deductions for enrolled employees.
Follow these steps if your company offers a DCFSA you'd like to transfer to Gusto. You must offer medical benefits through Gusto or use the broker integration to offer a Gusto DCFSA.
Before you begin, you'll need a list of currently enrolled employees, their balances, and year-to-date contributions. Reach out to your current DCFSA administrator if you need help finding this.
Once you complete the steps in Gusto, we'll start setting up your benefit and reach out to you with next steps.
Non-discrimination testing is a method you can use to make sure your benefits don’t favor highly compensated or key employees. For Flexible Spending Accounts (FSAs), a common test to use is the key employee concentration test. For Dependent Care Flexible Spending Accounts (DCFSA), both the key employee concentration test and the average benefits test are commonly used. You are encouraged to check with your tax expert and/or legal counsel to confirm which tests are necessary for your company.
We suggest that you run non-discrimination tests three times during your policy year to avoid any issues with the IRS:
If you have concerns about failing these tests throughout the policy year, you should check with your tax expert and/or legal counsel to determine which of the options below is best for you and then reach out to our team so we can help make changes to your benefits. Here’s what we may recommend:
The key employee concentration test requires that, of your employees’ total annual benefit amount, 25% or less of this amount comes from your key employees’ benefit totals. The total annual benefit amount includes pre-tax premiums of all lines of coverage, such as medical, dental, and vision, for both employees and dependents. If none of your company’s key employees opt in to the Health FSA, your company passes this test automatically.
If key employees account for greater than 25% of the total annual benefit amount, you are likely to fail the key employee concentration test at the end of your policy year
A key employee, is defined by the IRS as:
The average benefits test applies in a variety of situations, but for Gusto customers it’s especially important for DCFSAs. This test requires that the average election amount for the DCFSA of non-highly compensated employees be at least 55% of the average contribution amount for the DCFSA of highly compensated employees.
It can be difficult to predict whether your company may pass or fail this test until open enrollment is over, as it is based solely on your employees’ choice to opt into (or out of) the Dependent Care FSA. It can also be difficult to predict throughout the duration of your policy year, as any new hires opting in (or terminated employees losing this benefit), can also affect your pass/fail result at the end of your policy year.
A highly compensated employee, as defined by the IRS, is identified as an employee:
If everyone at your company owns more than 5% of the company and/or the majority of the team earns more than $120k, the DCFSA may not be the best benefit for your company.
Employees who satisfy the following criteria do not count toward the top-paid group:
Note: This article is for general and educational reference only and is accurate as of April 1, 2019. Since IRS laws are complex and change frequently, we'd recommend working with a tax professional to perform non-discrimination testing.
Here is some additional information on the specific IRS regulations pertaining to non-discrimination testing:
Who’s eligible
Any employee who's eligible to participate in health benefits with your company is eligible to participate in the Dependent Care FSA. This means:
Who’s ineligible
Per the IRS, some individuals are not eligible to contribute to a DCFSA:
Follow the steps below to enroll as a new hire or during open enrollment:
Your Gusto Benefits Card will arrive at your mailing address in a plain white envelope before the benefit begins.
After the benefit's effective date, you can find your plan details in the Benefits section of your Gusto account. There you'll also find your plan document, which explains DCFSA rules and how to use your benefits. Payroll deductions will begin on the first payroll of the DCFSA's plan year.
Note: This section is for benefits managed through the Gusto Benefits Card Manager, not the Benefits Card Hub.
Dependent Care FSA funds can be used on care for qualified dependents that allows an employee (and their spouse, if applicable) to work or look for work.
How to use your DCFSA funds
There are two ways you can use your funds on eligible expenses:
Eligible expenses
Here's what makes an expense eligible:
When your plan year ends or you leave your company, you may have extra time to submit claims. Check out the dropdown below for more info.
Receiving your card
We'll mail your Gusto Benefits Card before the effective date. We'll email you once it's been sent, and it'll arrive in a blank white envelope. The same card can be used for up to 3 years if you renew your benefit each year.
Add your card to mobile pay
Once you receive your card in the mail, you can add it to your mobile wallet. Choose your phone provider for instructions:
If you use your card for the first time by swiping it or using mobile pay in person, the card is automatically activated. If your first use of the card is an online transaction, follow the steps below to activate it first.
If you need help adding your card to your mobile wallet, contact your mobile wallet provider.
Activate your card
Swiping your card at a physical location will automatically activate it.
If your first use of the card is an online transaction, follow the steps below to activate it first.
Use your card for multiple benefits
If your company offers multiple benefits savings accounts through Gusto and you enroll in more than one, you'll use the same Gusto Benefits Card for all transactions. For example, if you enroll in both commuter benefits and an FSA, you'll use the same Gusto Benefits Card for eligible commuting and medical expenses. Eligible claims and transactions are automatically drawn from the correct account.
Find your PIN
Your Gusto Benefits Card should be used as a credit card, though some vendors require a PIN.
Report your card as lost or stolen and order a new card
If your Gusto Benefits Card has been misplaced or stolen, report it as soon as possible.
If you do not have the option to issue another card to yourself, reach out to [email protected], and we'll issue you a new Gusto Benefits Card.
Dispute a card transaction
If you find a transaction that you did not complete yourself, and you believe to be fraudulent, you can dispute it.
Note: If you recognize the transaction, but the service provider charged the wrong amount, contact your provider directly to discuss the transaction.
If the dispute is approved, you should see a refund on your account within 55 days.
You may use your card on qualified expenses for yourself and your dependents. An eligible dependent is any family member who is a tax dependent on your tax return.
If needed, follow the steps below to add a dependent to your account and issue them their own card.
We'll mail the card in a blank white envelope to your mailing address within 7–10 days.
Follow the steps below to register for the Gusto Benefits Card Manager (GBCM) for the first time.
Once you're registered, you can access your Gusto Benefits Card Manager at this link or from the Benefits tab of your account.
If you've left your company and did not register for your Gusto Benefits Card Manager account during your employment, reach out to [email protected] for your sign-in credentials.
You can review transactions, submit claims, and more in the Gusto Benefits Card Manager. If you need to create your Gusto Benefits Card Manager account, follow the steps above.
Receipt requirements
To submit a claim, make sure you have documentation for the service that includes:
Submit a claim
Follow these steps to submit your claim.
We’ll let you know once your claim has been approved or denied. To avoid a denied claim, make sure you’re using your card only for eligible expenses.
When you'll be reimbursed
If your claim is approved, we'll email you to ask if you want to be reimbursed with a check or by direct deposit. A check will arrive at your mailing address in 7–10 days. If you choose direct deposit, it will appear in 3–5 business days. It will be sent to the bank account listed under “Reimbursement Details” in your Gusto Benefits Card Manager and it will appear as an MBI or Med-I-Bank credit.
Need to submit claims after leaving your company?
If your benefit has a runout period, you may have extra time to submit claims for qualifying expenses incurred during your employment.
If you didn’t register for your Gusto Benefits Card Manager account during your employment, reach out to [email protected] for your sign-in credentials.
If we need more info from you to process a DCFSA claim, we'll email you. The IRS requires that we validate the eligibility of each DCFSA expense.
This may happen if you use your Gusto Benefits Card at a vendor that does not have an inventory information approval system (IIAS)—a system that contains known IRS-approved expenses.
We'll review your documentation and email you with an update within 3–5 business days.
If you do not upload documentation, we'll send a reminder email one week and three weeks after the first notification. If 35 days pass after the second reminder email with no documentation uploaded, the account will be suspended and a balance due will be created.
Here's what your documentation should include:
If you're unable to provide documentation online, you may fax it to us. Print the email we sent to you requesting the missing documentation. Fax the email and your documentation to (844) 791-8320.
If you used your Gusto Benefits Card on an ineligible expense, we’ll email you with next steps. Your card may be temporarily suspended until the ineligible expense is resolved.
To resolve an ineligible expense, you can either offset the balance with an eligible expense, or you can pay it back from your bank account.
Option 1: Offset the balance with an eligible expense
Your card is reactivated once the offset is processed, and you no longer owe a balance for an ineligible expense.
Option 2: Pay the expense back from your personal bank account
The repayment will be processed within 7 business days. When you submit a repayment, the "Balance Due" is removed from your home page, but the expense is still listed as "ineligible". If approved, the expense will be updated.
If your card is temporarily suspended, and you want to pay for any eligible expenses in the meantime, you can pay out of pocket and submit a claim with your receipt.
You can submit a Dependent Care FSA claim over the balance that you have available, but you'll only be reimbursed up to the amount you have in the account (if approved). You'll be reimbursed for the remaining balance over time or until you reach your annual DCFSA contribution.
Note: This section is for benefits powered by Elevate and managed through the Benefits Card Hub, not the Gusto Benefits Card Manager.
How to use your Dependent Care FSA funds
Dependent Care FSA funds can be used on care for qualified dependents that allows an employee (and their spouse, if applicable) to work or look for work. There are three ways you can use your funds on eligible expenses:
Eligible expenses
Here's what makes an expense eligible:
When your plan year ends or you leave your company, you may have extra time to submit claims. Check out the dropdown below for more info.
Here's how to set up your Benefits Card Hub account, sign in, and recover your password or username.
To access the Benefits Card Hub for the first time, follow the steps below to register.
If you've left your company and did not register for the Benefits Card Hub during your employment: It’s not too late to register by using the steps below. But first, contact Gusto to request your registration ID.
Once you register for the Benefits Card Hub, you can sign in at this link or from your Gusto account.
Here's how to get there from your Gusto account:
If you do not know your password or username for the Benefits Cards Hub, follow these steps to recover or update it.
Here's how to add your card to mobile pay, lock or replace your card, dispute a transaction, and more.
Your Gusto benefits card will be mailed to your home address on file with Gusto after you’ve completed your enrollment into a pre-tax benefit (FSA, DCFSA, HSA, or Commuter).
Once mailed, it should arrive within 7–10 business days in a nondescript envelope from Gusto. Sign in to the Benefits Card Hub if you need to report your card lost or stolen.
You will only receive one card even if you are enrolled in multiple pre-tax benefit accounts. The card will automatically apply expenses to the appropriate account.
Once you’ve activated your card, you can add it to your mobile wallet. Choose your phone provider for instructions:
If you need help adding your card to your mobile wallet, contact your mobile wallet provider.
You must activate your Gusto benefits card before you can use it. You can activate it by phone or online in the Benefits Card Hub.
You'll set up a PIN during activation, but note that no vendors should require a PIN.
Activate your card by phone
Call the number on the sticker applied to your card. You will be prompted to provide the following information:
Activate your card online in the Benefits Card Hub
You will only receive one card even if you are enrolled in multiple pre-tax benefit accounts. The card automatically applies expenses to the appropriate account.
You set up a PIN when you activate your Gusto benefits card. However, you should not have to use it. Always check out using the credit option. If prompted for a PIN, you should always try to bypass the option.
Most vendors do not require a PIN to complete a transaction, even if prompted.
You may need to update a Gusto benefits card if one is lost or stolen, or if you no longer wish for your dependent to have an active card. Follow the steps below to manage your cards.
Lock a card
Close a card
Here's how to close one of the cards associated with your account. For example, you may do this if you no longer wish for your dependent to have an active card.
Replace a card
You have 60 days from the date of a transaction to dispute it for fraud. After 60 days, the transaction cannot be disputed. If you have a transaction you need to dispute, fill out this form.
What happens next?
Your dispute will go through an initial review within 3–5 business days. After the initial review, if deemed eligible for dispute, a provisional credit will be applied within 5–7 business days. If the dispute is approved, the credit will remain. If the dispute is denied, the credit will be removed. In total this typically takes around 60 days.
You may be able to request a Gusto benefits card for eligible dependents. There are two important consequences to ordering a dependent card that you must be aware of.
Here's how to request a Gusto benefits card for your dependent.
You can review and manage your expenses in the Benefits Card Hub: Under "My Accounts," click DCFSA. See the steps above on how to register or sign in to the Benefits Card Hub.
Add or edit a reimbursement method
You can choose to be reimbursed by check or direct deposit. Follow these steps to set up or change your reimbursement method:
Note: Adding a bank account can take 2–3 business days to verify.
Receipt requirements
Make sure your receipt includes:
Submit an expense for reimbursement
If you paid out of pocket for an eligible expense, you may submit it for reimbursement as long as the service was rendered during your coverage period, and the final date to submit claims has not passed.
To submit an expense for reimbursement:
If the information can be validated immediately, your claim will be approved on the spot. If additional review is required you will receive an email when the claim has been processed. This is typically 3-5 business days
When you'll be reimbursed
If your claim is approved, you’ll be reimbursed using the reimbursement method you selected above.
Here's how the reimbursement is sent, based on the reimbursement method you've chosen:
Submit an expense for reimbursement after leaving your company
If your benefit has a runout period, you may have extra time to submit claims for qualifying expenses incurred during your employment. You can confirm your last day to submit an expense in the Benefits Card Hub.
If you did not register for your Benefits Card Hub during your employment, contact Gusto for help.
Pay a bill directly
If you receive a bill for an eligible expense, you can pay it via check directly from your associated pre-tax benefit account.
If you've already paid the bill and want to be reimbursed, go to the header above titled "Submit an expense for reimbursement."
Here's how to pay a bill:
If all the required information can be identified in the receipt, your claim will be automatically approved and the payment will be made to the provider by check. If not, the claim will be manually reviewed within 3-5 business days. You will receive an email once the claim has been reviewed and processed.
Note: Checks expire after 180 days. You will receive an email if a check is about to expire. If the check was sent to your provider please connect with them first about the payment.
The IRS requires that we validate the eligibility of each DCFSA expense. If an expense requires additional information to complete this validation, we’ll email you. You’ll also see it as a notification on your Benefits Card Hub homepage.
Here's how to resolve an expense requiring action:
We'll review your documentation and email you with an update within 3–5 business days.
Here's what your documentation should include:
If you used your Gusto Benefits Card on an ineligible expense, we’ll email you. To make sure you're using the account’s funds by IRS standards, you should resolve this expense before the account expires.
To resolve an ineligible expense, you can either offset the balance with an eligible expense, or you can pay it back with a check.
Option 1: Offset the balance with an eligible expense
Option 2: Pay the expense back via check
Mail a check for the amount of the transaction to:
You can submit a Dependent Care FSA expense for reimbursement that is over the balance that you have available. If approved, you'll only be reimbursed up to the amount you have in the account. Then you'll be reimbursed for the remaining balance over time, or until you reach your annual DCFSA contribution.
Choose a section below for more ways to manage your benefits.
If you are no longer interested in offering a DCFSA, you can either cancel the plan at your next benefits renewal, or cancel the benefit mid-year.
The contribution amount you choose during your enrollment is locked in for the remainder of the company’s policy year. You can only change your DCFSA if you experience a valid qualifying life event, like a change in day care needs.
Check out the chart below for life events that qualify you to make changes, and click here for steps to change your DCFSA in Gusto.
Here are the contribution changes you can make:
Event | Changes you can make |
Change in day care needs |
|
Relocation (only if it leads to a change in the cost of dependent care) |
|
Court order |
|
Birth or adoption |
|
Marriage, domestic partnership, or civil union |
|
Divorce or legal separation |
|
You enroll in a different DCFSA |
|
Your dependent enrolls in a different DCFSA |
|
You or a dependent gain eligibility for a DCFSA |
|
You aged out of a parent's plan |
|
Death of a dependent |
|
Dependent lost other coverage |
|
Moved in or out of plan area |
|
International relocation |
|
Death of a dependent |
|
There are no tax forms required for DCFSA benefits.
After your plan year ends or if you leave your company, you may have extra time to submit expenses for reimbursements.
To confirm your deadline to submit an expense for reimbursement: Sign in to your Gusto employee account and go to the Benefits section. Click the Dependent Care FSA tile, then access either your Gusto Benefits Card Manager or Benefits Card Hub.
If your plan year has ended or your company has canceled the Dependent Care FSA, you may still have access to your Dependent Care FSA funds via the runout period, grace period, or rollover.
If your company is moving off of Gusto or has found a new broker, connect with your employer on whether your Dependent Care FSA will be moving as well. In either of these situations, you will not be able to submit expenses for reimbursement after the plan has ended.
At the end of your company’s plan year, you have 90 days to submit claims for services rendered during your previous plan year. This is called the runout period.
Your reimbursement request(s) must be for services rendered during your eligible coverage period. If you have two accounts that are eligible for reimbursements, you will submit a reimbursement request separately.
In addition to the runout period, your plan may also have a grace period. This is extra time for you to use DCFSA funds on new expenses after the plan year ends. The grace period is typically 2 months and 15 days. Check the DCFSA tile in the Benefits section of your Gusto account to see if your plan has this and your last day to submit claims.
Once the runout period ends, any remaining funds left in your account are forfeited to the employer. Since DCFSAs are linked to the company's bank account, the funds remain there.
A DCFSA is terminated on the last day of employment. Funds are "use it or lose it," meaning any leftover funds after the runout period are forfeited to the employer.
You have until 90 days after your last day of employment to submit reimbursement requests for services rendered during the plan year. This is called a runout period, and you can find the last day you can submit a request in the Dependent Care FSA section of your Benefits Card Hub.
90 days after your last day of employment, any remaining funds left in your account are forfeited to the employer. Since DCFSAs are linked to the company's bank account, the funds remain there.
On February 1st, 2024, the Pennsylvania Department of Revenue announced a new tax credit for Dependent Care Flexible Spending Account (DCFSA) contributions. It’s retroactively effective Jan 1, 2023.
Here’s how Pennsylvania taxes are affected:
The maximum tax credit is $154.
Q: How much will my PA liability be lowered by?
A: The IRS sets the yearly DCFSA maximum contribution (employer/employee) amount listed in box 10 as $5,000. If $5,000 is the total listed in box 10 of Form W-2, this adjustment in wages should lower your PA tax liability by a maximum of $154. Of course, individual contributions can differ, so this amount may be lower.
Q: What about my 2024 DCFSA contributions?
A: For 2024, any contributions made to a DCFSA will automatically be adjusted toward taxable wages in accordance with the new regulations.
Q: Why are we learning about this so late?
A: The Pennsylvania Department of Revenue executed this change on 12/14/23, and released information to the public on 2/1/24, after the 1/31/24 deadline for issuing the federal Form W-4. There were several unanswered questions in the 2/1/24 release that needed to be addressed before programming changes were made.
Q: I've already filed my taxes. What should I do?
A: The maximum tax credit for DCFSA is $154. This amount can be lower based on differences in employer and employee contribution amounts. If you need to change your initial personal filings, consult your tax professional.
Learn more on the Pennsylvania Department of Revenue website.
Below is a template employers can provide to their employees who are impacted by the change in dependent care benefit. This notice is used only if an employee has decided to amend their personal tax return.
To: Employees
Re: 2023 Dependent Care Flexible Spending Account (DCFSA)
We've been notified by our payroll service provider, Gusto, that your Dependent Care Flexible Spending Account (DCFSA) benefit is no longer subject to Pennsylvania personal withholding tax for both employer and/or employee contributions. The Pennsylvania Department of Revenue enacted this change on 12/14/23, and released information publicly on 2/1/24 after Form W-2s were finalized. This change is effective retroactively to 1/1/23.
As a result, if you choose to make an adjustment to your personal tax return, this communication serves as a confirmation, verifying why the amount on the Form W-2 (box 16) does not match the adjustment amount you report on line 1a of your PA personal tax return.
To take advantage of the tax credit up to a maximum of $154, you'll need to modify your PA personal tax return line 1a amount. Line 1a differs from what's reported on your Form W-2 (box 16) because of a manual adjustment/calculation in PA wages. The wage displayed on line 1a of your personal return must be adjusted by taking the amount on Form W-2 (box 16) and reducing it by the amount listed on Form W-2 (box 10).
Click here for the agency’s guidance recommending the adjustment amount.
Please keep a copy of this communication for your records with your 2023 PA tax return if you're filing your returns electronically.
Sincerely,
The Gusto Team
On behalf of Employer