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Update for 2020: IRS has opened up mid-year FSA changes for the 2020 plan year. To learn more, check out this article.
Sometimes after you sign up for a Flexible Spending Account (FSA), your life circumstances change. Maybe you got married, or welcomed a new addition to your family. Now you're wondering if you can change your FSA contributions.
Normally, you can only elect contributions into your FSA during a yearly open enrollment period, but there are exceptions.
Qualifying event: Mid-year changes
A qualifying event affects your eligibility for coverage under your specific FSA plan. When a qualifying event occurs, many employers allow you to make a mid-year change in elections.
Qualifying events are divided into main categories:
A change in marital status
Marriage, divorce, annulment, death of a spouse, and legal separation.
A change in the number of [tax] dependents
Birth, adoption, placement for adoption, and death.
Starting a new job, quitting a job, changing from full-time to part-time, etc.
A few things to keep in mind:
Job changes also affect dependents and their coverage.
Not all benefit elections can be changed with a job change – unless, for example, someone would be paying a higher premium due to a job change.
If someone changes from a full-time job to a part-time position, that impacts eligibility as well.
Dependents: Newly satisfying or no longer meeting dependent eligibility requirements.
- Under regulations set forth in the Affordable Care Act (ACA), non-dependent children under the age of 27 are eligible for coverage.
- A change in status (no longer being a student, or a child reaching the age limit) would also end eligibility.
This is only an allowed change if the coverage eligibility is affected in some way. For example, you can't change coverage only because you move, unless the move directly impacts your coverage.
COBRA Qualifying events, Judgments, Decrees or Orders, Entitlement to Medicare and FMLA (Family Medical Leave Act).
Steps After a Qualifying Event:
You can only make changes that are “consistent" with the qualifying event (i.e. coverage eligibility must somehow be affected). You should always check in with your FSA provider about qualifying events. Your Summary Plan Description should list which qualifying events allow you to make changes under your plan.
Note: Not all employers let employees make mid-year changes. If a qualifying event occurs and you want to make a change in your election, you should notify your FSA administrator within 30 days of the event. You can find the contact information for your benefits administrator on the back of your FSA card or by contacting your human resources department.