ABATax Comments: IRC Section 125, Cafeteria Plan Regulations

American Bar Association > ABA Groups > Section of Taxation > Policy > Public Policy
header
Section of Taxation
Submission to the Internal Revenue Service

Comments Concerning Cafeteria Plan Regulations
Under Internal Revenue Code Section 125

Index

Note: You may download the full file to allow for easier keyword searching and printing. You must have the free Adobe Acrobat Reader to view, search, or print the downloaded file.
Disclaimer
I. Purpose of Submission
II. Executive Summary
III. Comments
A.Significant Cost or Coverage Changes
1.Election Change Based on Change in Other Family Member’s Plan
2.Significant Cost Decrease
3.Health FSA Election Changes
4.Substantial Change in Network Providers
5.Definition of “Significant”
6.Safe Harbor Approach
B.Medicare, Medicaid and other Government Programs
C.Clarity of the Regulations
D.Effective Date of the Proposed 2000 Regulations
E.Comments on the Final 2000 Regulations and previously issued cafeteria plan regulations
1.Is the list of changes in status events an exhaustive list or is it merely a safe harbor?
2.Expanding the scope of the cafeteria plan regulations to apply to other types of programs that provide group insurance
3.Use of electronic claims reimbursement
4.Kindergarten Expenses under a Dependent Care FSA
5.Can coverage under a QMCSO be retroactive?
6.Guidance on non-discrimination testing

Advertisement