Q.- Our health FSA plan has a carryover feature. When determining if a COBRA election has to be given to a terminated employee, do we include the carryover amount as part of the calculation?
A.- The carryover amount is not considered when setting the premium amount for COBRA continuation coverage. The carryover amount would be included in determining the amount of benefit a qualified beneficiary has for the remainder of the plan year in which the qualifying event occurred. The carryover is part of the over-spent/under-spent analysis.