"[Notice 2015-87] states that the carryover amount must be included in determining the amount of the benefit that a qualified beneficiary is entitled to receive.... The Notice clarifies that this does not include any unused carry-over amounts carried over from the previous plan year.... [H]ealth FSAs must allow carryovers by similarly situated COBRA beneficiaries, on the same basis as non-COBRA beneficiaries. However, the FSA is not required to allow a COBRA beneficiary to elect additional salary reduction amounts for the carryover period, or to have access to any employer contributions to the health FSA made during the carryover period."  MORE >>