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On-Site Clinic - Guidance on "significant benefits" requirement?


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Has the IRS clarified what constitutes "significant benefits in the nature of medical care" beyond the Examples in Q&A 10 of Notice 2008-59?

We're dealing with a free, on-site clinic that offers a level of care somewhere in between the clinic described in Example 1 (physicals, immunizations, allergy injections, minor pain relief, and treatment of on-site accidents), which doesn't render the employees ineligible for HSA/HDHP, and the clinic described in Example 2 (all employee medical needs), which does disqualify them.

All the discussion I've been able to locate merely restates the Examples, and we'd like to know whether the IRS has spoken (even informally) about the shades of gray in between. Thanks.

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