Different Coverage Periods Allowed?

[IRA]

Our client has 10/1 - 09/30 fiscal year. Their insurance policies renew 10/1, but they want to operate the FSA on a calendar year. Can we write the plan so that the coverage period for pre-tax health insurance will be 10/1 - 09/30 but the coverage period for the FSA will be the calendar year?

[KJohnson]

1.125-5(e)(3) of the proposed regulations provide:

(3) Separate period of coverage permitted for each qualified benefit offered through FSA. Dependent care assistance, adoption assistance, and a health FSA are each permitted to have a separate period of coverage, which may be different from the plan year of the cafeteria plan.

[IRA]

Thanks. I missed that.