By Ric Joyner, CEBS, CFCI
Second chart deals with the timelines and implementation issues.
We have received many questions regarding when OTC and FSA caps kick in. OTC is to be removed January 2011. What if your plan year is not calendar? It is our understanding (still in flux) that OTC doesn’t run out until your plan year ends. So if your plan ran June to June OTC would end the following June in ‘11.