Required Amendments for Cafeteria Plan and FSA Plan Changes Permitted Under Pandemic Relief

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11.12.21Advisory

Beginning in 2020 and throughout the COVID-19 pandemic, a wide array of relief was made available to cafeteria plans and flexible spending account (FSA) plans under the CARES Act, ARPA, and other legislative acts, notices, and announcements. This relief was optional to plan sponsors who could elect what relief, if any, would be made available to plan participants operationally under their plans. 

If a plan sponsor implemented any of the relief options, plan amendments reflecting how they were implemented are generally required to be made by the end of the calendar year following the plan year that the change relates to. 

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