Vol. 46, No. 1
The final Internal Revenue Service rules adopted last year specify exactly which life events—or "changes in status," in IRS jargon—can be the basis of a mid-year change in an employee’s cafeteria plan. According to an analysis by Willis National Benefits Resource, a unit of London-based insurance broker the Willis Group, the seven changes are:
1. A change in an employee’s marital status—such as marriage, divorce, annulment, legal separation or spouse’s death.
2. A change in the number of employee’s dependents caused by birth, adoption, placement for adoption or death.
3. A change in the number of dependents whose care can be reimbursed on a pretax basis, as it applies to dependent-care elections.
4. The start or end of an adoption proceeding as it applies to adoption-assistance elections.
5. A change in residence for an employee, spouse or dependent.
6. A change in employment status of an employee, spouse or dependent. These may include changes in worksite, strike, lockout, starting or ending employment, starting or returning from an unpaid leave of absence, a change in job status (for example, from part-time to full-time) or other changes that affect plan eligibility.
7. A change that causes an employee’s dependent to start or stop meeting the plan’s eligibility criteria. Examples include attaining the limiting age (often 19 years old) and ceasing to be a full-time student.