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"period of coverage" for a premium conversion plan


Guest JGodsoe
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Guest JGodsoe

May a premium conversion plan provide for a semi-annual enrollment period without violating cafeteria plan/constructive receipt rules? 125 regs appear to only define "period of coverage" as a 12 month period with respect to health FSAs and Dependent Care plans. Can this be interpreted as meaning that for non-health FSA and Dependent Care benefits (such as medical coverage) the applicable period of coverage durin which participants are prohibited from changing elections (unless the 125 exceptions apply) may be six months?

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