If we decide to uniformly extend the FSA submission deadline, what will be required to make it happen?

Technically, employers are required to make an amendment to the cafeteria plan document, since the runout period is defined in the plan document. However, given the unique circumstances of COVID-19, it may not be necessary to have a neatly packaged and formal amendment to the plan document. Instead, it would be sufficient to modify the relevant plan term and communicate it to your employees. This might be as simple as preparing an email or memo to covered individuals describing the updated provision. Contact Sterling for help with this.