Health FSA / COBRA Administrative Forms

[Guest EMC]

How are people incorporating the clearer, but still complicated, Health FSA rules in the '99 Proposed Regs into their administative forms?

For example, the facts of a particular case may permit a terminating employee to elect COBRA cont. covg. under the Health FSA for the remainder of the current year, but not permit such cont. covg. beyond that. Because a Health FSA that can so limit its COBRA liability must also offer another Group Health Plan (a HIPAA Excepted Health FSA), the scenario is as follows: a terminating individual is entitled to 18 mos. of COBRA cont. covg. under the "other" Group Health Plan, AND is entitled to "x" number of months of COBRA cont. covg. under the Health FSA for the months remaining in the current year. Therefore, in the section on the Election Form detailing the length of the cont. Covg., there must be a place for the election of "x" months under the Health FSA as well as a place to elect up to 18 months for the other GHP.

This is just an example, but doesn't this make election forms fairly complicated? Are others out there modifying existing forms for Health FSA options or creating separate forms for the Health FSA elections under COBRA? Thanks.