Under the final regs, spouses and dependents of covered employees must be given an indepenent election to continue benefits under COBRA. Is this true for medical reimbursement plans? My thoughts were that COBRA elections should be limited to the employee-participant (who could then submit claims on behalf of spouses and dependents).
The before tax benefits were not available to spouses and dependents, and I'm not sure what benefit would be available for the remainder of the plan year to spouses and dependents.
Any thoughts? Also, do participants in premium conversion plans need an additional notice beyond that provided by the underlying health insurance plans. Seems to be duplicative.

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I think there is a similar issue when an employee with a medical spending account gets divorced. What rights does the former spouse have to the medical spending account under COBRA? I am not aware of any official guidance. I would be interested in how people are dealing with this.