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Flexible Spending Accounts (FSA) Clarification on “Effective Date of Participation”

Point-of-Clarification: This is to provide you with a clear explanation for the effective date of plan participation for the Flexible Spending Accounts. This pertains to both the Health FSA and the DepCare FSA. This is VERY important during pre-enrollment in helping to determine which expenses will be eligible when calculating the annual agreement amount.

The general rule is that participation in the plan begins the first day of the month following the month in which the employee enrolls, subject to Payroll deadlines. NOTE: This is very different from the effective dates of the other health and welfare plans. Read on.

Here are EXAMPLES which assume that the date of hire/eligibility is January 27, 2009:

EXAMPLE 1:
Enrollment is registered before deadline for March 1 monthly payroll:

A) The employee completes online enrollment and it is confirmed on February 12 AND it registers on the local payroll database in time for March 1 monthly payroll deadline.
B) The system will automatically generate a "systems effective date" of 02/28/09 (this can be seen on the OLPPS/IDED and IRET screens).
C) Expenses incurred as of March 1, 2009 (or later) are eligible for reimbursement. Any expenses incurred before that date will be denied.

EXAMPLE 2:
Enrollment is registered after deadline for March 1 monthly payroll:

A) The employee completes online enrollment (and it is confirmed) on February 26, during PIE but it registers on the local payroll database too late for March 1 monthly payroll deadline.
B) The system will automatically generate a "systems effective date" of 03/31/09 (this can be seen on the OLPPS/IDED and IRET screens).
C) Expenses incurred as of April 1, 2009 (or later) are eligible for reimbursement. Any expenses incurred before that date will be denied.

Keep in mind also that, following confirmation of online enrollment, it can take up to two business-days for the online enrollment to register on the local Payroll database.

Department Administrators: See OLPPS/IDED or IRET screens.