Section 125 - Mixing Medical & Dependent dollars

An employee made a poor estimate on his Section 125 Medical and Dependent Care Reimbursment accounts. He wants to move dollars between the two accounts yet would not exceed the maximum limit of either account. I said no, the two accounts are separate and, barring a qualifying event, can not be changed. I actually read the SPD and it says amounts can not be changed for medical or for dependent care. I see a transfer as a change to the individual account even though the total is remaining the same.

Is this correct and, if so, does anyone know where I can find documentation to support it that specifically discusses transfers?

Thank you.

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