HSA / FSA Grace Period interaction - hints on content of coming guidance?

[JDuns]

I saw that the IRS planned to issue more guidance on the interaction of FSAs and HSAs during the grace period.

It is my understanding that, under the guidance to date, if a person had elected to participate in a full service FSA for 2005 and the FSA sponsor amends the program to allow reimbursements during the first 2.5 months of 2006, neither that person nor their spouse would be eligible to contribute to a HSA for the first 3 months of 2006 because they had disqualifying coverage (even if they had used their entire account balance before year end).

Does anyone have any insight into what the guidance might say?

[Gary Lesser]

IRS Plans More Guidance for 401(K) Plans, Including Amendment and Restatement of EPCRS Excerpt:

Link to Guidance

The Department of the Treasury and the IRS have issued their 2005-2006 Priority Guidance Plan listing regulations and other guidance currently under development. See Employee Plans Area (pages 2-4) and HSA and effect of 2-1/2 month rule on page 5. No answers are provided