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When you say "not qualified for COBRA" do you mean COBRA for the FSA or for your group health plan? One should not affect the other. If you were covered by the group health plan before termination, then you should be COBRA-eligible for that group health plan regardless of the position you are in with regards to your FSA. I know that I have been in an "overspent" situation for my FSA a few times, but was able to continue my health coverage using COBRA provisions.

First, a small correction for the OP. The employer can actually offer a plan that covers the spread between the minimum allowed deductible and the max OOP, not just between the HSA maximum contribution limit and the max OOP. This is a common plan and referred to as a post-deductible HRA and is similar to the concept of a post-deductible FSA. To answer jpod's post: This is not at all inconsistent with HDHP/HSA code/regulations. "Other coverage" is only disqualifying if it pays/reimburses before the minimum allowed HDHP deductible. These are 2017 = $1300 Individual/$2600 Family and 2018 = $1350 Individual/2700 family. Finally, while totally self-insured plans are usually only the province of very large employers, an HDHP/HSA/(post-deductible and/or limited HRA) can be very cost effective for the employer and beneficial for the employees. Self-insuring a higher deductible above the minimums and the maximum OOP will cost far less than having an insurance company do so. After all, the insurance company is making a profit. Many medium -> large sized businesses can benefit from such constructs.

You know when I Google Lowes 401(k) login I get this link: https://leplb0180.portal.hewitt.com/web/lowes/login?forkPage=false This tells me the current TPA is Aon-Hewitt. I do another Google and I get this phone number of the Lowes' Aon-Hewitt service center https://leplb0180.portal.hewitt.com/web/lowes/pre-contactus Might want to call them and and ask questions.

I got an image of strange looking (but identical in appearance) Dr. Seuss creatures playing in a field, MOOPS and MOPES. "It's pretty hard telling the MOOPS from the MOPES, but the MOOPS play with hoops and the MOPES play with ropes." Or something equally ridiculous. I think I need therapy...

A reading from the book of Regulations Section 1.415(j)-1(d)(2) .....multiplying the applicable dollar limitation for the calendar year in which the limitation period ends by a fraction, the numerator of which is the number of months (including any fractional parts of a month)... to make it fun 1.401(a)(17)-1(b)(3)(iii) simply says the numerator of which is the number of months in the short plan year, the denominator is 12 (no mention of using fractional periods) of course every example I have ever seen always had a plan year ending at the end of the month.