Has the IRS specifically indicated that electronic elections are permitted for cafeteria plans? Last year's Notice 99-1 and the proposed regulations dealt with this issue only in the context 401(a) retirement plans. I haven't been able to find anything comparable re: cafeteria plans.

Also, is there anything that would preclude a cafeteria plans (or any specific components such as FSAs, dependent care assistance plans, etc.) from allowing automatic continuation of the prior year's election if the participant fails to affirmatively re-elect? I've seen this done with premium only plans, but the FSA regulations seem to contemplate specific annual elections (but I could be reading too much into those). If an annual election is required, could a participant make an election in 2000 that would specifically cover 2001, 2002, etc. (by the terms of the employee's own decision)?

Thanks for any comments or suggestions.