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Cafeteria Plan calendar year-Insurance policy-fiscal year


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I have a cafeteria plan that is on a calendar year basis.

The client's insurance policies are on a fiscal year basis (5/1-4/30).

I am aware of how to file Form 5500 with these policies.

The question was asked as to how to handle the "lock in" period.

The employees should be able to enroll and make changes for 5/1 open enrollment.

The cafeteria plan has a January to December term on their forms and would normally be "locked in" for this period unless they had a Change in Status.

What are your thoughts on this considering the two different periods?

I suggested changing the cafeteria plan year to match the insurance policy years to make it less confusing.

Thank You,


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I think your thoughts are correct. You need to get them on the same year. I don't see how else it could work. The 125 regs have some verbiage in them that seeks to limit plan year changes, but the point of that is to not use plan year changes as a way around the annual lock-in. You need to read them, but hopefully would not prevent you from doing what you need to.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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