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Posted

My Company is preparing to implement a salary reduction qualified transportation fringe benefit program effective 1/1/2001. In designing the program, the following issues arise:

1)If an employee ceases to make salary reduction amounts but remains employed, may s/he seek reimbursement for qualified transportation provided in the future until his/her account is used up?

2) If an employee prepays a parking expense before the program is implemented, may s/he seek reimbursement for each month as the parking is provided?

3) Can contributions be generic and applied to parking and/or transit passes or are there two separate categories?

4) If an employee is paid biweekly, then s/he will be paid three times during two months of every year. Q&A-13 of the Proposed Regulations limits salary reduction to the combined limit of $240. During months when the employee has three payroll dates, it is possible that her/his salary reduction amount will exceed the combined limit. Any suggestions for dealing with this situation?

Posted

Good questions. Now, some answers:

1. No, the only expenses that are reimbursable are those that were incurred during particpation in the plan. If the employee incurred expenses prior to terminating his/her participation, then those expenses are covered.

2. As above, only expense incurred after the program's implementation may be claimed for reimbursement. However, if, going forward, the employee has a monthly parking expense, s/he may claim that each month.

3. Contributions may be generic. All that is necessary are the proper receipts. So, if an employee takes public transportation two days a week, but takes a vanpool the other three, both expenses can be claimed.

4. What happens here is that twice a year, we have a deduction holiday in which no deductions for anything are taken. You will need to work with your payroll department to work out the detail.

Hope this helps...

Posted

As far as question #4 goes, the way around this is to deduct the full amount the first Pay Period of each month rather than split it up between 2 or 3 pay periods each month. It works out the same cash wise for the employee and is a little easier because you don't have to calculate the pay period cost for a receipt that covers a full month.

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