News & Analysis as of

Benefit Plan Sponsors Cafeteria Plans Flexible Spending Accounts

Bricker Graydon LLP

What Happens to Health FSA Balances When COBRA Coverage is Elected?

Bricker Graydon LLP on

While most plan sponsors understand that their plans must offer continuation coverage under COBRA for their medical benefits, many administrators find themselves on less solid ground when it comes to COBRA coverage and health...more

Bass, Berry & Sims PLC

Flexible Spending Accounts: Require Substantiation or Risk Disqualification

Bass, Berry & Sims PLC on

On April 28, 2023, the IRS Office of Chief Counsel issued Chief Counsel Advice Memorandum 202317020 (CCA Memo), with an important reminder to employers who provide health and dependent care flexible spending arrangements...more

Harris Beach Murtha PLLC

IRS Releases Information Letters on Substantiation Rules for Health FSA Debit Cards

The IRS recently released two Information Letters addressing the substantiation rules that apply to health flexible spending account (FSA) debit cards. (As an aside, IRS Information Letters call attention to a...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

COVID-19 Cafeteria Plan Relief: IRS Clears the Mud

The Consolidated Appropriations Act, 2021 (CAA) contained temporary relief measures aimed at addressing unused contributions to health flexible spending accounts (FSA) and dependent care assistance programs (DCAP). On...more

Patterson Belknap Webb & Tyler LLP

IRS Guidance on Additional Flexible Spending Account and Mid-Year Election Relief Under Cafeteria Plans in 2021 and 2020

On February 18, 2021, the IRS issued Notice 2021-15, which provides guidance with regard to a number of provisions of the temporary changes to the rules related to the operation of health and dependent care flexible spending...more

Perkins Coie

IRS Clarifies Extended Cafeteria Plan Relief

Perkins Coie on

Much of the previous relief that had been granted to cafeteria plans during the COVID-19 pandemic was set to expire after 2020. In late December, though, Congress passed the Consolidated Appropriations Act, 2021 (CAA), which...more

Patterson Belknap Webb & Tyler LLP

Stimulus Legislation Allows Temporary Changes to Health and Dependent Care Flexible Spending Account Plan Rules

On December 27, 2020, the latest of several COVID-19 relief packages became law, as part of the Consolidated Appropriations Act, 2021 (the “New Law”). One of the most notable benefits-related provisions in the New Law...more

Proskauer - Employee Benefits & Executive...

Additional Relief for FSA Benefits

As part of the COVID-19 relief package passed by Congress earlier this week, the federal government expands on earlier relief issued by the Internal Revenue Service (IRS) for health and dependent care flexible spending...more

Husch Blackwell LLP

New IRS Guidance Expands Flexibility For Cafeteria Plans In Response To COVID-19

Husch Blackwell LLP on

On May 12, 2020, the Internal Revenue Service (IRS) released new COVID-19 guidance (Notice 2020-29 and Notice 2020-33), providing both temporary and permanent flexibility to Internal Revenue Code section 125 cafeteria...more

Faegre Drinker Biddle & Reath LLP

Normal Cafeteria Plan Mid-Year Election Change Rules Apply – For Now

As of March 20, 2020, there has been no legislation or IRS guidance allowing plan sponsors to permit cafeteria plan participants to make COVID-19 related mid-year election changes, other than those which also meet the current...more

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