To better administer pre-tax programs and ensure mid-year election changes are valid, there is an optional field called QLE Change in the election file. This field helps Forma understand when election changes are made due to a Qualifying Life Event. Using the QLE Change field helps ensure the file does not mistakenly overfund or under-fund accounts and can indicate how much to fund an employee in a given period.
What if I can’t provide ‘QLE Change’ data?
If you can’t provide QLE change data, it will not block file processing, but you may receive warnings to notify your team that there’s a mid-year election change. This is applicable to FSA, LPFSA, and DCFSA only. You will not receive election change errors or warnings for HSA, Transit, and Parking.
An EN107 warning will be generated when the ‘Employee Annual Election’ is changed, and an EN108 warning will be generated when the ‘Employer Annual Election’ is changed for an FSA, LPFSA, or DCFSA account whose original account start date is in the past. We allow any change when the account start date is in the future. Generally, there should be a valid reason (QLE) to update the annual election after the account starts.
Records with EN107 and EN108 warnings will still be processed. When you receive one of these warnings, please kindly review if the change is intended.
- Yes: No action is required.
- No: Please correct the election details as soon as possible by loading a new election file to prevent the account from being overfunded or under-funded and to prevent the employee from seeing incorrect information. FSA and LPFSA balances will be updated immediately when we receive an annual election update. All annual election details will be displayed on the Forma member portal.
You will only receive the warning once when the election has been updated. However, you will receive additional warnings if further QLE updates are made to the elections file.
For example, John initially enrolled in an FSA with an annual election of $1000 starting January 1st, 2025. He was married in April, which qualifies him to make an annual election change to take effect on May 1st, 2025. He wants to update the annual election to $3000. John also decides to enroll in DCFSA, which he was not enrolled in earlier. You send an updated election file on May 3rd, 2025:
| Account Type | Employee Annual Election | Account Start Date |
| 2025 FSA | 3000 | 20250501 |
| 2025 DCFSA | 5000 | 20250501 |
- His Forma FSA annual election will be updated to $3000. The FSA balance will be funded with an additional $2000. You will receive a warning EN107, because the election amount was different from the original $1000.
- His Forma DCFSA will be created for the first time. No warning will be generated.
If you continue to send the same information, you will not receive further warnings for these updates. You will receive additional warnings under the following scenarios:
- Forma receives the file to create a QLE and saves it to the system. A new election file is processed with the following data:
| Account Type | Employee Annual Election | Account Start Date |
| 2025 FSA | 3200 | 20250501 |
You will receive an error EN058 because the amount should be $3000 effective on 20250501.
- Forma did not receive the file to create the QLE. A new election file is processed with the following data:
| Account Type | Employee Annual Election | Account Start Date |
| 2025 FSA | 3200 | 20250501 |
You will receive a warning EN107 and the election will be updated to 3200.
Another example, John is a new hire, hired on February 1st, 2025. He initially enrolled in an FSA with an annual election of $1000, effective on February 1st, 2025. You provided that information to Forma. Three days later, John changes his mind and wants to elect $100. You allow retroactive changes, as long as it is within a 30-day window (note: the rule is up to your discretion). You send an updated election file on February 3rd, 2025:
| Account Type | Employee Annual Election | Account Start Date |
| 2025 FSA | 100 | 20250201 |
- His Forma FSA annual election will be updated to $100. $900 will be removed from his balance. You will receive a warning EN107, because the amount was different from the original $1000.
If I can provide ‘QLE Change’ data, what do I put in that field?
If you can provide QLE change data, only use TRUE in the following scenarios. Using the incorrect value may result in an error.
- Account Type is FSA, LPFSA, or DCFSA
- Employee Annual Election is updated
- Employer Annual Election is updated
- The account start date in the new election file should reflect the date when the new election takes place. Make sure to update the account start date so Forma knows when the new election will be effective, and so the system will automatically create a QLE on record.
Generally, you do not need to mark ‘QLE Change’ as ‘TRUE’ for new hire enrollments or for open enrollment elections. Additionally, election changes during open enrollment or for new hires do not require ‘QLE Change’ to be ‘TRUE’.
You will receive an error EN058, to prevent the creation of two different elections on the same date. This happens when:
- You send an updated ‘Employee Annual Election’ and/or ‘Employer Annual Election’
- Given the account start date in the file, the system found that you already created a QLE in a previous file. But the ‘Employee Annual Election’ and/or ‘Employer Annual Election’ are different from the amount you provided earlier when you created the QLE.
This is because a QLE should only allow the employee to make one change, and usually the employee should only have one QLE at a time. Even if you have two QLEs on the same date, there is only one update that can be made.
For example, John elected $1000 starting January 1st, 2025, for his FSA. He was married in April and was qualified to make an annual election change to take effect on May 1st, 2025. He wants to update the annual election to $3000. John also decided to enroll in DCFSA, which he was not enrolled in earlier. You send an updated election file on May 3rd, 2025:
| Account Type | Employee Annual Election | Account Start Date | QLE Change |
| 2025 FSA | 3000 | 20250501 | TRUE |
| 2025 DCFSA | 5000 | 20250501 | TRUE |
- His Forma FSA annual election will be updated to $3000. The FSA balance will be funded with an additional $2000. You will not receive a warning EN107, because you indicated that it is a QLE change. The system will automatically create a QLE on the record.
- His Forma DCFSA will be created for the first time. No warning or error will be generated, and no QLE will be created because it is a new account.
You can continue to send the same file for the rest of the plan year without warnings or errors, if there are no further updates. If there is an update and you send a file as follows:
| Account Type | Employee Annual Election | Account Start Date | QLE Change |
| 2025 FSA | 3200 | 20250501 | TRUE |
| 2025 DCFSA | 4000 | 20250501 | TRUE |
- FSA row will be errored out with error EN058 because a QLE already exists on May 1st, but the annual election is different.
- DCFSA will not be errored out, because there was no QLE created. The system will see it as a retroactive update and change the annual election accordingly. If you provide QLE Change = TRUE, you will not receive a warning.
Let’s say John has another QLE in July, and a file is as follows:
| Account Type | Employee Annual Election | Account Start Date | QLE Change |
| 2025 FSA | 3200 | 20250701 | TRUE |
| 2025 DCFSA | 4000 | 20250701 | TRUE |
- You will not receive a warning or error for both rows. The system will create the QLE for each account and reflect the change.
Another example, John is a new hire, hired on February 1st, 2025. He immediately enrolled in FSA with an annual election of $1000, effective on February 1st, 2025. You provided the information to Forma. Three days later, John changes his mind and elects only $100. You allow retroactive changes, as long as it is within a 30-day window (note: the rule is up to your discretion). You send an updated election file on February 3rd, 2025:
| Account Type | Employee Annual Election | Account Start Date | QLE Change |
| 2025 FSA | 100 | 20250201 | TRUE |
- His Forma FSA annual election will be updated to $100. $900 will be removed from the balance. You will not receive a warning EN107, because you indicated it is a QLE Change. If the QLE Change value is FALSE, you will receive the warning EN107.
Summary: when will I see QLE errors or warnings?
-
EN058 (error)
- QLE Change is irrelevant, whether it’s FALSE or TRUE or NULL
- Account start date is different than Account original start date
- Account start date matches a QLE date(s)
- Current QLE (given the QLE date) has different ‘Employee Annual Election’ or ‘Employer Annual Election’ compared to the election file
- ‘Pay period election’ change is irrelevant
-
EN107 or EN108 (warning)
- Account start date is in the past
- QLE Change is FALSE or NULL
- When QLE Change is TRUE, you should never receive this warning
- ‘Employee Annual Election’ or ‘Employer Annual Election’ is changed
- ‘Account start date’ change is irrelevant
- ‘Pay period election’ change is irrelevant