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- Change In Status (CIS)
- Qualifying Events (QE)
- Covered Dependents
- FSA Period of Coverage/Changes
- IRS Special Consistency Changes
- Appeals Process
Change In Status (CIS)
Mid-year changes from one health plan to another are not permitted after the open enrollment. Once the annual open enrollment period closes, you may add or delete dependents to your health plan only under limited circumstances: a qualifying event (QE). Changes must be reported within 45 days of a qualifying event (60 days to add newborns/adoption, or placement for adoption).
Complete a Change in Status (CIS) form and Plan Status Change form and submit to the Benefits Administration Unit. Election changes must be consistent with the event and result in loss or gain of insurance coverage. A partial list of permitted mid-year changes appears below.
Qualifying Events (QE)
- Eligibility for Medicare/Medicaid/Florida Kid Care
- Employment change from full-time to part-time
- Change in Number of Tax Dependents or vice versa (employee or spouse)
- Spouse’s employer’s open enrollment
- Birth of a child
- Beginning or end of employment of a spouse
- Unpaid LOA (employee or spouse) resulting in gain or loss of insurance coverage
- Adoption of a child or placement for adoption
- Significant change in health coverage due to spouse’s employment
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Children age 26 and under: The Patient Protection and Affordable Care Act (PPACA) extended the limiting age for dependent children to the end of the calendar year in which the dependent turns age 26. Former eligibility criteria for this group, such as marital status, financial dependency, student status no longer apply.
Consequently, employees cannot remove a dependent child from coverage due to marriage, or initial employment, unless the child gains other group insurance and enrolls in it. Moving out of the employee’s home and losing financial dependency on the parent are not QEs that would permit the dependent’s coverage to be canceled. The only event that now makes the child ineligible for coverage is enrolling in other group insurance coverage.Back to Top
FSA Period of Coverage/Changes
You can change your Flexible Spending Account (FSA) election(s), or vary the salary reduction amounts you have selected during the plan year, only under limited circumstances as provided by your employer's plan(s) and established IRS guidelines. A partial lists of permitted qualifying events under your employer's plan(s) appear on the following page.
Election changes must be consistent with the event. For example: if you get divorced, an IRS special consistency rule allows you to lower or cancel your Healthcare FSA coverage for the individual involved. The Benefits Administration Unit of Risk Management, will review on a uniform and consistent basis, the facts and circumstances of each properly completed and timely submitted mid-plan year election change form.
To Make a Change: Within 45 days (60 days to add newborns) of an event that is consistent with one of the events on the following page, you must complete and submit a flexible benefits change in status form and health plan status change forms to your Department Personnel Representative (DPR).
These forms may be obtained online at the benefits website. Documentation supporting your election change request is required. Do not delay submission of your change in status and health plan status change forms while you gather your documentation. Simply forward the forms to your DPR and present your documentation as soon as it becomes available. Upon the approval and completion of processing your election change request, your existing elections will be stopped or modified (as appropriate). Generally, mid-plan year, pre-tax election changes can only be made prospectively, no earlier than the beginning of the pay period after your election change request has been received by the Benefits Administration Unit, unless otherwise provided by law. Changes to add a new dependent become effective the first day of the month following receipt of a timely request with the exception of birth, adoption or placement for adoption which become effective as of the event date. Payroll changes to delete a dependent become effective the first day of the pay period following receipt by the Benefits Administration Unit.
Your period of coverage for FSAs is your full plan year, unless you make a permitted mid-plan year election change, terminate employment or lose eligibility for group coverage. A mid-plan year election change will result in split periods of coverage, creating more than one period of coverage within a plan year with expenses reimbursed from the appropriate period of coverage. Money from a previous period of coverage can be combined with amounts after a permitted mid-plan year election change. However, expenses incurred before the permitted election change can only be reimbursed from the amount of the balance present in the FSA prior to the change. Mid-plan year election changes are approved only if the extenuating circumstances and supporting documentation are within your employer's, insurance provider's and IRS regulations governing the plan.Back to Top
IRS Special Consistency Rules Governing Changes in Status
- Loss of dependent eligibility - If a change in your marital or employment status involves a decrease or cessation of your spouse's or dependent's eligibility requirements for coverage due to: your divorce, your spouse's or dependent's death or a dependent ceasing to satisfy eligibility requirements, you may decrease or cancel coverage only for the individual involved. You cannot decrease or cancel any other individual's coverage under these circumstances.
- Gain of coverage eligibility under another employer's plan - If you, your spouse or your dependent gains eligibility for coverage under another employer's plan as a result of a change in marital or employment status, you may cease or decrease that individual's coverage if that individual gains coverage, or has coverage increased under the other employer's plan.
- Dependent care expenses - You may change or terminate your Dependent Care FSA election when a Change in Status (CIS) event affects (i) eligibility for coverage under an employer's plan, or (ii) eligibility of dependent care expenses for the tax exclusion available under IRC § 129.
Appeals Process for Denied Changes
If you have a request for a Change in Status denied, you have the right to appeal the decision by sending a written request within 30 days of the denial for review to the Benefits Administration Unit of Risk Management, ISD. Your appeal must include:
- a copy of the denied request
- the denial letter you received
- why you think your request should not have been denied
- any additional documents, information or comments you think may have a bearing on your appeal
Your appeal will be reviewed and you will be notified of the results of this review within 30 business days from receipt of your appeal. In unusual cases, such as when appeals require additional documentation, the review may take longer than 30 business days. If your appeal is approved, additional processing time is required to modify your benefit elections.
Note: Appeals are approved only if the extenuating circumstances and supporting documentation are within your employer's, insurance provider's and IRS regulations governing the plan.Back to Top
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