INSTRUCTIONS FOR MANAGING FSA PARTICIPANT TERMINATIONS

  1. Complete an Account Change Form and return it to GDI’s Enrollment Team. Please include the date of termination and return it as soon as possible to avoid overpayments. For clients with the Benny (debit card), it is critical that GDI be notified ASAP to de-activate the card.
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  2. If your organization is subject to COBRA regulations, you are obligated to offer COBRA on behalf of your Medical FSA plan if the qualified beneficiary has a positive balance at the time of the COBRA-qualifying event. (Please let us know if you need information regarding COBRA for FSA’s).
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  3. To determine the account balance, please call our Customer Service Team at (800) 626-3539 or in Maine at 781-8800.
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  4. If the employee has a negative balance, no action is required.  REMINDER:  Medical FSA’s are subject to the IRS “Uniform Coverage Rule”. This rule allows participants to spend up to their annual election at any time during the Plan Year. It is important to note that employers cannot recoup any funds from the terminating employee who has a negative balance.
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  5. If the employee has a positive balance, you should inform the employee of their rights under COBRA (if your organization is subject to COBRA regulations).  REMINDER:  A terminated employee has the same amount of time as a regular employee (including run-off period) to submit claims for reimbursement for services incurred through the date of termination.
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  6. If the employee elects to continue the Medical FSA via COBRA, complete another Change Form and send to our Enrollment Team to open their account under COBRA.  
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NOTE: The IRS Uniform Coverage Rule does not apply to Dependent Care accounts. Additionally, a terminated employee who has a Dependent Care account can continue to incur expenses and submit for reimbursement to utilize all of the funds in their account. Remember: they can no longer make deposits into their account; but they can incur expenses for reimbursement of their remaining account.