Multiple Plan Years

[Johearain]

Judging by my inability to find anything useful about this anywhere on the Internet, I'm assuming this situation is anything but common.

Here goes:

I have the following benefit plans with the following plan years:

125 plan: calendar year

FSAs (GP, LP, DCA, CE): calendar year

Medical: 11/1 - 10/31

All ancillary: 10/1 - 9/30

And I don't even have a guess as to what my ERISA plan year is but I'm guessing it's calendar year.

Basically, I'm cleaning up a giant mess left over from years of people who had no business administering benefits.

The only thing I want to do is term everything in December and start over on 1/1, but for various reasons let's just assume that none of these plan years can change. I cannot bring the medical in line with the ancillary, I cannot bring the 125 in line with anything else, and the FSA cannot be anything other than the calendar year. On top of all that, everything but the medical is MEWA (not Taft-Hartley).

I can't find anything to tell me one way or another whether there is a problem with having all of your plans renew at different times than your 125 plan. I've never heard of anyone doing this so for all I know it could be perfectly fine but my gut tells me there are about a thousand ways for this thing to go wrong.

So my question is:

Is this legal? Are there any compliance concerns with having your underlying plans renew at a different time than your 125 plan? Do I have to allow employees to change their medical election when the 125 plan renews (since they're taking medical in lieu of cash under the 125 plan) in January even though the insurance contract doesn't renew again until November? If I allow employees to make an election change (with respect to pretax premium deductions) when the medical plan renews in November, is that technically not permitted under the 125 plan? Unless maybe if it also happens to satisfy the change in costs/coverage LE? If I can't let them change their election with the underlying plan changes in the middle of the 125 plan year, I'm assuming we would just have a midyear rate change? What? No....

I'm so completely confused right now I'm not even sure I worded my questions correctly. In all the years I've been doing this I've never heard of an employer who decided "hey I think I'll have all my benefit plans renew at different times of the year because that's fun for me...three open enrollments every year...splendid plan, Bob! Pass the biscuits!"

Ugh. Help?