COBRA and Cafeteria Plans

[Guest tcoppeta]

Regarding Cafeteria Plans and COBRA:

We have someone who has been participating in our Flex. Health acct. through COBRA beginning in Sept. She sent payment for Sept., but has not paid for October. Yesterday I received a reimbursement request for a service rendered 9/28/01. Does date of service still matter if the person is partcipating through COBRA? Basically, my question is, even though she hasn't paid for October, do I still need to reimburse her for a service rendered in Sept.? Some regulations I read made me think I do NOT have to--because by not paying for October, she is effectively no longer participating in the plan. Does anyone know for sure?

[Mary C]

Yes, the expense is reimburseable. Just a couple of points - first, she has till 10/31 to pay the flex amount for October. Don't assume she isn't participating anymore because she hasn't paid yet, she still has 1 week. Second, she was participating when the expense was incurred, 9/28. Everything I've read said expenses incurred while a participant are payable up to the total amount elected whether the participant is an active employee or on COBRA.