text: California's New FSA Claims Submission Deadline Notice Requirement - Newfront Insurance and Financial Services
  Response: It is possible to provide the notices by the end of the run-out period. For instance, if the 2019 calendar plan year's run-out period is March 31, 2020, it is okay as long as you provide the two notices before March 31, 2020.
  The "before the end of the plan year" language is something we have been looking into possibly cleaning up in the future, since our intent was to ensure the notices are given out before the run-out period deadlines and the funds in the plan year expire.