What Happens to Qualified Transportation Plan Balances When an Employee Leaves?

What Happens to Qualified Transportation Plan Balances When an Employee Leaves?

Qualified transportation fringe benefits are a popular way for employers to support commuting costs while offering tax advantages. But what happens to unused balances when an employee leaves the company? If you’re considering implementing a qualified transportation plan, it’s crucial to understand the IRS rules governing these benefits—especially regarding terminations.

Key IRS Rules for Transportation Plans

Two primary IRS rules shape how balances are treated upon termination:

  1. No-Former-Employees Rule
    Qualified transportation plans cannot reimburse expenses incurred after employment ends. This means terminated employees are ineligible for post-employment transit reimbursements.
  2. No-Refunds Rule
    Unused balances—whether from employer contributions or pre-tax salary reductions—cannot be refunded to the employee. These funds must remain within the plan.

What Can Terminated Employees Do?

Employees who leave the company can still submit reimbursement requests for qualified transportation expenses incurred during employment, as long as they do so within the plan’s run-out period—a grace period for submitting claims after coverage ends.

However, if they:

  • Don’t have enough eligible expenses,
  • Miss the run-out deadline, or
  • Have excess contributions,

…those unused funds are forfeited.

Minimizing Forfeiture Risk Through Plan Design

Employers can reduce forfeiture risk by designing the plan thoughtfully. For example:

  • Limit monthly contributions to the cost of a transit pass.
  • Send regular reminders to employees about their balances and deadlines.
  • Allow election changes to avoid over-contributing.

What Happens to Forfeited Funds?

Your plan document should clearly state how forfeited balances are handled. Options include:

  • Retaining funds to cover plan administration costs.
  • Redistributing funds to other participants (within IRS limits).
  • Complying with state escheat laws, especially if the plan is “funded” (i.e., money held in separate accounts).

Qualified transportation plans offer great benefits, but they come with strict IRS rules. By understanding the limitations and designing your plan carefully, you can support your employees while minimizing forfeitures and compliance risks.

What Happens to Qualified Transportation Plan Balances When an Employee Leaves?

Federal Law Overhauls Employee Benefits: What Employers Need to Know

A new federal law—formerly known as the “One Big Beautiful Bill”—has introduced significant changes to employee benefits. These updates impact everything from dependent care, health savings accounts to Transportation benefits. Here’s a breakdown of the most important changes employers should prepare for. 

Dependent Care Benefits Expanded 

  • DCAP Limit Increased: Starting in 2026, the maximum tax-free amount employees can receive through a Dependent Care Assistance Program (DCAP) increases from $5,000 to $7,500 (or from $2,500 to $3,750 for married individuals filing separately). 
  • Employer Childcare Credit Enhanced: Employers offering childcare services will benefit from a more generous tax credit, encouraging workplace-supported childcare solutions. 

Health Savings Accounts (HSAs) Strengthened 

  • Telehealth Coverage Made Permanent: High-deductible health plans (HDHPs) can now permanently cover telehealth services before the deductible is met, without affecting HSA eligibility. 
  • New HSA-Compatible Plans: Starting in 2026, bronze and catastrophic Exchange plans will qualify as HDHPs. 
  • Direct Primary Care Allowed: These arrangements will not disqualify HSA eligibility if they meet specific criteria. Fees for such services are now considered qualified medical expenses. 

Transportation Benefits Updated 

  • Bicycle Commuting Reimbursements Eliminated: Starting in tax years after 2025, reimbursements for bicycle commuting expenses will no longer qualify as tax-free transportation fringe benefits. This change makes permanent the suspension that has been in place since 2018. 
  • Inflation Adjustments Modified: Minor updates have been made to how exclusion limits for other qualified transportation benefits—such as transit passes and parking—are adjusted for inflation. 

The new federal legislation significantly enhances several core employee benefits including HSAs and DCAPs. These updates not only expand eligibility and contribution limits but also provide permanent tax advantages for both employers and employees. By aligning benefit strategies with these changes, organizations can strengthen their offerings, improve employee satisfaction, and ensure compliance with growing federal standards. 

Source: Thomson Reuters